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

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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 and maximum contaminant levels. Furthermore, European coffee buyers increasingly have additional requirements that you need to comply with to target specific segments or to keep up with the market. These are especially in the field of (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.

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 European Commission’s Trade Helpdesk gives a complete overview of (legal) requirements on the European coffee market. The Product Code for coffee products is 0901.

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.

An important aspect of controlling food safety hazards is defining your critical control points. This means that you define the risks in your supply chain, indicating how you prevent or mitigate and monitor these risks, as well as what to do if something does go wrong. Elaborating such a Hazard Analysis Critical Control Points (HACCP) scheme can be done in collaboration with consultants specialised in implementing food management principles.

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 often not 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 BRC.

Another strategy to ensure food safety as a producer is to follow good agricultural practices. The main standards in this area are provided by GLOBALG.A.P. They are voluntary 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 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.

Tips:

Food contaminants

Food contamination can occur at different stages of the production process due to environmental contamination, 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 on the basis of 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. Salmonella
  4. Extraction solvents
  5. Other: Polycyclic Aromatic Hydrocarbons (PAHs), Acrylamide

Tips:

  • You must comply with the regulation on contaminants in foodstuffs (Regulation EC 1881/2006); otherwise your products will not be allowed into the European market. Suppliers to Europe are responsible for ensuring that imported foodstuffs comply with European legislation.
  • Check the European Commission’s factsheet ‘Managing food contaminants: how the EU ensures that our food is safe’ for further information on food contamination control in the European Union.
  • Focus on applying good agricultural practices to reduce the presence of food contaminants, as the risk of contamination of any kind can be prevented by better growing, drying, processing and storage practices. Information on good agricultural practices in coffee production can, amongst other, be found on the website of the World Coffee Research.
  • For information on safe storage and transport of coffee, refer to the website of the Transport Information Service.
  1. 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 will be withdrawn from the European Union’s market. For organic coffee, it goes without saying that MRLs should be (next to) zero.

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.

Tips:

  • Check the legislation regarding the control of pesticide residues (Regulation EC 396/2005) for further information on pesticides.
  • Consult the EU pesticide database for an overview of the maximum residue levels (MRLs) for each pesticide. You can search on your product or pesticide type. Always check with your buyers if they require additional adherence to MRL limits and pesticide use.
  • Focus on reducing the amount of pesticides in your products. A good way to do this is applying Integrated Pest Management (IPM), an agricultural pest control approach that uses complementary crop management strategies and practices to help minimise the use of pesticides. Useful sources are the European Centre for Integrated Pest Management and the Trainee Manual on Integrated Pest Management from CropLife International.
  • If in doubt or to avoid any doubt from your potential buyer, get your coffee analysed by a (preferably EU-accredited) laboratory to test for presence of MRLs. This should not cost more than a few hundred euros.
  1. Mycotoxins / mould

Moulds are another important reason for coffee border rejections. Ochratoxin A (OTA) levels, which are found on green coffee beans, are a specific point of attention. Although there is no specific limit for green coffee beans, for roasted and ground coffee the maximum OTA level is set at 5 μg/kg, and for instant coffee the maximum level is set at 10 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.

Tips:

  • Focus on good agricultural, drying, processing and storage practices, for example by adopting Good Agricultural Practices and/or Good Manufacturing Practices. These steps have a significant influence on the development of mycotoxins.
  • Read and follow the Codex Alimentarius’ Code of Practice for the Prevention and Reduction of Ochratoxin A Contamination in Coffee (CXC 69-2009).
  • If in doubt, get your coffee analysed by a (preferably EU-accredited) laboratory to test for presence of Mycotoxins. At the writing of this report, Eurofins charges a little under €100 for an Ochratoxin A test, and a little over €100 for an Aflatoxin (another mycotoxin) test.
  1. 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.

Tips:

  1. 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).

Tip:

  1. Other: Polycyclic Aromatic Hydrocarbons (PAHs), Acrylamide

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 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).

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.

Tips:

General requirements on packaging and labelling

The European Union’s food labelling legislation does not apply to bulk products such as green coffee. However, 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:

Green coffee is traditionally shipped in woven bags made from natural fibres, such as jute or burlap. These bags typically hold 60 or 70 kilogrammes of green coffee. However, jute and burlap bags do not protect against moisture. As such, plastic big bags and plastic container liners are increasingly used, although they may still let some moisture in. 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 other innovative materials like Videplast bags 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.

Tip:

  • Refer to the non-product specific legislation on labelling and packaging for more information on rules which apply to all goods marketed in the European Union.

2. What additional requirements do buyers often have?

Some buyers have requirements that go beyond existing legislation, in particular regarding food safety, environmental impact and social responsibility. Northern-European and Western-European countries generally have stricter additional requirements than Southern-European and Eastern-European countries.

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. The quality of green coffee is graded and classified before export. There is no universal grading and classification system for coffee. The Specialty Coffee Association’s standards for green coffee grading is often used as a point of reference. However, most producing countries have and use their own grading systems.

The International Trade Centre states that grading is usually based on the following criteria:

  • Altitude and/or region
  • Botanical variety
  • Preparation (wet-processed (washed), dry-processed (natural), semi-washed (wet-hulled), pulped natural or honey-processed)
  • Bean size (screen size), sometimes also bean shape and colour
  • Number of defects (imperfections)
  • Roast appearance and cup quality (flavour, characteristics, cleanliness)
  • Density of the beans

Screen size is important to ensure that coffee batches are uniform in size, as that allows for uniform roasting which improves the quality of the final product.

