What requirements must coffee comply with to be allowed on the European market?

To enter the European coffee market, there are both legal and non-legal requirements you must meet as an exporter. These mainly relate to food safety. Furthermore, European coffee buyers increasingly have additional requirements that you need to comply with to target specific segments or to keep up with European market developments. These are especially common when it comes to basic or extra food safety certification and sustainability standards. Lastly, complying with specific niche requirements related to higher sustainability and/or quality standards may increase your chances on markets that command higher values and lower volumes, if your product is suitable for them.

1. What are mandatory requirements?

In this document you can find the most important legal and non-legal requirements you must meet when you want to market coffee in Europe. These include general requirements for food products, especially on food safety, as well as specific legislation for coffee. The Access2Markets webpage of the European Commission gives a complete overview of legal and other requirements on the European coffee market. The Product Code for coffee (green and roasted, including decaffeinated) is 0901. Make sure to use this code when looking up coffee-specific requirements on the Access2Markets webpage.

Food safety

When it comes to food products such as coffee, the main focus of European Union’s legislation is food safety and food hygiene. The General Food Law is the legislative framework for this subject. This law ensures the quality of food products throughout the whole supply chain. Products that are not considered safe will be denied access to the European Union.

In the event of repeated non-compliance of specific products originating from particular countries, such as a health certificate or analytical test report, stricter conditions are required for import. Products from countries that have shown repeated non-compliance are put on a list included in the Annex of European Commission Implementing Regulation (EU) 2019/1793. The list of products and countries subjected is updated regularly. It is important to keep up-to-date on developments despite the limited nature of the increased checks for coffee.

Food contaminants

Food contamination can occur at different stages of the production process due to environmental elements, cultivation practices, processing methods or transportation. Since many contaminants are naturally occurring, it would be impossible to impose a total ban on them. European Union legislation ensures that contaminants are kept at levels that are as low as possible so that they do not threaten human health or negatively impact the quality of food. The levels are set based on scientific advice provided by the European Food Safety Authority (EFSA).

The main contaminants likely to be found in coffee products are:

1. Pesticides
2. Mycotoxins / mould
3. Pathogens
4. Extraction solvents
5. Hydrocarbons
6. Other: Acrylamide

A) Pesticides

The presence of pesticides is one of the most common reasons for border authorities to reject coffee coming from producing countries. The European Union has set maximum residue levels (MRLs) on the amount of pesticides allowed in food products, including coffee. The use of pesticides is permitted but should be strictly controlled to remain within the allowed limits. This is especially relevant for coffee farmers using pesticides to fight insect infestation such as the coffee berry borer. Be aware that products containing more pesticides than allowed by European regulations will be withdrawn from the European Union’s market.

For organic coffee, MRLs of pesticides must be zero. Buyers will randomly select batches of organic green coffee, which they might send to accredited third-party laboratories to check for residues.

Recently, the use of glyphosate is placed under particular scrutiny. For decades, this was the most frequently used herbicide in the world. The current approval for the use of glyphosate in the European Union expires on 15 December 2022. Currently, a group of four countries (France, Hungary, the Netherlands and Sweden) is in the process of applying for the renewal of approval of glyphosate after 2022. Glyphosate is a controversial chemical substance used in numerous herbicides and has been under attack from politicians and environmentalists alike. The working group’s risk assessment on glyphosate is expected to come in mid-2023.

In addition, the Farm to Fork strategy (part of the European Green Deal) aims to make food systems fair, healthy and environmentally friendly. Among the most notable targets set by this EU strategy is a 50% reduction in the use of pesticides by 2030. As part of this measure, the EU has proposed legally-binding targets for maximum residue levels and set strict new rules to enforce environmentally-friendly pest control.

B) Mycotoxins / mould

Mould is another important reason for coffee border rejections. Ochratoxin A (OTA) levels, which are found on green coffee beans, are a specific point of attention. OTA contamination can be caused during production (picking of overripe cherries), post-harvest practices (bad fermentation) and during transportation in humid / leaky containers or storage in badly ventilated warehouses.

In 2022, the European Union set new limits for Ochratoxin A (Regulation (EU) 2022/1370). Although there is no specific limit for green coffee beans, the maximum OTA level for roasted and ground coffee has been lowered to 3 μg/kg, and for instant coffee it is 5 μg/kg. In general, OTA levels drop during the roasting process, partly because different batches of green coffee are blended (each batch will contain different levels of OTA). Note that dark roasting may lower the level of OTA but that OTA is not completely eliminated during the roasting process, so it is important to check the levels in green coffee.

