How ItalCaffè built a scalable EUDR compliance workflow

About ItalCaffè

ItalCaffè is a coffee wholesaler, based in Trieste, Italy, that specialises in the trade and distribution of coffee and coffee-related products. Founded in 2012, the company employs 260 staff and has an annual turnover of €101 million, classifying it as a non-SME under EUDR. ItalCaffè sources a wide variety of coffee beans and derived coffee products - including roasted beans, ground coffee, and ready-to-serve capsules - from certified suppliers based in the European Union.

The company does not import directly from producing countries such as Brazil, Ethiopia, or Vietnam. Instead, it purchases from established EU-based importers and roasters, then repackages or relabels the goods for resale within Europe and for export to select non-EU markets. Because it does not place any EUDR-regulated commodities on the EU market for the first time, ItalCaffè is considered a trader, not an operator.

Initial challenges

When assessing its EUDR obligations, ItalCaffè faced several specific questions:

• Understanding the responsibilities of a non-SME trader under EUDR: Unlike SME traders, non-SME traders are treated as operators for due diligence purposes and must comply with the full due diligence obligations of EUDR.
  
  
• Determining which products are in scope under EUDR: ItalCaffè trades in coffee beans, among other items. Derived items such as coffee pods, flavored syrups, and coffee-based snacks must be cross-checked against the CN codes listed in Annex I.

• Addressing concerns about mixing: one of ItalCaffè’s core services is purchasing bulk roasted beans and packaging them into smaller consumer-friendly quantities. They are uncertain whether this is allowed under EUDR.

• Managing suppliers with uncertain reliability: As a non-SME trader, ItalCaffè is obligated to submit its own DDS unless it can confirm that the upstream DDS meets all EUDR requirements. This means they must evaluate supplier maturity before referencing prior DDS.

• Handling a substantiated concern: ItalCaffè was reported* to the authorities with a substantiated concern regarding one of the plots where the coffee they trade is produced on. They were initially unsure on the required process for responding to a substantiated concern.

*Hypothetical - substantiated concerns cannot be submitted until after the implementation date of EUDR (31 December 2025)

Key EUDR challenges and how ItalCaffè addressed them‍

1. Understanding non-SME trader’s responsibilities under EUDR

Unlike SME traders, who benefit from reduced responsibilities under EUDR, non-SME traders like ItalCaffè must meet the same core obligations as operators. This includes conducting due diligence, retaining documentation, and actively assessing risk across their supply chain. When the regulation came into effect, ItalCaffè needed to understand how these expanded requirements applied to their role as a trader of in-scope commodities.

How they solved it:
ItalCaffè implemented Coolset’s EUDR platform, which dynamically adapts workflows based on the company’s role (operator or trader) and size (SME or non-SME). As a non-SME trader, the platform triggered a full due diligence workflow, requiring ItalCaffè to complete a comprehensive risk assessment for every coffee product sourced from both standard and high-risk countries.

The platform ensured ItalCaffè couldn’t proceed without submitting mandatory due diligence statements (DDS), uploading risk mitigation documentation, and maintaining auditable records for each batch. Using Coolset’s automated risk flagging and compliance prompts, ItalCaffè structured its entire EUDR process in line with the regulation - not just at onboarding, but on an ongoing basis for every relevant import.

2. Determine which products are in-scope under EUDR

When the EUDR obligations first became clear, ItalCaffè needed to determine exactly which of its product lines were subject to the regulation. Whole beans, ground coffee, and capsules were all under review.

How they solved it:
ItalCaffè reviewed Annex I of Regulation (EU) 2023/1115 and confirmed that all products under CN code 0901 (coffee, whether roasted or unroasted, and coffee husks and substitutes) are in scope. Even though they do not process raw materials or change HS codes, the company ensures that all coffee-based products fall under proper due diligence documentation.

Coolset’s product scanner module helped ItalCaffè upload its full inventory and automatically identify which SKUs matched regulated HS codes. This saved days of manual review and confirmed that 80% of ItalCaffè's current stock requires DDS.

3. Addressing concerns about mixing and mass balance

One of ItalCaffè’s core services is purchasing bulk roasted beans and packaging them into smaller consumer-friendly quantities. The company initially assumed this might change their regulatory status.

