Introduction

Picture your morning coffee. Before it reached your cup, those beans travelled through a complex global supply chain – one that's increasingly shaped by sustainability regulations. ISO 20400:2017 is the overarching standard providing guidance for sustainable procurement. But, translating it into practical actions is challenging for many organisations.

💡 What is Sustainable Procurement?

Sustainable Procurement = embedding environmental, social, and governance considerations into your business purchasing decisions – from the coffee beans you source to the packaging they ship in.

From the coffee plantations of Ethiopia to your local café, every stage of the journey now falls under specific regulatory requirements. These regulations create a comprehensive framework to ensure sustainability at each step: protecting forests where coffee grows, safeguarding worker conditions at processing facilities, verifying sustainable production methods, and ensuring transparent reporting of environmental impact.

This article is your regulatory cheatsheet. We'll guide you through the key regulations on sustainable procurement at each stage of the value chain:

1. Sourcing (EU Deforestation Regulation)
2. Supplier Management (Corporate Sustainability Due Diligence Directive)
3. Manufacturing (Ecodesign Regulation, Packaging & Packaging Waste Regulation, Anti-Greenwashing Rules)
4. Reporting (EU Taxonomy, CSRD)

Brace yourself, we are about to unpack a lot of acronyms.

1. Sustainable Sourcing

That coffee bean in your morning espresso began its journey in the Brazilian rainforest. The EU Deforestation Regulation ensures that this journey is deforestation-free. For coffee producers and other companies dealing with commodities like cocoa and palm oil, this means  robust traceability systems and  thorough due diligence.

The EU Deforestation Regulation (EUDR)

The EUDR, which came into force on 29 June 2023, represents the EU's most ambitious effort to combat global deforestation. Originally scheduled for December 2024, implementation has been pushed back to December 2025.

Who's Affected and When?

• Medium and Large Companies: Must comply by 30 December 2025
• Micro and Small Businesses: Have until 30 June 2026 to meet requirements

Beyond Coffee: The Scope of EUDR

The regulation extends well beyond your morning brew, covering commodities that significantly impact global forests:

• Coffee and cocoa
• Palm oil and soy
• Cattle and rubber
• Timber
• Derived products (think chocolate bars to wooden furniture)

In Practice

EUDRs creates a new standard for sustainable sourcing. Businesses must prove their products haven't contributed to deforestation or forest degradation after 31 December 2020. Here's what this means in practice:

1. Information Gathering: Build comprehensive product documentation
2. Risk Assessment: Evaluate each product's potential non-compliance
3. Risk Mitigation: Implement robust verification processes, from supplier audits to enhanced documentation

The Role of Certifications

While certifications alone don't guarantee EUDR compliance, organisations like the Rainforest Alliance and Forest Stewardship Council (FSC) offer valuable tools for meeting these requirements. For instance, the Rainforest Alliance's EUDR Deforestation Risk Assessment Tool combines forest data, public datasets, and proprietary tree cover mapping to support compliance efforts.

2. Supplier Management

You've stocked up on deforestation-free beans. That’s great - but the work doesn’t stop here. You also have to ensure fair labour practices at plantations, safe working conditions in the processing facilities, and high ethical standards across your entire global network of suppliers and partners. The Corporate Sustainability Due Diligence Directive (CSDDD) provides a comprehensive framework that's reshaping how organisations approach supply chain responsibility.

The Corporate Sustainability Due Diligence Directive (CSDDD)

The Corporate Sustainability Due Diligence Directive (CSDDD)(effective July 2024) is pushing companies to look beyond their immediate operations and consider their entire value chain's impact.

Who Needs to Comply?

The directive casts a wide net, capturing:

1. Large EU Companies: Those with 1,000+ employees and €450 million worldwide turnover
2. Large Non-EU Companies: Companies generating €450 million turnover within the EU

In Practice

Under CSDDD, companies must weave sustainability in their operations through:

1. Comprehensive Impact Assessment: Evaluating human rights and environmental impacts across operations
2. Climate Action Planning: Developing transition plans aligned with Paris Agreement goals
3. Value Chain Oversight: Extending responsibility to subsidiaries and business partners

The Human Side of Sustainability

Beyond CSDDD, a tapestry of national legislation ensures ethical labour practices across global supply chains:

