In February, I met Elisa, a single mother raising a teenager while growing coffee alongside avocado and macadamia in Kenya. She is among the relatively few women parcel owners who converted inherited land into a formal title deed. I remain deeply skeptical of one assumption underlying EUDR: that a smallholder growing coffee or cacao on less than an acre, and intercropping out of necessity with macadamia, avocado, and household food crops, should somehow be treated as a meaningful driver of the deforestation problem the Regulation seeks to address. That skepticism has only deepened as I spend more time with the realities of rural production, and it is not a concern lost on smallholders themselves. Elisa was part of a cohort of 137 producers, mostly women, whom I interviewed to examine the exclusionary risks of emerging Regulation, primarily EUDR, through smallholder and gender perspectives.

I previously shared some of the farmers’ apprehensions in a Medium post—an article that generated unexpected in-person conversations and direct messages and ultimately helped prompt this newsletter. Among the concerns raised was the possibility that newly collected farm data could eventually be used for taxation, alongside broader questions about the socioeconomic implications of compliance. I also discussed constraints common in smallholder rural realities, including digital illiteracy and limited access. Yet some of these assumptions can be overstated. Nearly two-thirds of the farmers I interviewed owned smartphones, regularly purchased mobile data, and frequently used mobile-money applications.

What stood out instead was data-collection fatigue. Each Regulation, certification scheme, and buyer demanded more information, while little of lasting value remained with either the farmer or the cooperative. Elisa’s farm had already been mapped by government agencies and by a European coffee buyer. Yet, the latter dataset remained inaccessible to the cooperative, leaving it with little to show a future buyer. Data fatigue predates EUDR, but the Regulation is intensifying it. My concern is that rising compliance costs could further decouple smallholder producer groups from SME importers and roasters that maintain sourcing relationships with them.

Meanwhile, coffee, like other EUDR-covered commodities, has been flooded by one mobile application after another, including sophisticated systems that still run into data breakdowns. Much of the burden falls back upstream into Excel sheets, with fragmented information assembled later from Frankfurt, Amsterdam, or Brussels. Other tools collect data effectively but offer little utility to either the farmer or the cooperative, much like Elisa’s data now sits with a European buyer rather than remaining useful at origin.

The irony is that the frustration is increasingly shared. The same downstream actors that once benefited from keeping data inside closed systems now face the consequences: one cooperative I came across was effectively the custodian of 17 Excel sheets, many outdated, duplicated, or difficult to reconcile. Some had followed the apparent simplicity of single-point geolocation, which, as I explain below, can be poorly suited to smallholder land-use realities. The result is endless upstream updating, often with little incentive for farmers already experiencing the kind of data fatigue Elisa described.

What follows are a few lessons I have drawn from these conversations and from building around them. Some speak directly to EUDR and data sovereignty; others concern the wider opportunity for digital transformation at origin. They are not the only model, but they shaped the system we are building and helped us avoid several of the problems described above.

EUDR Has an Incentive Problem at Origin

To make compliance sustainable, we must address a structural misalignment: EUDR’s strongest regulatory incentive sits downstream, while the evidence it requires must originate upstream. The obligation falls primarily on actors placing products on the EU market, yet smallholders and many producer organizations do not necessarily share the same incentive to maintain EUDR-specific systems. This is particularly true where cooperatives can sell into non-EU markets, including China, or through auction systems without carrying the same compliance burden. Cooperatives with established relationships with European roasters face greater pressure, but the incentive problem remains.

This incentive misalignment creates a catch-22. Smallholders account for roughly 80 percent of global coffee production, so European buyers cannot bypass origin actors. EUDR cannot be satisfied from an office in Brussels, Paris, or Frankfurt: geolocation begins at the farm gate, and traceability depends on records maintained there. To keep those records accurate over time, the infrastructure must also create practical value for the farmers and cooperatives generating them. At Terraxis, as we developed our software Plotra, we recognized this incentive problem first, and everything flowed from there.

Context-Aware Systems Are Not Optional at Origin

Digital systems often assume neat, discrete parcel boundaries and rely heavily on satellite interpretation. But smallholder land use rarely fits that model. A single farm may include several parcels used by multigenerational family members, with boundaries that zigzag alongside neighboring plots while all production ultimately moves to the same mill.

