A Ground-Up Perspective on EUDR: Its Regional Impact and Unintended Consequences | 25, Issue 23
For her Master of Science in Climate Change and Development, MARÍA PAZ LOBO spent time in the coffee region of Amazonas, Peru, researching how the EUDR has and could change farmer livelihoods. She shares key findings from her dissertation.
Witnessing the rollout of the European Union Deforestation Regulation (EUDR) over the past four years, I have been reminded of a quote attributed to one of Aesop’s fables: “Be careful what you wish for, lest it come true.” While popular narratives often depict the private sector as anti-government and anti-regulation, the truth is that over the past decade many coffee businesses have wanted and worked hard to build closer relationships with public-sector agencies in coffee-producing and coffee-consuming countries alike, in pursuit of a more sustainable coffee industry. These companies recognize that regulation can create a level playing field for competitors in arenas of public interest—for example, public health—and that, despite the up-front costs of complying with regulations, the long-term benefits to customers and stakeholders are critical for the sustainability of the enterprise (not to mention the industry it belongs to).
In Issue 22, we heard from Eileen Gordon-Laity of the European Coffee Federation (ECF) about the substance of the legislation and what it means for coffee businesses working in EU countries or with EU partners. Like the European Council and partially the European Parliament—the entities responsible for developing and ratifying EU legislation—the ECF is based in Brussels, so it has been close to the center of activity. In this issue, María Paz Lobo takes us far from the policymakers in Belgium to explore the implications of the EUDR for coffee farmers in Amazonas, Peru—a region that is directly affected by the EUDR. The author’s research reveals that while this legislation may be new, the power dynamics are familiar: farmers are only minimally aware (if at all) of the regulation, and they have very few resources available to help them prepare for a new set of expectations for compliance and documentation.
This is a problem, and not just for those farmers she interviewed; large-scale non-compliance in Amazonas would affect everyone sourcing coffee for the EU market from this region (and the myriad regions like this one across Peru and in coffee-producing countries around the world).
Like so many problems, the challenge of achieving compliance presents opportunities, especially considering the recently announced 12-month delay in implementation. A lot of work has already been done by EU companies of all sizes, institutions in coffee-producing countries, and intergovernmental organizations (among others) to communicate the upcoming changes to the affected parties and to develop and test new technology for mapping coffee landscapes. Progress has been painful at times, and no doubt the EUDR will continue to challenge the coffee industry. Nevertheless, despite the critiques it regularly receives, the legislation has prompted investment at an unprecedented rate and created a clear mandate for companies to act. It may not have been the regulation we wished for, but it has a lot to teach us.
KIM ELENA IONESCU (she/her)
Chief Strategy Development Officer
Between 2023 and 2024, I attended no fewer than 15 lectures on the European Union Deforestation Regulation (EUDR). Like many of my sustainability colleagues in the coffee industry, I felt overwhelmed by the constant discussions about geolocations, data resolutions, and monitoring platforms.
I felt as if I was losing sight of the overall objective and the real, day-to-day implications the regulation could have on coffee farmers. I found myself grappling with conflicting views and feelings about the EUDR’s purpose and impact, intensified by the fact that most opinions I heard came from voices in the Global North.
Figure 1. I conducted semi-structured interviews with coffee farmers, including Marilina Rodriguez (right).
In May 2024 I embarked on a mission across the slopes of Amazonas, Peru, aided by a cooperative, a coffee transnational,[1] and a sturdy Honda motorcycle. I was conducting research for my master’s dissertation, and the idea was to listen to as many farmers as possible, capturing their socioecological perspectives on deforestation, climate change, and livelihoods, and their interactions with external stakeholders. Could I help build a bottom-up narrative that would defy and contrast with the top-down regulatory approach of the EUDR? Could I zoom in on all the complexities, inequalities, and dynamics that occur at a regional level to better understand how the EUDR could have unintended consequences on a specific region, consequently leading to potential livelihood transformations for coffee farmers?
During my time in Amazonas, I conducted 12 semi-structured interviews with coffee farmers and 9 with local experts (including a cooperative manager and Amazonas specialists from the Ministry of Agriculture, Peru). Here, I’ll share some of the most relevant findings from my study, focusing on insights that have often been overlooked in current EUDR discussions but that are particularly important because they reflect the direct perceptions and experiences of coffee farmers.