How they solved it:

ItalCaffè confirmed - via EUDR FAQs and the official regulation - that repackaging without altering the HS code does not change the trader status, provided the product has already been placed on the EU market by an operator. Therefore, they remain a trader, not an operator.

However, the regulation forbids mixing compliant and unknown origin / non-compliant goods. Using Coolset’s batch tracking system, ItalCaffè implemented an internal segregation rule: only products with a verified DDS from upstream operators were eligible for packaging, and mixed-origin beans could only be combined if all sources were known, documented and compliant.

They used Coolset’s supplier maturity assessment, to understand whether they could trust the due diligence performed by upstream suppliers. If they couldn’t, they used the Coolset platform to perform due diligence. Finally, when repackaging products they declared a new DDS, including upstream DDS where applicable. 

4. Managing suppliers with uncertain reliability

As a trader, ItalCaffè may refer to due diligence statements (DDS) that have already been submitted, in their own DDS – but only if they confirm the upstream DDS meets the full requirements under EUDR. 

How they solved it:

ItalCaffè used the ‘Supplier maturity assessment’ available in Coolset’s EUDR platform, to determine whether their suppliers had completed due diligence in accordance with EUDR’s requirements. The maturity assessment is a one-time survey sent directly to suppliers through the platform, and requests information on: past misconduct, verification processes, and steps taken to comply with EUDR. 

The platform’s risk-tiering logic helped the ItalCaffè team understand exactly which suppliers may be failing to perform the necessary due diligence requirements, and thus where they should investigate further. Most suppliers scored low-risk on the assessment, and thus ItalCaffè was exempted from replicating due diligence and could pass on existing DDS numbers in their DDS. 

However, in the case of two suppliers, Coolset flagged a risk of EUDR non-compliance. One supplier didn’t have any documented processes for EUDR, and the other had many law violations in the past.

ItalCaffè conducted further investigations, communicating with the suppliers to gain a better understanding of the situations. After in-depth discussions, and evidence that supplier 1 was compliant with EUDR, ItalCaffè decided it could trust the supplier and their DDS.

For supplier 2, inspection into the prior law violations suggested it was not a responsible supplier, and ItalCaffè chose to undertake their own due diligence to be confident in their EUDR compliance. After a few months, if no issues arise they ItalCaffè will revert back to referencing its suppliers DDS.  

5. Handling a substantiated concern

In early 2025, a civil society organization submitted a “substantiated concern” to the Italian competent authority, alleging that one of ItalCaffè’s capsule lines was derived from deforestation-linked beans.

How they solved it:

Under Article 31 of the regulation, substantiated concerns must be investigated. ItalCaffè had previously relied on upstream DDS for this product line. After receiving the concern, they requested plot data, and employed Coolset’s satellite monitoring tool to review the deforestation risk. The deforestation check showed that part of the plot had been cleared after the EUDR implementation deadline, and thus was not ‘deforestation free’. 

ItalCaffè immediately notified their supplier of this concern, and the affected batch was isolated and not placed on the EU market. As they had conducted a supplier risk assessment, and were able to prove this to authorities, ItalCaffè were not fined, and the competent authorities moved on to investigate the supplier. ItalCaffè updated its risk matrix to downgrade the supplier’s trust level, and audited other shipments to ensure no further contamination of the supply chain.

Conclusion

Through early action and platform support, ItalCaffè turned potential EUDR compliance risk into a structured plan. By identifying in-scope products, segmenting traceability workflows, and responding decisively to substantiated concerns, the company now has a robust compliance strategy.

Coolset’s tools helped ItalCaffè navigate ambiguous cases, structure supplier evaluations, and respond swiftly to regulatory checks - without exceeding its legal obligations. The result is a scalable, low-friction compliance workflow built on transparency, accountability, and future-proofing.

ItalCaffè SRL is now positioned to maintain access to the EU market, build supplier trust, and demonstrate leadership in sustainable commodity trading.

ItalCaffè SRL is a hypothetical case study. Learn more about EUDR-ready tools for non-SME traders at Coolset.com/eudr