From 30 December 2026, large and medium-sized companies that sell coffee, cocoa, wood and other covered products in the European Union must prove those products did not come from recently deforested land. Uganda's exporters will not file the EU paperwork themselves, but their buyers cannot file it without information from them.
What the regulation requires
The EU Deforestation Regulation (Regulation (EU) 2023/1115) covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood, and many products made from them. Before placing these products on the EU market, the company responsible must show three things:
- Deforestation-free: the land where the commodity was produced was not deforested or degraded after 31 December 2020.
- Legal: it was produced in line with the laws of the producing country, including land, labour, environmental and tax law.
- Covered by a due diligence statement: submitted to the EU's information system before the goods are sold or exported.
After two postponements, the rules apply from 30 December 2026 for large and medium companies, and from 30 June 2027 for most micro and small companies. In May 2026 the European Commission published a simplification package and said there would be no further delay.
What buyers will ask Ugandan suppliers for
Expect EU importers, and the traders who supply them, to ask for the following, usually as a condition of the contract:
- Geolocation of every plot. The location of each piece of land where the coffee or other commodity was grown. For plots of four hectares or less, a single point (latitude and longitude) is enough. Larger plots need a polygon showing the boundary.
- A link from each export lot to its plots. Records showing which farms supplied which lot, through collection points, washing stations or hullers.
- Evidence of no deforestation since 2020. Usually a check of the plot locations against satellite forest maps. Buyers may run this themselves, but they will expect clean location data.
- Evidence of legal production. Proof that the supplier is registered and licensed, that farmers have the right to use the land, and that labour and environmental laws were respected.
- Data in a usable format. Many buyers will ask for plot data in GeoJSON, the format used by the EU system, with a consistent farmer and plot ID.
Smallholder supply chains are the hard part. A cooperative buying from thousands of farmers needs a plot location for each of them. Mixing coffee from mapped and unmapped farms in the same lot can make the whole lot unsellable in the EU.
Seven steps to get ready
- Map your supply base. List every farmer, group and collection point you buy from, and estimate volumes.
- Register farmers with consent. Farmer names, IDs and plot locations are personal data under Uganda's Data Protection and Privacy Act, 2019. Explain why you collect them and get consent.
- Collect plot locations. Use a phone or GPS app and trained enumerators. Walk the boundary for plots over four hectares.
- Screen for risk. Check plots against forest-cover maps and follow up on any that overlap forest or protected areas.
- Separate compliant supply. Keep mapped, screened produce apart from other produce from purchase to export.
- Keep legality records. Registration, licences, land and labour documents, kept in one place and easy to share.
- Agree terms with buyers early. Data formats, who pays for mapping, and how often data must be updated.
Where to start this quarter
With less than three months to go for large buyers, the priority is to map the farms behind your EU-bound volumes first, then extend to the rest of your supply base before the June 2027 date for smaller companies. A well-run mapping exercise also gives you something useful beyond compliance: a clean farmer register you can use for extension, finance and certification.
This brief is general information, not legal advice. Check the latest guidance from the European Commission and your buyers.