About Amazonas, Peru
Amazonas is the fourth-largest coffee-producing region in Peru, contributing about 15% of the country’s total production. Of this, 39% is exported to the EU, making it the primary market. In addition, coffee production is the region’s most vital economic activity and a key source of monetary income for the local population.[2] According to the 2024 Farmer Registry, over 75,000 farms were identified in the Amazonas Department, 92% of which are smaller than 10 hectares. The Registry also revealed that fewer than 10% of farmers reported receiving technical assistance, only 5% had access to financial support, and fewer than 1% utilized technology on their farms.[3]
The region is known for having minimal intervention from the state, private companies, and civil organizations, especially compared to its neighboring departments Cajamarca and San Martin, which are far more recognized in the coffee industry. There is a strong narrative around Amazonas as a “virgin” region for coffee, with many companies becoming more aggressive in recent years as they recognize a high potential to increase coffee production. One local expert referred to Amazonas as one of the “newest” regions. Historically, limited access to the coffee areas as well as little promotion caused delays in the region compared to other regions. However, as the expert explained to me, production has increased in recent years and “it is going to continue to explode."
Power Imbalances and the Burdens of Compliance
The European Commission named coffee, along with six other commodities, the most relevant in relation to commodity-driven deforestation. Coffee was therefore included in the EUDR, with the goal of combating forest loss and associated climate change. For those interested in learning more, the European Coffee Federation’s Eileen Gordon Laity wrote about the most important details of the regulation in a previous issue of 25.[4]
Although our coffee industry has not been shy with critique about the amount of work, time, and resources the regulation has required, many scholars have been critical of the EUDR for different reasons. One of those reasons is that unilateral (“one-way street”) regulatory approaches to the climate crisis are embedded in colonial relationships of injustice, with significant power inequalities between the Global North and Global South.[5][2] Scholars argue that the EUDR disproportionately places the compliance burden on producing countries. They contend that it overlooks systemic drivers of tropical deforestation—such as the EU’s overconsumption of agro-commodities—and instead shifts responsibility to producing nations, framing deforestation as a failure of governance, poor production practices, and inadequate monitoring.[6]
This EU-centric approach risks causing unintended consequences that have already been flagged by various organizations, including increased administrative and financial burdens, misrecognition, exclusion from markets, and adverse effects on smallholder farmers’ livelihoods.[7][8][9][10]
Figure 2. Overlooking Alex's farm in Lonya Grande, Amazonas.
Deforestation Drivers Are Complex and Multifaceted
During my interviews, I was struck by the lack of consensus regarding the attribution of blame for deforestation, even among the local experts consulted. Responses varied significantly, with no agreement even among farmers within the same cooperative or community. The role of coffee plantations as a cause of deforestation was particularly contested, highlighting the complexity and context-specific nature of the underlying causes of deforestation.
Understanding who drives deforestation, why it occurs, and where it takes place requires a nuanced and highly contextualized approach. Some drivers of deforestation, such as poverty, population growth, farming practices, and land tenure remain contested among scholars. For example, it is difficult to disentangle poverty from other influences such as political, geographical, and temporal trends, all of which can shape deforestation patterns.[11]
Smallholder swidden agriculture (where land is cleared for cultivation by slashing or burning vegetation) is often blamed for deforestation in Peru. In reality, its causes are more complex. Between 2013 and 2021, Peru lost 1.4 million hectares of forest, with about 63,000 hectares lost in Amazonas alone.[12] Nearly 80% of this loss occurred in patches smaller than 1 hectare. While agricultural expansion—including coffee cultivation—has been identified as a cause of forest loss in the region, traditional practices like fallow management (when land is harvested then left unsown to restore fertility), agroforestry, and crop rotation also play a role. For these reasons, when deforestation is reduced to simple causes and narratives, this can result in ineffective policies that overlook cultural practices and can worsen rural poverty. Effective strategies must consider farmers’ livelihoods and socioecological perspectives to avoid further marginalizing vulnerable communities.
Farmers’ Current Coffee Area Could Determine Expansion
Another notable trend I found in the interviews was that farmers with less area shared the aspiration of having more land, as this was associated with higher production. Farmers with a greater area (more than eight hectares) viewed additional land as requiring more investment in labor, as this would surpass available family labor. One of the farmers I interviewed, who owns a ten hectare farm, mentioned: “We have already set a limit more or less of the maximum we could cultivate, and we are practically there already. It is expensive to grow coffee; a lot is invested in labor.”
Among my interviewees, farmers that had less than 5 hectares shared negative perceptions in terms of quality of life, with many highlighting the lack of access to adequate basic services and consistent low prices received for their coffee. “I think the quality of life is very poor. We barely have enough to eat.”
