EUDR deadlines for Kenyan exporters: what applies from 30 December 2026

The dates that now apply

Regulation (EU) 2025/2650, adopted on 19 December 2025 and published in the Official Journal on 23 December 2025, rewrote the application article (Article 38) of the EU Deforestation Regulation, Regulation (EU) 2023/1115.

The later date for micro and small operators does not apply to timber products covered by the old EU Timber Regulation, which follow 30 December 2026. Coffee is not affected by that exception.

Who the obligations fall on

Under the EUDR, an operator is the person who, in the course of a commercial activity, places relevant products on the EU market (makes them available there for the first time) or exports them from the EU. For Kenyan coffee, that is usually the EU importer or roaster that first places the coffee on the EU market, not the Kenyan exporter. The exporter's role is to supply the information the operator needs.

In practice the effect on Kenya is the same: your buyer cannot place the coffee on the market without a due diligence statement, and it cannot write that statement without your plot locations, production dates and supplier details. Expect the questions to arrive well before 30 December 2026.

What else changed in December 2025

• One statement, filed once. The due diligence statement is submitted by the operator that first places the product on the market. Downstream operators and traders no longer file their own statements; they keep the reference number of the original one.
• A simplified regime for micro and small primary operators. Natural persons and micro or small enterprises in a country classified as low risk, selling products they produced themselves, submit a one-time simplified declaration instead of due diligence statements.
• Records. Operators keep due diligence statements for five years, and the Commission's summary notes that operators must keep information on their suppliers and customers for five years.
• Reviews. The Commission was required to carry out a simplification review and report by 30 April 2026, and a general review of the Regulation by 30 June 2030. Check whether the simplification review has led to further amendments before you finalise your plans.

What has not changed

The substance of the test is the same. Coffee placed on the EU market must be deforestation-free, meaning produced on land not deforested after 31 December 2020; it must be produced in line with the relevant laws of Kenya; and it must be covered by a due diligence statement that includes the geolocation of every plot it came from. The geolocation rule (a point for plots up to four hectares, a polygon above) is explained in our article on the 4-hectare polygon rule.

The EUDR covers cattle, cocoa, coffee, oil palm, rubber, soya and wood. Tea is not covered, so tea exporters face no EUDR deadline, although their buyers may ask for similar traceability under their own policies.

A practical plan for the next months

1. Ask each EU buyer what it needs and by when: data fields, format (points or polygons, file type) and the first shipment it applies to.
2. Map your supply base: which cooperatives, wet mills and estates supply which lots, and which of them already have plot data.
3. Close the plot-data gap: register farmers and plots, collect locations in the field and check them for quality.
4. Check plots against forest maps for the 2020 cut-off and record the result.
5. Gather legality evidence: land and membership records, licences and the documents your buyer asks for.
6. Link it to shipments: make sure each lot you sell can be tied to the plots and the production period behind it.

We build farmer and plot registers and provenance exports for coffee; see field-data platforms and OriginTrace.