We therefore moved beyond the apparent simplicity of a single GPS point and opted for boundary polygons. In these settings, a point may satisfy a minimum geolocation requirement while still doing little to distinguish adjacent parcels or prevent overlapping records. Mapping the boundary gives the cooperative a clearer representation of the actual production area and reduces that risk.

The same contextual approach matters when interpreting land-use change. EUDR is not about every tree cut, branch pruned, or temporary reduction in vegetation. The central question is whether forest was converted to agricultural use after the 2020 cut-off, not whether normal farm management altered canopy density. This let us avoid prohibitive satellite costs and build much higher confidence in a parcel’s size and land use—without policing routine farm management, such as pruning or removing trees affected by Coffee Berry Disease (CBD).

Leverage EUDR to Create Operational Infrastructure at Origin

Mapping a parcel is useful, but it means little if that record isn’t connected to the cherries delivered from the farm to the wet mill. That connection is where EUDR can become more than a compliance exercise.

For the cooperative, digitizing the existing workflow links producer records, deliveries, mill intake, batch formation, and inventory into one operational record. Bush counts, seedlings awaiting planting, certification membership, and other farm-level information can sit within the same system, replacing paper-heavy records with structured, usable data. A farmer’s delivery then becomes both a transaction confirmation and the first commercial event in the chain of custody. The same record can later serve another buyer without forcing farmers through another cycle of mapping and data collection.

For the farmer, a verified digital delivery history can turn data into an economic asset. It provides structured evidence of expected agricultural income that may support applications for crop financing through local SACCOs, creating more lasting value than a one-off payment for participating in a survey or mapping exercise.

This is not about turning compliance into charity. It is about avoiding the familiar cycle of fragmented spreadsheets and repeated data collection. If a cooperative can maintain a structured record and legitimately reuse it with future buyers, that is a feature, not a flaw. This aligns with the principle we support: useful, portable digital infrastructure rather than another closed compliance database. Data utility is a far stronger incentive for cooperatives and producer groups—it forces us to practice what we preach when building digital public goods.

Let the System Work With the Cooperative Workflow

Any system deployed at origin needs enough flexibility to reflect how the cooperative already works, rather than forcing it to reorganize around the software. Once the cooperative has meaningful ownership of the system, implementation becomes far easier. In our case, cooperatives began assigning their own officers to support farm mapping, reducing costs and reliance on external data-collection teams.

We also built role-based interfaces around existing responsibilities:

Agronomists have the broadest role because they maintain regular contact with farmers. They can update production information, record regenerative-agriculture support, reflect newly planted seedlings in bush counts, and serve as an entry point for human-rights screening, including child labor and casual labor minimum-wage commitments.

Collection center and wet mill staff focus on recording and authenticating deliveries before coffee moves into processing.

Leadership and Admin staff can build export consignments in the system—bundling the Due Diligence Statement (DDS), human rights due diligence, and required export documents into one shareable resource for exporters or roasters, replacing 17 separate emails and WhatsApp PDFs.

Takeaway

EUDR has inadvertently triggered one of the largest waves of agricultural digitization in modern history. The question is what remains after the initial compliance push subsides: stick to the legacy of fragmentation, or convert it into long-term value. We chose the latter.

The bet is that EUDR can become one output of a broader digital transformation rather than the sole reason for building the system. That will not resonate with everyone, and it differs from traditional compliance-as-a-service models. But it follows directly from what we heard at origin. If farmers and cooperatives are expected to generate and maintain the evidence downstream compliance depends on, the infrastructure must work for them, too.

This works because we operate in specialty coffee and cacao sourcing, strengthen the chain of custody through relationships built on shared infrastructure, and pass this model directly to our roaster and confectionery clients. We see no conflict between upholding the principles of digital public goods, data sovereignty, and farmer data utility and delivering compliant, commercially sound practices that withstand regulatory scrutiny. The objective is not simply to capture more data, but to make the system genuinely useful to the cooperative staff already doing the underlying work.