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Fresh from the EUDR briefing last week, Food Matters Live caught up with Paul Rooke, Executive Director at the British Coffee Association. He discusses what regulation means for coffee as a commodity, why supply chain collaboration is vital and shares his key insights from our Ascot event.

What are some of the unique challenges coffee poses as a commodity for EUDR compliance?

One of the greatest challenges lies in the sheer number and scale of coffee producers. With over 80% of coffee sourced from smallholder farmers and a global total of around 15 million producers, effectively disseminating compliance messages throughout the supply chain presents considerable logistical hurdles.

Unlike some commodities where a shipment might contain produce from only a handful of growers, each 20-ton shipment of coffee could encompass the output of 2,000 to 3,000 growers. This complexity adds another layer of challenge.

Do you believe the December 30th deadline for medium to large businesses is feasible, or do you see a valid argument for extending it?

The European Commission has consistently maintained that reopening the legislation ahead of its planned review period is not feasible. However, it’s worth noting that a new Commission and European Parliament will be in place following the June elections, which leaves room for change.

“Unlike some commodities where a shipment might contain produce from only a handful of growers, each 20-ton shipment of coffee could encompass the output of 2,000 to 3,000 growers.”

A more conceivable scenario might involve a “soft” introduction of the legislation, where financial penalties are withheld for an initial period. It’s also essential to recognise that there are implementation challenges for both the Commission and Member States, some of which may not be prepared to meet their commitments by year-end.

Do you think there’s sufficient support in place for food businesses to navigate incoming regulations?

The adequacy of EU-produced guidance has been a longstanding issue, with a gap between the industry’s queries for additional guidance and the Commission’s proposed coverage areas. Many food businesses, spanning manufacturing and food service sectors, have unanswered questions, particularly concerning commodities like soya and its derivative products. It remains unclear whether the Commission has thoroughly considered the complexities inherent in the journey of raw materials toward finished products.

Are there any insights or resources you could share to assist other retailers on the path to EUDR compliance?

From a coffee perspective, and as a trade association representing companies in the sourcing and manufacturing sectors, we would encourage a greater level of contact and discussion which will, in turn, help to provide a better understanding of how compliance is being met in the supply chain and how this will feed into retailer compliance.

“It remains unclear whether the Commission has thoroughly considered the complexities inherent in the journey of raw materials toward finished products.”

We are working alongside others in the coffee sector, under the auspices of the International Coffee Organisation, to develop a template which will help direct companies to third party solution providers and the services they offer. This will be particularly important as businesses determine the type of external support needed to complete due diligence statements.

How critical is supply chain collaboration for the food and drink industry in achieving compliance?

It’s essential. Given how EUDR rules are interlinked with other sustainability, green claims, and corporate due diligence legislation, a coordinated understanding of information requirements is crucial for effective and meaningful compliance at a reasonable cost.

What insights did you take away from the Ascot event that you’d like to share?

It was interesting to see the similarity in questions and concerns raised across different commodity sectors. This, coupled with the genuine eagerness among attendees to learn, understand, and implement, underscores a real desire within businesses to fulfil the objectives of this legislation. The industry now needs regulators to show the same ambition and willingness to work with them to make it happen.

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