Commission agrees on EUDR
29. June 2023 European Comission Parliament settled details on EUDR Legislation.
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 have our due diligence system ready by April 2025.
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.
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.
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.
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. In Q3/2024 we started 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.
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.
We closely monitored the practical implementation of the legislation and updated our timelines based on the renegotiations regarding the implementation date of the regulation.
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 updated deadline for our internal due diligence system to be ready is in Q1 2025. By then we will be able to process all necessary data and can provide Due Diligence Statements, depending on customer needs and involved supply chains. Once the regulation formally comes into application on 30th December 2025, we will of course always provide Due Diligence Statements with all relevant orders.
Due Diligence Statements cannot be created and shared retroactively. Depending on the supply chain geolocations or Due Diligence Statements can be shared during the phase-in period in 2025. Availability and the conditions for this scenario need to be negotiated individually with the trader responsible.
The geolocations of products imported after the application date on 30th December 2025 will be referenced in the Due Diligence Statement in the EU information system which will be shared with customers. In case customers are per regulation required to conduct their own due diligence, we will share the relevant geolocations separately.
No geolocations of farmers will be shared with customers prior to a relevant purchase due to privacy and data security reasons.
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 products 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, not all products are certified, and we are neither relying on certification as 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 existed prior to the cutoff date in 2020. This is supported by the fact that many crop plants including coffee trees need to mature at least 5 years to bare harvestable fruits. Additionally, the incompliance risk regarding legality of production will be assessed based on various sources such as questionnaires and external databases to verify adherence to local laws.
Over the course of the past months, we have reviewed many suppliers and supply chains. As we are mostly working with smallholder producing organizations, this results in analyzing multiple thousand land plots. So far, we can confirm not to have found major issues with deforestation. Nevertheless, given the vast number of land plots under examination and the remote analysis approach, some deforestation risk alerts are inevitable due to the inherent nature of our supply chains. Whenever these risks are identified, they will be verified to exclude potential false positives. Only if a false positive can be excluded clear measures are following to assess whether the risk can be mitigated or in extreme cases producers need to be excluded or business relations need to be ceased.
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.
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.
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:
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.