C) Pathogens: salmonella

Salmonella is a form of microbiological contamination. It occurs occasionally as a result of incorrect harvesting and drying techniques. Coffee beans are considered low-risk commodities regarding salmonella contamination, since its eventual roasting is a “kill step” for any microorganisms present in the product. As such, no microbiological criteria for coffee have been set in the current European legislation. However, food safety authorities can withdraw imported food products from the market or prevent them from entering the European Union when microorganisms are found during controls.

D) Extraction solvents

Solvents can be used for decaffeination of coffee. There are maximum residue limits restrictions for the extraction solvents such as methyl acetate (20 mg/kg in the coffee), dichloromethane (2 mg/kg in the roasted coffee) and ethylmethylketone (20 mg/kg in the coffee).

E) Hydrocarbons: Polycyclic Aromatic Hydrocarbons (PAHs) and Mineral Oil Aromatic Hydrocarbons (MOAHs)

There is increasing concern in the European Union regarding other forms of contamination in coffee. Several of them are grouped as what are known as Polycyclic Aromatic Hydrocarbons (PAHs), which may result from drying (of green coffee) and roasting processes. Examples are Benzo(a)pyrene and Anthracene.

In the drying process specifically, contamination is commonly caused by the smoke emitted from the fuel in artificial driers. However, it might also be related to air pollution, for instance when drying at the roadside. Commission Regulation (EU) No 835/2011 defines specific PAH limits for specific foodstuffs; they do not yet include coffee beans, but observance and prevention of contamination is advised (see Recommendations).

Mineral Oil Aromatic Hydrocarbons (MOAHs) are mineral oils that might be carcinogenic. Officially there are no maximum levels established in Europe. Still, some countries have set guidelines, like Germany. Green coffee can get contaminated with MOAHs during all stages of the supply chain; during the production and drying of green coffee next to busy roads, during processing due to the overuse of grease in machinery, as well as during packaging, storage, and transport.

F) Other: Acrylamide

Recently, there has been a discussion in the European Union regarding the levels of acrylamide in roasted coffee. Acrylamide is a carcinogenic substance that forms naturally when coffee is roasted at temperatures above 120°C. Commission Regulation (EU) 2017/2158 establishes that the benchmark level for roasted coffee is 400 μg/kg. As an exporter of green coffee beans, you will not be directly affected by this legislative development, but it is important to note the increasing food safety controls for coffee in Europe.

General requirements on packaging and labelling

There are specific industry practices for coffee labelling to ensure product identification and traceability. Labels of green coffee should be written in English and should include the following information:

• Product name
• International Coffee Organization (ICO) identification code
• Country of origin
• Grade
• Net weight in kilograms
• Supplier’s name
• For certified coffee: name/code of the inspection body and certification number

Figure 1: Example of green coffee labelling

Source: Escoffee

Green coffee is traditionally shipped in woven bags made from natural fibres, such as jute or burlap. These bags typically hold 60 kilograms of green coffee. Although the 60 kg bag is the most common, some countries use bags holding 46 kg, 50 kg, 69 kg or 70 kg. However, jute and burlap bags do not protect against moisture. As such, plastic big bags and plastic container liners are increasingly used to lower this risk. These plastic bags range in size from 60 kilogrammes to full container-sized bags of 20 tonnes.

You also have high-barrier packaging (in all sizes, including container-size). This type of material keeps out both oxygen and moisture. Materials such as Grainpro or Videplast liners are often used to pack specialty coffees inside jute bags. The most exclusive specialty coffees are often vacuum-packed to preserve the green coffee quality.

Other packaging used to transport coffee includes polypropylene super sacks for 1 tonne of coffee, polyethylene liners for 21.6 tonnes and vacuum-packing. These techniques provide two advantages in the coffee trade, namely increased efficiency and preservation of quality.

Figure 2: Examples of coffee packing: jute bag, container-sized flexi bag, GrainPro and Videplast liner

Sources: raadtradingco.com, bls-bulk.com and GrainPro

2. What additional requirements do buyers often have?

Some buyers have requirements that go beyond existing legislation, in particular regarding food safety, quality, and environmental impact and social responsibility.

Additional food safety requirements

Note that, as the bulk of green coffee beans sourced in producing countries will still be roasted in the export destination, food safety management systems related to processing are not always required. However, some coffee buyers might require exporters to comply with a food safety management system, for example ISO 9001 or ISO 22000 or hazard analysis and critical control points (HACCP) principles. HACCP is often a first step towards more rigorous food safety schemes, such as FSSC22000 or BRCGS. HACCP schemes can be developed with the aid of consultants specialised in implementing food management principles.