As Jason Hickel et al. argue, EU and other Global North consuming markets play a role in perpetuating farmer poverty. They posit that “cheap labor and raw materials in the Global South are not ‘naturally’ cheap, as if their cheapness was written in the stars. They are actively cheapened.”[13]The reality is that the costs of production and living for smallholder coffee farmers are not recognized in coffee prices, contributing to poor quality of life, low productivity, and potential aspirations for land expansion to maintain or increase production.
There are aspirations for expansion throughout the supply chain, driven by increased awareness and promotion of coffee from Amazonas. Local experts mentioned significant increases in demand for coffee in the region, especially in the last decade. This creates unavoidable tensions between the industry’s ambitions for expansion, farmers’ own goals of increasing production, and regulatory approaches like the EUDR, which impose constraints on how such expansion can occur.
While many point to increasing productivity as the answer (which undeniably could have direct benefits for coffee farmers’ livelihoods), it is important to highlight the high investment and support this would require in a region that has historically been neglected. Several studies have highlighted the presence of the Jevons Paradox (when improvements in resource efficiency lead to increased overall consumption of that resource, rather than a decrease). For instance, it has been observed that increases in agricultural intensification and yields can lead to higher profits, which in turn incentivize further agricultural expansion and thus deforestation.[14][15]
There is Little Overall Awareness of the EUDR
Most farmers I interviewed were unaware of the existence of the EUDR, reflecting a clear lack of inclusion and recognition of the target group within the policy process. Similarly, local governmental institutions interviewed also had little knowledge about the regulation. In one instance, a government official admitted he learned about the EUDR through a cousin who worked as a coffee exporter, as he had received no official notification.
Additionally, most of the local experts I interviewed viewed the EUDR negatively, despite their different backgrounds and roles within the coffee sector. A common concern was the lack of clarity on how coffee farmers could benefit. Some interviewees contrasted the EUDR to certification schemes, noting the absence of direct incentives like price premiums offered by some certifications. Nonetheless, a few of the local experts mentioned that the regulation’s traceability requirements might encourage more farmers to join associations, cooperatives, or farmer organizations, which may ultimately have a positive impact—particularly for the significant percentage of coffee farmers who continue to grow, process, and sell their coffee independently.
Collection 1. (left to right) Edison’s farm, coffee pickers gathering at Alex's farm in Lonya Grande, Henry with the Honda motorcycle that I used to travel to and around Amazonas.
Unintended Consequences of the EUDR Are Already in Sight
Although it is premature to draw definitive conclusions on the impact of the regulations, certain unintended consequences of the EUDR were already becoming evident in the specific local context in 2023 and 2024. For instance, the cooperative involved in the research highlighted the significant financial burden they are shouldering to collect the necessary geolocation data, with little support from buyers or governmental institutions.
Generally, the farmers I interviewed reported receiving minimal government assistance. This lack of support is particularly relevant in the context of the regulation, as insufficient government intervention exacerbates the power imbalance between the EU’s legislation and the smallholder farmers most affected by it. Government action is crucial as a “buffer” to help mediate between large-scale regulatory demands and the local realities of coffee producers.
The interviews also revealed another risk for coffee farmers: diminished bargaining power in pricing. Farmers deemed noncompliant or at risk of noncompliance may struggle to negotiate fair prices for their coffee, potentially forcing them to sell to intermediaries who could exploit their vulnerable position. This risk is even more pronounced for farmers not affiliated with any cooperative or private company. One local expert noted: “My big concern is what happens to the other 60% of producers who are not organized in any chain, who do not receive technical assistance, and who sell coffee to the best low-quality buyer.”
Effective strategies must consider farmers’ livelihoods and socioecological perspectives to avoid further marginalizing vulnerable communities.
Looking Ahead
As I write this on the final day of 2024, a 12-month delay in the EUDR has been confirmed.[16] By now, most industry players directly affected have likely developed at least a tentative plan for the road ahead—not necessarily inexpensive, straightforward, or foolproof—but a strategy to ensure compliance, nonetheless.
My hope is that this delay gives us the opportunity to pause and reconsider the underlying issues that have been overshadowed by the urgency of compliance. It’s crucial that we balance the imperative to halt deforestation with an honest acknowledgment of the power imbalances inherent in the regulation and the historical socioeconomic marginalization of coffee farmers. We must deepen our understanding of the drivers of deforestation on a regional scale, monitor the potential unintended consequences of EUDR as they unfold, and consider the impact on already vulnerable groups such as women, Indigenous populations, and migrant workers. These consequences, if unchecked, will only exacerbate other pressing challenges like climate change and poverty that many farmers are already grappling with. ◊
MARÍA PAZ LOBO (she/her) is currently the Sustainability Manager at The Coffee Source based in Costa Rica.
