Trabocca's EUDR Compliance:
Our approach for
deforestation-free coffee

Due Diligence System

Trabocca is actively preparing to comply with the European Union Deforestation Regulation (EUDR) by developing an internal due diligence system to ensure that its coffee supply chains are deforestation-free. We are engaged in ongoing compliance efforts, including data collection, supplier support, and verification through third-party tools, with a target to be fully compliant by December 2024.

Learn more about Trabocca’s approach to supply deforestation-free coffee under EUDR compliance, find answers to frequently asked questions, or download our EUDR Statement for a comprehensive overview.

 

New coffee plant in front of huge native tree.
Shade grown coffee under native trees at Burka Gudina Farm in Limmu Kossa, Jimma, Ethiopia.
Coffeepicker in semi-forest coffee Farm.
Coffeepicker at Burka Gudina Farm in Limmu Kossa, Jimma, Ethiopia.

Timeline

of EUDR: Deforestation-free coffee

Commission agrees on EUDR

29. June 2023

European Comission Parliament settled details on EUDR Legislation.

Trabocca starts EUDR preparations

July 2023

Trabocca's EUDR Task Force starts building the framework of our internal due diligence system.

Deforestation questionnaire for suppliers

September 2023

Starting supplier engagement and extensive data-collection to asses risks within supply chains.

Pre-assessing deforestation risks

November 2023

Identifying potential risks in supply chains via Global Forest Watch Pro, to define key action points in ongoing compliance project.

Testing EU Information System pilot

December 2023

Trabocca, as one of the selected companies takes part in EU Information System pilot test phase to evaluate its functionality.

Expanding sustainability team

April 2024

Hired a new Sustainability Specialist to support in EUDR compliance project.

Announcing partnership with Osapiens

July 2024

Trabocca partners up with Osapiens, a solution provider for precise and reliable EUDR compliance analysis.

Osapiens - Solution provider

Internal target deadline for EUDR system

1. November 2024

Earlier internal deadline to ensure system readiness for compliance of shipments arriving in early 2025.

EUDR becomes applicable for Trabocca

30. December 2024

EUDR legislation becomes effective for Trabocca. From this date onwards all coffee imported into the EU will be compliant and deforestation free.

What is Osapiens?

Trabocca announces its partnership with Osapiens, a compliance solution provider, to enhance its supply chain management, quality control, and compliance efforts. Osapiens' platform is designed to offer holistic solutions rooted in traceability fundamentals, leveraging technology to improve transparency and efficiency within supply chains. This collaboration aims to streamline processes, ensure regulatory compliance, and create efficiencies that benefit Trabocca's business partners and purchase orders, while integrating various data sources to optimize overall supply chain performance.

EUDR FAQ

What is the EUDR?

The European Union Deforestation Regulation (EUDR) is a new law adopted by the European Union to prevent the import of goods linked to deforestation and forest degradation. It requires companies to ensure that products, such as coffee, imported into the EU do not contribute to deforestation. This regulation aims to reduce the environmental impact of global supply chains and promote sustainable practices.

How do you ensure compliance?

Please see statement above. We have been working on this topic since its implementation in 2023. We have a continuous and dedicated task force led by our sustainability team working on the matter and in Q3/2024 we will be starting to work with one of the leading and high quality EUDR SaaS companies to ensure traceability and compliance of all our EU destined coffee supply chains.

What is a DDS?

A Due Diligence Statement (DDS) is a proof of a set of processes and measures that companies must implement to comply with the EUDR. It involves gathering information about the origin of the coffee, assessing the risk of deforestation in the supply chain, and taking steps to mitigate any identified risks. The DDS ensures that coffee imported into the EU meets the deforestation-free requirements.

When will you be ready to comply with EUDR? When can you share DDS codes?

Our EUDR compliance project has been ongoing since over a year. Please be aware that collecting all required data and setting up the systems is a lengthy project. The deadline for our internal due diligence system to be ready is in early Q4/2024, which is when shipments leave ports of origin and might arrive in the EU in early 2025. By then we should be able to process all necessary data and will only import compliant products.

However, per regulation we are required to provide DDS codes to relevant products not earlier than by 30th of December 2024. Although we’d like to follow some requests to provide these earlier, the DDS codes can technically not be provided before December 2nd, 2024. This is due to the EU information system producing these codes not being live before that date. We are closely monitoring the practical implementation of the legislation and will update our timelines in case of changes in the public launch of the EU Information System. Please respect that we cannot cater for any individual requests of due diligence statements and DDS codes prior to these dates.

Can you share geolocations of products we have been buying from you in the past?

Geolocations of products sold after the in-action date will be shared with costumers through the EU information system and will be referenced via the respective DDS codes. Aside of that, we are not allowed to share any geolocations of farmers with costumers prior to a relevant purchase due to privacy and data security reasons.

Do you expect any incompliant products?

We do not expect substantial shares of our supply chains to be incompliant. Multiple factors indicate low rates of incompliance risks. Our track record in certified coffee enables not only traceable supply chains but also high standards when it comes to adherence to local laws, safeguarding protected areas and anticipating deforestation through counter measures such as afforestation and agroforestry systems. All certified products in our portfolio are third party audited and verified, showcasing a good indicator for regulatory compliance. However, we are neither relying on certification as a sole proof of compliance nor as proof of no deforestation.
Deforestation-freeness will be assessed with precise satellite imagery and drone footage, which will prove that in almost all cases plantations have been existing prior to the cutoff date in 2020. This is supported by the fact that many crop plants including coffee trees need to mature up to 5 years to bare harvestable fruits. Additionally, the incompliance risk regarding legality of production will be assessed based on various internal and external databases to verify adherence to local laws.
If risks are identified, clear measures will follow to assess whether these can be mitigated or in extreme cases business relations need to be ceased.

What happens if a company fails to comply with the EUDR?

If a company fails to comply with the EUDR, it may face penalties such as fines, import bans, or other legal actions. Non-compliance can also lead to reputational damage, as consumers and stakeholders increasingly demand sustainable and ethically sourced products.

Corporate policies

We are part of Acomo N.V., an international group of ingredient producers. All employees of Trabocca and its entities across the world sign the group Code of Conduct. The group also has two additional policies on human rights and environmental impact.

 

Sourcing policies

At Trabocca, we go beyond these policies for our own operations and our supply chain. Most of the impact our business has on the environment and on people, occurs at origin. To make sure we monitor relevant risks and act on adverse impacts, or opportunities for positive impact, we have a thorough, mandatory vendor approval process and Due Diligence System. This system is based on the OECD Guidance for responsible business conduct and is a continuous process that helps identify risks relating to human rights, labour rights and the environment with a view to ending, preventing or mitigating those risks. We use social certificates and Sedex Radar (Trabocca reference nr: ZC5000022697) to assess and monitor risks in our supply chain. Radar creates a risk score per supplier based on inherent risks (determined by a multitude of information sources) and site characteristics (based on SAQs and SMETA audit reports).

Read more detail in our policy documents:

 

Get in touch

At Trabocca, our commitment to EUDR compliance is driven by a dedicated task force that meets frequently to ensure our supply chains are compliant as quickly as possible. This team is made up of Trabocca employees and supported by sustainability and IT experts from Tradin Organic. Since the core of our sourcing strategy has always been the close relationship with our partnered producers, we feel confident in providing the required information by collaborating closely, educating, and working hand-in-hand with our partners. If you have any questions, doubts, or feedback, we encourage you to reach out to us at sustainability@trabocca.com. We’re here to help and eager to hear from you.