Another strategy to ensure food safety as a producer is to follow good agricultural practices. Buyers may require producers to meet the main standards of GLOBALG.A.P. They are standards for the certification of agricultural production processes that provide safe and traceable products. GLOBALG.A.P. has a special Green Coffee standard, which covers production from pre-harvest activities such as soil management and plant protection product application to post-harvest handling and waste management.

In addition, exporters and producers may want to think about implementing good manufacturing practices (GMP). These general principles provide guidance on post-harvest processes such as washed or natural processing, manufacturing, testing and quality assurance to ensure that the product is safe for human consumption. At the least, your GMP plan should include guidelines for your processing facility and equipment as well as your warehouse and transportation.

Quality criteria

If you want to access the European coffee market, you will have to meet your buyer’s quality standards – which are particularly high within the specialty segment. In general, coffee quality is judged based on both a physical evaluation of green and roasted coffee and a sensory evaluation of the roasted coffee.

Green coffee assessment

First, the quality of green coffee is graded and classified before export. There is no universal grading and classification system for coffee, but the Specialty Coffee Association’s standards for green coffee grading are often used as a reference. However, most producing countries have and use their own grading systems. The Organisation for Standardisation (ISO) also provides specific standards on coffee quality, such as ISO 10470 (Green coffee - Defect reference chart).

Grading and classification is usually based on the following criteria:

• Altitude and region
• Botanical variety
• Processing method: wet/washed, dry/natural, honey, pulped naturals
• Screen size: important to ensure uniform roasting, which improves final product quality
• Classification of defects or imperfections
• Number of defects or imperfections
• Bean density
• Cup quality

European buyers typically do a green coffee assessment. This includes a screen-size evaluation, defect count and an assessment of bean colour, appearance and smell. This is followed by a moisture check and water activity analysis. Sample roasting is then done to evaluate green coffee quality and uniformity.

Sensory assessment: coffee cupping

Coffee is also assessed and scored by a method called cupping. Buyers use different protocols and standards to conduct a sensory assessment. However, the SCA recommends specific guidelines and protocols for cupping coffee. The most widely used cupping tool is the SCA’s Coffee Taster's Flavor Wheel. Some of the quality attributes assessed are: flavour, fragrance/aroma, aftertaste, acidity, body, uniformity, balance, cleanliness, sweetness and off-notes. Overall ratings provide a summary assessment based on a scale of 50 to 100; the higher the score, the better the quality.

Note that there is no exact definition of specialty coffee within the coffee industry. The Coffee Quality Institute and the cupping protocols of the Specialty Coffee Association consider coffees graded and cupped with scores below 80 to be standard quality and not specialty. Nevertheless, the exact minimum scores defining specialty coffee differ per country and per buyer. Most buyers consider 80 too low and demand a cupping score of 85 or higher for it to be considered specialty.

If you sell specialty coffee, it is important for buyers to know the cupping score of your coffee. Although not mandatory, it is highly relevant to add this information to the documentation of the coffee you are exporting – this may add value to your product. Therefore, it is very important to be aware of the quality of your coffee, either through local cupping experts or by becoming a cupping expert yourself. Note, however, that your coffee will most likely be cupped again at the destination market by your buyer. Most coffee will be approved based on the cupping results of the pre-shipment sample.

Figure 3: SCA Coffee Taster’s Flavor Wheel

Source: sca.coffee

Social responsibility

European buyers are increasingly addressing social and environmental issues in the coffee supply chain, and it is becoming common for them to develop corporate social responsibility (CSR) policies and codes of conduct that suppliers must follow. Sometimes they also become involved in local social and environmental projects.

Have a look at the websites of these small and mid-sized coffee importers for examples of sustainability codes of conducts and/or projects they have set up at origin:

• GEPA (Germany), Ethiquable (France) and Altromercato (Italy): these are all importers that work on the basis of fair trade principles.
• This Side Up (the Netherlands): specialty coffee importer that empowers farmers by helping them become fully independent agro-entrepreneurs.
• Nordic Approach (Norway): specialty coffee importer that focuses solely on sourcing traceable green coffees, they for instance work on the ground in origin to contribute to product development.
• Efico (Belgium): this coffee importer created the private Efico Foundation, which promotes sustainable coffee production through certification, training and education programs.