References
[1] I want to thank Cooperativa Laguna de los Condores and Volcafé Peru for connecting me with the coffee farmers I interviewed, providing the transport to all the farms, and making sure I was safe along the way. This work was guided by my great professor and dissertation supervisor Dr. Andrew Ainslie at University of Reading, whom I thank immensely.
[2] Ministerio de Comercio Exterior y Turismo Peru, “Reporte Comercio Regional Amazonas 2022,” gob.pe/institucion/mincetur/informes- publicaciones/3502673-reportede-comercio-reporte-comercio-regional-rcr-amazonas-2022-i-sem.
[3] Ministerio de Desarollo Agrario y Riego Peru, “Padrón de Productores Agrarios,” accessed December 31, 2024, ppa.midagri.gob.pe/.
[4] Eileen Gordon Laity, “Cracking Coffee Regulation: The Coffee Supply Chain Challenges with EUDR Compliance,” 25, Issue 22 (2024), sca.coffee/sca-news/25/issue-22/cracking-coffee-regulation.
[5] Elke Verhaeghe and Sabaheta Ramcilovic-Suominen, “Transformation or More of the Same? The EU’s Deforestation-Free Products Regulation Through a Radical Transformation Lens,” Environmental Science & Policy 158 (2024): 103807, doi.org/10.1016/j.envsci.2024.103807.
[6] E. M. Kumeh and Sabaheta Ramcilovic-Suominen, “Is the EU Shirking Responsibility for Its Deforestation Footprint in Tropical Countries? Power, Material, and Epistemic Inequalities in the EU’s Global Environmental Governance,” Sustainability Science 18, no. 2 (2023): 599–616, doi.org/10.1007/s11625-023-01302-7.
[7]Coalición por una Producción Sostenible,"Impact Study of the European Union Regulation on Deforestation Free Products on Coffee and Cocoa Value Chains in Peru" (2024), produccionsostenible.org.pe/wp-content/ uploads/2024/02/Executive-Summary-EUDRImpact-Study-on-coffee-and-cocoa.pdf.
[8] Wageningen University & Research, “Deforestation and Forest Degradation in Coffee Supply Chains” (2023), edepot.wur.nl/630209.
[9] E. Zhunusova et al., “Potential Impacts of the Proposed EU Regulation on Deforestation-Free Supply Chains on Smallholders, Indigenous Peoples, and Local Communities in Producer Countries Outside the EU,” Forest Policy and Economics 143 (2022), doi:10.1016/j.forpol.2022.102817.
[10] J. Grabs et al., “Designing Effective and Equitable Zero-Deforestation Supply Chain Policies,”Global Environmental Change 70 (2021), doi:10.1016/j.gloenvcha.2021.102357.
[11] Center for Global Development, cgdev.org/sites/default/files/stopping-deforestation-what-works-what-doesnt.pdf.
[12] Ministerio del Ambiente Peru, “Plataforma de Monitoreo de Cambios Sobre La Cobertura de Los Bosques,” accessed December 31, 2024, geobosques.minam.gob.pe/geobosque/view/index.php.
[13] J. Hickel et al., “Imperialist Appropriation in the World Economy: Drain from the Global South Through Unequal Exchange, 1990–2015,” Global Environmental Change 73 (2022), doi:10.1016/j.gloenvcha.2022.102467.
[14] F. F. Goulart et al., “Sparing or Expanding? The Effects of Agricultural Yields on Farm Expansion and Deforestation in the Tropics,” Biodiversity and Conservation 32, no. 3 (2023): 1089–1104, doi:10.1007/s10531-022-02540-4.
[15] M. Graziano Ceddia et al., “Governance, Agricultural Intensification, and Land Sparing in Tropical South America,” Proceedings of the National Academy of Sciences 111, no. 20 (2014):7242–7247, doi.org/10.1073/pnas.1317967111.
[16] Council of the European Union, “EU Deforestation Law: Council and Parliament Agree on Its Targeted Amendment,” December 3, 2024, consilium.europa.eu/en/press/press-releases/2024/12/03/eu-deforestation-law-council-and-parliament-agree-on-its-targeted-amendment/.
We hope you are as excited as we are about the release of 25, Issue 23. This issue of 25 is made possible with the contributions of specialty coffee businesses who support the activities of the Specialty Coffee Association through its underwriting and sponsorship programs. Learn more about our underwriters here.