Dubai – Ali Azakary | Qahwa World
On May 4, the European Commission published its “simplification” package for the Deforestation Regulation. Some saw it as genuine relief. Others called it cosmetic.
Qahwa World continues its interview series with industry experts. After Dr. Steffen Schwarz from Germany and Kim Thompson from Dubai, our third guest is Burke Campbell.
Burke is a Canadian of Cree-Métis heritage who left the Alberta oil sands to work in coffee farms in Honduras. His journey connects resource extraction, economic sovereignty, and sustainable development. From his personal awakening to the parallel between Indigenous communities in Canada and coffee farmers in Honduras, through his pioneering work connecting Yemen’s ancient coffee heritage to modern markets, Burke’s story is one of resilience, vision, and an uncompromising pursuit of justice.
Here is what he said.
- What is your overall take on the EU simplification decision? Does it truly reduce the burden, or is it mostly cosmetic?
Burke Campbell: Cosmetic. The real problem is who pays the documentation tax, and the May package left that architecture in place.
The Commission missed its own statutory April 30 deadline by four days, then released four instruments on May 4. They did not reopen the regulation. They cleaned up the paperwork around it.
The 75 percent compliance cost reduction announced by Commissioner Roswall was largely legislated on December 18, 2025, when the Council and Parliament shifted the due diligence filing burden away from EU traders and onto whoever first places the product on the market. The May package recycles that and adds a few line items. Soluble coffee in. Leather out.
Read the line the Commission used about its own simplified regime. The Commission itself admits that the SME and primary operator route covers close to one hundred percent of farmers and foresters in the EU. Brussels has functionally exempted itself from a regulation it is still asking a Honduran cooperative, an Ethiopian farmer, and a Ugandan smallholder to comply with. They simplified the part of the regulation that touched them. The rest stands.
I write this from Copán Ruinas, Honduras. An Alliance Bioversity and CIAT estimate places around 85 percent of producers in this country in the at-risk category for EU market exclusion, and more than half of our coffee leaves through European ports. The May package did nothing for them. Brussels reduced the burden it was carrying. The burden Brussels exported is unchanged.
- Who benefits the most from this simplification?
Burke Campbell: Big companies. Not small producers, and not low-risk exporting countries.
Small producers do not benefit. Outside the EU they do not get the simplified declaration relief that European primary operators receive. They build the polygons themselves and pay every line of the cost.
Low-risk exporting countries get a label, not relief. A Vietnamese exporter still owes geolocation. A Colombian cooperative still owes geolocation. The “low-risk” classification means simplified due diligence. You skip the formal risk assessment step. The polygon is still required. The compliance vendor still gets paid. The country gets a sticker on the file.
Look at where the money actually lands. All of it north.
The compliance technology sector. The Mannheim platform that Goldman Sachs bought into for 120 million dollars in 2024 runs the books for more than 1,300 customers. The two billion euros in residual annual compliance cost the Commission says is left in the system after simplification is structurally allocated to this sector. Goldman bought in early so it could collect.
The big trader-roasters. They have already absorbed the cost. The downstream operator architecture means smaller importers behind them just collect reference numbers, not run their own due diligence. The supply chain runs through the platforms the big traders own. The moat is real.
The European farmer and forester. Through the small and micro primary operator route they receive a one-time simplified declaration, a postal address instead of a polygon, and in many cases a national database the member state authority will pre-fill for them.
Who pays. Smallholder cooperatives in Honduras, Ethiopia, Uganda, Colombia, Indonesia, Peru. Mid-size specialty importers in Europe without proprietary platforms. The two billion does not stay in the countries that grew the coffee. It moves north.
- Soluble coffee is now fully covered, after being excluded before. How do you see this affecting coffee traders and roasters worldwide?
Burke Campbell: The loophole was real. If you processed non-compliant green coffee outside the EU and brought the finished instant in as an extract, you had not technically placed deforestation-linked coffee on the market. Closing it on the law’s own terms was correct.
For green coffee traders the change is administrative. The major traders already polygon-trace the green beans they handle. They add a line to their books for soluble extracts and concentrates. The systems exist. The marginal cost is low. They will absorb it.