Examples of sustainability codes of conducts and/or projects from large importers and roasters are:

• Neumann Kaffee Gruppe: Corporate Responsibility. The group also founded the independent NGO Hanns R. Neumann Stiftung, with which it implements several coffee-based projects to promote a sustainable coffee economy.
• Lavazza: Sustainability World. The company founded the Lavazza Foundation, which implements sustainability projects to support coffee producing communities worldwide.
• Nestlé: Sourcing coffee responsibly, which they do through their own programmes Nescafé Plan and Nespresso AAA Sustainable Quality Program.
• Louis Dreyfus Company: Sustainable Coffee, which is focused on the expansion of certified/verified coffee and the implementation of projects at origins to support coffee farming communities.
• Starbucks: Ethically Sourced Coffee. Starbucks sources its coffee through its own developed sustainability standard, the C.A.F.E. Practices. The company also has six farmer support centres around the world, providing training to farmers.

Some examples of sustainability codes of conducts from retailers are:

• Ahold Delhaize (Netherlands/Belgium): Their own brand complies with either Rainforest Alliance/UTZ or Fairtrade standards
• Marks and Spencer (United Kingdom): coffee products are all Fairtrade-certified
• Lidl (Germany): coffee products either Rainforest Alliance/UTZ, Fairtrade and/or organic certified

These codes of conduct may also affect you as a supplier. They may, for instance, require you to sign a suppliers’ code of conduct in which you declare that you do your business in a responsible way, meaning that you (and your suppliers) respect local environmental and labour laws, do not engage in corruption, etc. These aspects are also investigated further in company audits carried out by your (potential) buyer.

Besides the suppliers’ code of conduct from various companies, it is important to be aware that the EU is implementing its so-called European Green Deal. This Green Deal has the aim of making Europe sustainable and climate neutral by 2050. To achieve this goal, the EU is for instance working on EU law that requires companies to address human rights and environmental standards within their value chains, including coffee. As with the corporate codes of conduct, companies will require you to comply with these additional requirements.

The EU also aims to introduce measures to tackle European and global biodiversity loss. Specific actions include the EU Regulation on deforestation-free products, including coffee, for which the first legislative proposal was published in November 2021.

Sustainability certification

Certification is the most common way to show compliance with Corporate Social Responsibility (CSR) criteria. As such, many European companies, especially those in Northern and Western European countries, increasingly adhere to sustainability certification schemes. Various certifications focus on different issues and are popular in different countries or segments. Understanding the different certification standards is an important step towards accessing the EU market.

The major certification schemes in coffee are Fairtrade, organic, Rainforest Alliance/UTZ and 4C. Having at least a Rainforest Alliance/UTZ, organic or Fairtrade certification has almost become a requirement for doing business with European importers.

Rainforest Alliance/UTZ has large-scale operations, reaching mainstream markets in Europe. As of July 2020, Rainforest Alliance offers mutual recognition options for coffee. This means that companies at the end of the supply chain will be able to source UTZ and/or Rainforest Alliance-certified coffee and then use either the Rainforest Alliance or the UTZ label on their product.

You can consult the guide for farmers on how to get Rainforest Alliance certified here. If you are an exporting company, refer to this guide on how to get chain of custody certification. In June 2020, the Rainforest Alliance published its new certification program for farmers and companies. Audits under this new standard began in July 2021.

4C, which stands for Common Code for the Coffee Community, also serves the mainstream market. Access their website to find out how to obtain a 4C certificate.

Table 1: Most important third-party certification standards requested by European coffee buyers

Source: ProFound, 2021 (information retrieved from ITC Standards Map and specific standards’ websites)

Read more about Fairtrade and organic in the section below.

3. What are the requirements for niche markets?

If you want to enter a specific niche market, you should comply with specific niche requirements. These requirements will differ per buyer and may refer to one of the certification standards mentioned below. They primarily focus on strict and/or specific sustainability principles and apply to niche segments of the coffee market, some of which are increasingly present on mainstream markets – such as organic and fair trade. Meeting these additional requirements for value addition can increase your chances on the market considerably.

EU Organic and biodiversity-focused certification schemes

‘Organic by default’ does not exist from the perspective of European authorities and buyers. This means that organic certification entails more than ‘naturally grown’ and pesticide-free. In order to market coffee as ‘organic’ on the European market, it must comply with EU legislation (2018/848) on organic production and labelling. Regulation (EU) 2021/2306 describes rules on official controls and the certificate of inspection required for organic products and in-conversion products imported from third countries.

Note that this new EU organic regulation came into force on 1 January 2022. Producers in third countries (outside of the European Union) will now be subject to more rigorous inspections and verifications by authorities and control bodies. Inspections of organic production and organic products have become stricter to prevent fraud.