• UK Modern Slavery Act 2015: Requires businesses with £36 million+ turnover to publish annual statements on trafficking prevention
• Australia's Modern Slavery Act 2018: Requires businesses to assess and address modern slavery risks in their operations and supply chains
• French Duty of Vigilance Law 2017: Mandates large French companies to identify and prevent adverse human rights and environmental impacts across their value chains
• Germany's Supply Chain Due Diligence Act: Focuses on environmental and human rights protection
• Dutch Child Labour Due Diligence Law: Specifically targets child labour prevention
• Norwegian Transparency Act: Emphasises supply chain transparency
• California Transparency in Supply Chains Act: Requires large retailers and manufacturers to disclose their efforts to eradicate slavery and human trafficking
• U.S. Uyghur Forced Labour Prevention Act: Prohibits imports of goods made with forced labour in the Xinjiang region

3. Manufacturing

As your freshly roasted beans hit branded packaging, a new set of regulations join the conversation.

The Ecodesign for Sustainable Products Regulation (ESPR)

The EU Ecodesign for Sustainable Products Regulation (ESPR)(effective July 18, 2024) is transforming how products are designed, packaged, and marketed. Soon, through Digital Product Passports (DPP), your coffee packaging will tell its full sustainability journey – from bean farming methods to recycling instructions.

Who’s Affected First?

The product groups affected by ESPR first are: Iron and steel, Aluminium, Textiles, Furniture, Tyres, Detergents, Paints, Lubricants, Chemicals, Energy related products, and Electronics.

What are the Ecodesign requirements of ESPR?

Product under ESPR must be:

1. Built for longevity and reuse
2. Energy efficient in production
3. Designed for easy maintenance
4. Waste-minimising
5. Low carbon footprint

In Practice

The regulation introduces three main measures:

1. Digital Product Passport: Enabling complete traceability (think: scanning your coffee package to see its entire journey)
2. Unsold Product Management: Reducing waste from unsold goods
3. Green Public Procurement: Setting sustainable standards for public sector purchasing

EU Packaging and Packaging Waste Regulation

The new Packaging and Packaging Waste Regulation (PPWR) (launching February 11, 2025) is changing how we package products.

Key objectives include:

• Making all EU packaging recyclable by 2030
• Boosting recycled plastic usage
• Reducing virgin material dependence
• Eliminating unnecessary single-use packaging
• Promoting reuse and refill systems

Protecting Consumers From the Risk of Greenwashing

While sustainable sourcing and packaging are crucial, ensuring honest communication about these efforts is equally important. As your coffee package proudly displays its sustainability credentials, new regulations are transforming how businesses communicate their environmental impact to protect consumers from misleading environmental claims.

New regulations - such as the EU Green Claims - ban:

• Unsubstantiated environmental claims
• Carbon neutrality claims based solely on offsetting
• Unauthorised sustainability labels

This means:

• No more vague "eco-friendly" claims without evidence
• Clear, verified sustainability certifications
• Transparent communication about environmental impact

4. Reporting

Transparency extends beyond your coffee's packaging claims – regulations now require businesses to tell the complete sustainability story of their products. From the carbon footprint of bean cultivation to the social impact at every processing stage, the EU Taxonomy and Corporate Sustainability Reporting Directive (CSRD) turn sustainability reporting from  voluntary exercise into comprehensive mandatory disclosure.

The EU Taxonomy

Introduced in July 2020 as part of the European Green Deal, the EU Taxonomy serves as a classification system that helps distinguish sustainable practices from superficial claims. Think of it as a standardised language for sustainability aiming to:

• Prevent greenwashing through standardised definitions
• Enable informed sustainable investment decisions
• Channel investments towards genuine sustainable initiatives
• Provide clear frameworks for sustainable procurement

The Corporate Sustainability Reporting Directive (CSRD)

The Corporate Sustainability Reporting Directive (CSRD),(effective since January 2023) requires businesses to reveal the full environmental and social impact of their operations.

For example, coffee brands’ disclosure under CSRD could cover:

• Water usage in bean processing
• Carbon emissions from transportation
• Working conditions across the supply chain
• Environmental impact of packaging choices
• Social initiatives in farming communities

In Practice

1. Comprehensive Disclosures: Detailed reporting across environmental, social, and governance metrics
2. Double Materiality: Assessing both how sustainability issues affect the business and how the business affects sustainability
3. Value Chain Transparency: Documenting impacts from farm to final product

For more details about the CSRD, listen to our podcast here.

And that's it - from sourcing to reporting. We've unpacked enough acronyms to make your head spin, but hopefully, you understand the regulations affecting your morning coffee a bit better. We trust you've made a fresh cup or two to get you through the regulatory deep dive.