The Construction of Compliance with the European Union Deforestation Regulation in Global Coffee Value Chains

ABSTRACT The European Union's Deforestation Regulation (EUDR) obliges the importers and users of seven agricultural commodities to achieve supply chain traceability and prevent deforestation‐linked products from entering the EU market. This paper investigates how companies and producing countries in the coffee sector prepared for EUDR compliance by analyzing 61 semi‐structured expert interviews and 25 sectoral meetings. It draws on socio‐legal theorization on compliance construction and Global Value Chain scholarship to show that under regulatory uncertainty, compliance preparations are shaped significantly by pre‐existing value chain characteristics and power relations. Upstream, midstream, and downstream actors pursued different compliance approaches to reduce costs and improve their competitive position. While producing countries aimed to establish country‐level producer databases for EUDR compliance, trading companies drew on existing capacities to build out their traceable, sustainable coffee offers. Downstream coffee sector actors, in turn, constructed a “territorial” approach to EUDR compliance that eschewed strict traceability, but were ultimately unsuccessful in lobbying for its acceptance by EU authorities. The results highlight the importance of considering value chain dynamics when designing and implementing public policy, and paying greater analytical attention to the phase of compliance preparation within the policy cycle.