Operationalising the EU Deforestation Regulation: Intermediary Networks and Smallholder Inclusion in the Ugandan Coffee Sector

The EU Regulation on Deforestation-Free Products (EUDR) aims to curb global deforestation by restricting the placing and trading on the EU market of commodities linked to deforestation, forest degradation, and illegal land use. Although the regulation formally targets operators and traders within the EU, its due diligence requirements generate substantial extraterritorial effects as compliance obligations are transmitted upstream along global supply chains. This raises pressing questions of distributive justice, particularly regarding the ability of smallholder producers in producer countries to comply with new requirements and remain integrated in global value chains. This paper examines how abstract EUDR requirements are operationalised in practice through intermediary involvement in the Ugandan coffee sector, a context characterised by smallholder-dominated production and high vulnerability to exclusion. Drawing on political network theory and the Regulator–Intermediary–Target framework, the study conceptualises regulatory intermediaries as relationally embedded actors that translate, enact, and co-produce EUDR practices through concrete programmes, platforms, and infrastructures. These intermediaries include government agencies, business associations, NGOs, donor organisations, certification bodies, and geospatial and traceability technology providers. Methodologically, the study applies a mixed-method, descriptive Social Network Analysis combining face-to-face network surveys with semi-structured interviews. It maps the network of intermediary actors involved in EUDR operationalisation in Uganda, their collaborative ties, and flows of information, technical expertise, and financial resources. The analysis assesses how intermediary activities and infrastructures enable or constrain smallholder participation in deforestation-free coffee value chains, highlighting both inclusionary mechanisms and emerging risks of exclusion. (Submission to panel 6: The Politics of Environmental Networks)