Before you can market your green coffee as organic, an accredited certifier must audit your growing and/or processing facilities. Refer to this list of recognised control bodies and control authorities issued by the EU to ensure that you always work with an accredited certifier. To become organic certified, you can expect a yearly inspection and audit, which aims to ensure that you comply with the rules on organic production.

Note that all organic products imported into the EU must have the appropriate electronic Certificate of Inspection (COI). These COIs must be issued by control authorities prior to the departure of a shipment. This requires you to get necessary information, such as importer address and TRACES number, first consignee, seal and vessel number of your container. If this is not done, your product cannot be sold as organic in the European Union and will be sold as a conventional product. COIs can be completed by using the European Commission’s electronic Trade Control and Expert System (TRACES), where you will also have to register as organic exporter.

If you want to export to countries outside of the EU, check the legislation of that country. For instance, Switzerland has its own Swiss Organic Law, and the Organic Products Regulations 2009 apply in the United Kingdom. Note that countries outside the EU require a specific COI, such as the GB COI.

In addition, most European countries also have their own voluntary organic standards and labels, next to the EU organic label. Examples are Bio-Siegel (Germany), AB mark (France) and the Ø logo (Denmark). Some countries also have private standards or labels, for instance Naturland (Germany), Soil Association (United Kingdom), Bio Suisse (Switzerland) and KRAV (Sweden).

Note that most private standards have additional requirements on top of EU organic legislation. Therefore, always check the requirements on the official website of the standard itself. For instance, see Naturland’s comparison of its higher standards with the EU organic regulation.

Next to EU organic, there are other certification standards that use organic certification as a baseline, such as Demeter and SMBC Bird Friendly. Demeter is a biodynamic certification label and regarded as the highest grade of organic farming in the world. Demeter’s biodynamic certification requires biodiversity and ecosystem preservation, soil husbandry, livestock integration and prohibition of genetically engineered organisms.

SMBC bird-friendly certification promotes coffee farms that provide good, forest-like habitat for birds. Bird-friendly coffees are shade-grown, hence planted under a canopy of trees, and must also meet organic standards. Within Europe, the largest market for products certified by this standard is the United Kingdom.

Fair trade certification

The most common fair trade standard in Europe is Fairtrade International (FLO). The accredited certifier for Fairtrade is FLOCERT. Only after accreditation are you allowed to put the Fairtrade logo on your product.

Note that Fairtrade has introduced new requirements for certification on 1 June 2020. This will require coffee cooperatives, traders and other operators to have commitments in place for new Fairtrade sales volumes, which must be confirmed by the end buyer and validated by the respective national Fairtrade organisation. This new requirement aims to ensure that new and current cooperatives will immediately be able to sell their coffee under Fairtrade terms, thus providing the related benefits to farmer members.

Fairtrade producers are paid a Fairtrade Minimum Price. The current minimum prices and premiums for coffee, whether organic-certified or conventional, can be found in the Fairtrade Minimum Price and Fairtrade Premium Table. Refer to this full guidance to learn more on how to become a Fairtrade producer.

Other fair trade standards used on the European market are Fair for Life (by Ecocert IMO) and Fair Choice (by Control Union). Both standards do have the advantage of fewer costs, as the control bodies may combine the fair trade audit with the organic or Rainforest Alliance audit. However, it is important to always check for demand and interest for a specific certification with your (potential) buyer. Also, in the case of Fair Choice and Fair for Life, check if and what kind of premium would be involved, as this is not regulated like in the case of Fairtrade’s minimum price.

Another certification possibility is the Small Producers' Symbol (SPP). SPP focuses on social impact, adopting community-based sustainability principles. The SPP is supported by an independent certification system. Its label represents the alliance among organised small producers who build a local and global market that values the identity and the economic, social and cultural contributions of products from small producers’ organisations. As a producer you can also become a part of this network.

High-end specialty coffee

The high-end specialty coffee segment is characterised by a very high cupping score (around 87 and above), innovative processes (such as natural and honey-processing), direct trade relations, and high transparency and traceability from source to consumer. This means that buyers of these coffees ask for requirements that go beyond the requirements for certification.

Besides high quality, these buyers are interested in your origin stories; for instance, information about your coffee farm, the coffee growers and your processing facilities. This implies that you should know the specifics of your coffee, from soil management to the cup, from variety to processing, from external suppliers to farmers, and must be willing to share these honestly. Other than that, direct trade may result in more frequent coffee farm visits and product assessments by your buyers, as well as long-term business relations.

ProFound – Advisers In Development carried out this study on behalf of CBI.

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