If last year’s conversation was about becoming EUDR-ready, this year’s was about something harder: proving it.
That shift was impossible to miss at World of Coffee in Brussels. Across conversations with exporters, cooperatives, traders, and sustainability teams, one question surfaced repeatedly: Have we done enough?
For many organisations, the answer should be yes. Farms have been mapped. Farmer records have been strengthened. Traceability systems have been implemented. Governments, industry initiatives, and financial institutions have all invested heavily in helping coffee-producing regions prepare.
The uncertainty now lies somewhere else. It isn’t whether the work has been done, but whether it will stand up when enforcement begins.
The conversation has moved from implementation to evidence
Many of the organisations we spoke with, from the Dominican Republic, Mexico, Costa Rica, and Colombia, described significant progress towards EUDR compliance. The conversations were noticeably different from a year ago. There was far less discussion about where to start, and much more about whether existing systems, data, and workflows would satisfy European Competent Authorities once audits begin.
That marks an important transition.
For the past two years, readiness has largely been measured by implementation: mapping farms, collecting polygons, building due diligence processes, and assembling supplier records. The next phase will be measured by something different: whether those records can be defended when they are put to the test.
The regulation hasn’t changed. The conversation around it has.
We’ve seen the same shift beyond the conference floor. In Ethiopia, the Royal Norwegian Embassy-funded ECOM pilot, led by Farm Africa with Farmforce as technology partner, demonstrated that building an EUDR-ready producer record at smallholder scale is achievable. More than 4,500 producers, approximately 4,550 hectares of forest coffee, and thousands of signed consent records were brought into a single operational system designed for due diligence readiness. The challenge is no longer whether this information can be collected, but whether it consistently provides the level of evidence buyers, auditors, and regulators will expect.
The questions around technology have changed too
That shift was reflected in the conversations at the Farmforce booth.
Traceability remained the dominant topic, but visitors were no longer asking whether technology could support EUDR. Instead, they wanted to understand how farmer registration, field mapping, offline data collection, and compliance workflows fit together into an operational system that could be relied on under scrutiny.
One conversation with a specialty coffee organisation in Uganda captured that particularly well. Rather than focusing on a single compliance requirement, the discussion centred on designing an end-to-end farmer management model, from producer registration and field data collection through to ongoing compliance management. Offline capability wasn’t simply a product feature. It was an operational requirement for organisations working across remote sourcing regions.
Equally telling was what we didn’t hear.
Despite extensive discussions around traceability and compliance, there were no recurring requests for entirely new capabilities. Organisations weren’t looking for another mapping tool or another compliance dashboard. They wanted confidence that the systems they had already invested in would support the level of scrutiny they expect to face.
That feels like another sign of a maturing market. The challenge is becoming less about building new systems and more about getting the most value, and the greatest confidence, from the ones already in place.
From implementation to operational confidence
The strongest conversations throughout the week had another characteristic in common: they were grounded in real operations.
Many organisations arrived in Brussels with pilots completed, farmer mapping underway, or sustainability programmes already established. The discussion had moved beyond implementation and towards operational readiness, connecting systems, refining workflows, and preparing for the realities of compliance once enforcement begins.
Cost remains part of larger digital transformation projects, particularly where system integration is involved. But even those conversations reflect a different stage of maturity. The debate is no longer whether first-mile traceability is necessary; it is how organisations can maximise the value of the investments they have already made.
Three observations from Brussels
Three themes stood out across the week.
First, the coffee sector has made substantial progress towards EUDR preparedness. The dominant question is no longer What do we need to do? It is Have we done enough?
Second, traceability is increasingly being treated as operational infrastructure rather than a standalone compliance exercise. The focus is shifting from collecting information to maintaining records that can withstand regulatory scrutiny throughout the supply chain.
Finally, the next challenge is unlikely to be collecting more data. It will be having greater confidence in the data already collected, and being able to demonstrate that confidence when it matters.
The coffee sector has spent the past two years preparing for EUDR. The next phase will be defined by confidence: confidence that every polygon can be defended, every farmer record is complete, and the evidence is already there when scrutiny arrives.
Preparing for EUDR was the first milestone. Proving it may be the harder one.
