EUDR geolocation for Kenyan coffee and tea exporters: the 4-hectare polygon rule explained

Coffee is covered. Tea is not.

The EU Deforestation Regulation (EUDR), Regulation (EU) 2023/1115, applies to seven "relevant commodities": cattle, cocoa, coffee, oil palm, rubber, soya and wood (Article 2(1)). Tea is not one of them. Kenyan tea exported to the EU does not need an EUDR due diligence statement or EUDR geolocation.

Tea exporters still hear the word "polygon" from buyers. That demand comes from buyers' own sourcing policies and from sustainability certification, not from the EUDR. The method is the same, so most of this article is useful to tea producers too, but the legal obligations described below apply to coffee.

What the law says

Article 9(1)(d) requires the operator to collect the geolocation of all plots of land where the commodity was produced, with the date or time range of production. Where a product contains coffee from several plots, the geolocation of every plot must be included.

Article 2(28) defines geolocation. In plain terms:

• A plot is located by latitude and longitude, with at least one point and at least six decimal digits.
• For plots of more than four hectares used to produce relevant commodities other than cattle, the location must be a polygon, with enough points to describe the perimeter of the plot.

So a coffee plot of four hectares or less can be declared with a single point. A plot larger than four hectares needs its boundary. Six decimal digits of a degree is roughly ten centimetres on the ground: the point has to come from a GPS reading, not from a village centre on a map.

The location matters because of the cut-off date. Under Article 2(13), coffee is "deforestation-free" only if it was produced on land that has not been subject to deforestation after 31 December 2020. The geolocation is what lets an operator, or a competent authority, check each plot against forest maps.

What it means for Kenyan coffee

Kenya's coffee is mostly grown by smallholders. The European Forest Institute's preparedness check for Kenya reports that smallholders produce about 70% of the crop, organised in 605 active cooperatives that operated 1,122 primary wet mills in 2022/2023. In practice smallholders market their coffee through their cooperative. Under Kenya's coffee regulations an estate has at least five acres (about two hectares) under coffee, and smallholder plots are mostly smaller than that, so they sit well under the four-hectare threshold and a single point per plot meets the legal minimum. Larger estates exceed four hectares and need polygons.

The harder problems are not the threshold. The same report identifies three:

• Kenya's traceability system works from the wet mill to export, through out-turn numbers at the dry mill, but does not link the coffee to the plots where it was grown.
• There is no national register of coffee farmers; the data sits with each cooperative.
• Coffee is bulked at the wet mill, often from a few hundred to more than a thousand farmers a season, so tracing a bag to one farm is very difficult. The report suggests declaring all plots that supplied a wet mill in a given period, an approach it says should be tested with competent authorities.

The report also notes a government-led mapping effort: as of 25 October 2024, about 20% of Kenya's coffee area had been digitised, and exporters, cooperatives and service providers were collecting their own data in parallel.

Points or polygons: what to collect

The law sets a minimum. Buyers may ask for more than the minimum, such as a polygon for every plot whatever its size, because a boundary gives a more reliable check against forest maps than a point. Ask your buyers early, before field teams go out. Then:

1. Start from the member register. Each plot should link to a farmer and a cooperative membership number, so that the location can be tied to deliveries.
2. Measure in the field. Record a point at the plot, or walk the boundary for a polygon, with a phone or GPS receiver and an accuracy reading saved with each record.
3. Check the geometry. Reject polygons that cross themselves, overlap a neighbour or sit in the wrong county. A polygon is only useful if it is valid.
4. Check against forest maps for the 31 December 2020 cut-off, using both national and global layers.
5. Keep it current. Plots change hands and are subdivided; plan a refresh each season.

A note on the December 2025 amendment

Regulation (EU) 2025/2650 created a simplified regime for "micro or small primary operators": natural persons or micro and small enterprises in a country classified as low risk that place on the market products they produced themselves. They submit a one-time simplified declaration and may give the postal address of the plot instead of its geolocation, where the address clearly corresponds to the plot. Check the Commission's current country classification and your own status before relying on it; for most Kenyan coffee sold through cooperatives and exporters, plot geolocation is what buyers will ask for.

For the dates that now apply, see EUDR deadlines for Kenyan exporters. We build farmer and plot registers and map plot boundaries; see geospatial mapping and field-data platforms.