For roasters the picture splits. A specialty roaster importing green coffee and roasting it in Hamburg or Milan was never in the soluble category. Their position is unchanged. The companies whose position changes are the integrated roaster-processors. Their soluble lines now sit inside the same chain of custody architecture as their green portfolio. Mass balance accounting gets harder under EUDR rules. Each component has to be deforestation-free and individually polygon-mapped. You cannot blend a non-compliant lot into a compliant one and call the result compliant. The whole batch has to be clean.
For origin processors the change is structural. Vietnam exports about 3.3 million bags of soluble and roasted in green bean equivalent, with 60 percent bound for Europe. Nestlé is putting another 75 million dollars into its Dong Nai plant. Trung Nguyen 75 million into Đắk Lắk. Highlands Coffee 20 million into Bà Rịa-Vũng Tàu. Food Empire 80 million into a freeze-dry facility in Bình Định. Those facilities will absorb plot-level traceability cost on top of green bean traceability cost. The shipper exporting unprocessed green to Hamburg now carries a lighter compliance load than the country that processes its own beans before they leave.
That is the deeper point. The regulation now taxes origin processing. Vertical integration. Value retained in producing countries. The pathway out of green bean dependence is processing at origin. The Commission has just made that pathway more expensive than green bean export.
- Is the global coffee supply chain truly ready for the December 30, 2026 deadline? If not, which part of the industry will take the biggest hit?
Burke Campbell: No.
One thing first about the premise. The “except small producers” exemption you mentioned is an EU internal rule. A primary operator inside an EU member state, classified small or micro, can submit a one-time declaration through a cooperative, use a postal address instead of a polygon, and in many cases have the member state authority pre-fill the document from a national database that already exists. None of this is on offer to a small producer in Vietnam, India, Colombia, Honduras, Ethiopia, or anywhere else outside the Union. The exemption is for European small producers. Foreign smallholders in low-risk countries still build the polygons themselves and pay every line of the cost.
That single clause is the asymmetry.
The deadline is locked. December 30, 2026 for large and medium operators. June 30, 2027 for most micro and small operators outside timber. The Commission’s own information system was on limited operability from February 16 until mid-April because it could not handle the submissions it was designed to receive. It reopens in stages from June. Six months of integration time for several hundred thousand operators globally.
The polygon is the regulation’s central instrument. Once you have drawn it, your land is recorded in the EU’s traceability system, attached to every shipment that originates there.
Biggest hits, in order. African and Central American smallholder cooperatives without national traceability infrastructure. Ethiopia has approximately four million smallholders, mostly half-hectare plots, mostly shade grown, mostly unmapped. Honduras has, by Alliance Bioversity and CIAT’s estimate, around 85 percent of producers in the at-risk category, and more than half of its coffee export revenue going to Europe. Uganda has spent $9.15 million on its national register and will probably make the deadline. Then mid-size European specialty importers without proprietary platforms. Then Vietnamese and Indian instant processors, newly in scope after the soluble inclusion.
Effectively immune. The major traders with proprietary infrastructure. Nestlé, JDE Peet’s, NKG, Volcafe, Sucafina, ECOM, Olam, Louis Dreyfus, Touton, Lavazza, illycaffè. The Italian leather lobby that got leather pulled from the list. The carve-outs go to lobbies that can write back. The architecture stays where there is no lobby on the other side.
The supply chain is not ready. The architecture decides who gets to be ready.
They built a green wall. The farmers it claims to protect have been on the other side of green walls for 400 years. The trick is not to climb over. The trick is to stop accepting that the wall is the only door.
Qahwa World – Episode Four tomorrow with John Seroney from Kenya.
Read the related stories:
Kim Thompson: Sustainability Rules Must Not Punish the Producers Who Need Market Access Most
Dr. Steffen Schwarz: EUDR Simplification Remains an Administrative Monster
EUDR Simplification: Six Voices from the Coffee Industry Speak
European Commission Simplifies Deforestation Regulation.. What’s New?