The Organisation for Standardisation (ISO) also provides specific standards on coffee quality, such as ISO 10470 (Green coffee - Defect reference chart).

Specialty coffee is graded according to its cupping profile. Fragrance, flavour, aftertaste, balance, acidity, sweetness, uniformity and cleanliness are important factors in the grading process. This process is based on cupping protocols. 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 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.

Tips:

  • Read more about the quality requirements of the coffee industry at the website of the Coffee Quality Institute and follow its recommendations on how to improve quality along the value chain.
  • Learn more about coffee cupping and cupping scores on the website of the Specialty Coffee Association. Consider obtaining a Q-grader certificate to be able to cup and score your Arabica coffee according to international standards of aroma and taste. If relevant, explore opportunities to become a R-grader (or Q Robusta grader) as well.
  • Promote the quality of your coffee. Start by giving an accurate description of the physical properties of the coffee, such as screen sizes, which and number of defects, at what altitude the coffee was grown, how the cherries have been processed, etc. Additionally, if possible, cup your coffee, give a rating and mention the cupping protocol of the rating.
  • Learn more about maintaining the quality of your coffee during transportation on the website of the Transportation Information Service.

Social responsibility

European buyers are increasingly addressing social and environmental issues, for which they develop Corporate Social Responsibility (CSR) policies or codes of conduct. Sometimes they also become involved in local social and environmental projects. European buyers will expect you to comply with their policies and/or codes of conduct.

Examples of sustainability codes of conducts and/or project from smaller coffee importers are:

  • GEPA (Germany), Ethiquable (France) and Altromercato (Italy) 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 programs 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:

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.

Tips:

  • Investigate the existing sustainability standards established by retailers and roasters by looking into the sustainable sourcing pages on their websites, or by approaching roasters, importers and sector specialists directly. Check whether you can adhere to the guidelines laid down by these standards. They can be a good starting point if you want to supply coffee to these companies.
  • Consider participating or visiting roundtable meetings (via conference call) or seminars to meet industry players and other interesting stakeholders. Check out the website of the International Coffee Organisation (ICO) to keep up-to-date on these discussions.
  • Consider developing and implementing your own CSR policy or code of conduct. This is not always required by buyers but may be a good way to show potential buyers your views on social responsibility. Furthermore, this may help you to stand out when your buyer has to choose between several suppliers.
  • Ensure that your suppliers also have responsible business practices in place. Many social and environmental issues take place at farm level, which may not be a part of your direct (handling and processing) activities. To test to what extent your farmers are sustainable, you could ask them to fill in the Farm Sustainability Assessment by the Sustainable Agriculture Initiative.

Sustainability certification

Certification is the most common way to show compliance with Corporate Social Responsibility 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. 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 has published its new certification program for farmers and companies. Audits against this new standard will begin from 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.

Organic and Fairtrade, once considered standards for niche markets, are increasingly present in the mainstream (super)markets. Having at least a Rainforest Alliance/UTZ, organic or Fairtrade certification has almost become a requirement for doing business with European importers.

An alternative for selling uncertified coffee is to position yourself in the specialty segment with very high quality coffees, usually with cupping scores above 87 points. Low and average-quality coffees without certification are subject to very low international prices. To read more about the size of the certification schemes and its importance in different European countries, refer to our study on statistics and outlook on the European coffee market.

Tips:

  • For a full overview of certification schemes, please consult the ITC Sustainability Map.
  • Consider applying for certification. Certification can provide your company with opportunities such as trainings on more efficient agricultural practices and becoming independent of synthetic chemicals for fertilisation. In addition, certification can lead to access to new markets for exporters and cooperatives. Most certification schemes have trainings, tools or other types of assistance to help you understand the criteria and educate you on how to become certified.
  • When opting for certification, consider multiple certification schemes. For example, investigate the accessibility of certification programmes in your country or region, the credibility and recognition of the available certification programmes, the costs of certification and the type of certification preferred by buyers in your main European target markets.
  • Look into the different operators worldwide which handle Rainforest Alliance/UTZ certification. This will provide you with insight into the countries where these certifications are most demanded, and the players which can be your potential buyers.

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.

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 1235/2008 describes the implementing rules of the EU legislation for imports of organic products from third countries.

The new organic regulation (2018/848) was published in 2018, and will apply from 1 January 2021. Check the IFOAM Organics Europe website to find out what the new regulation will imply for you as a producer. As a coffee producer, you will have to comply with the same rules as producers in the European Union. The new regulation will reinforce controls and enhance possible actions against fraud.

In order to export your organic product, it is important that you issue your Certificates of Inspection (COIs) by control authorities prior to the departure of a shipment (Article 13 (2) EU 2020/25). If this is not done, your product cannot be sold as organic in the EU 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).

If you want to export to countries outside of the EU, check the required legislations by that country. For instance, Switzerland has its own Swiss Organic Law and the Organic Products Regulations 2009 apply in the United Kingdom.

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 demand additional requirements, in addition to those of the EU organic legislation. Therefore, always check the requirements asked for by the official website of the standard itself. For instance, you can check the additional requirements asked for by Naturland, in comparison to the EU organic regulation, by clicking here.

Before you can market your coffee as organic, an accredited certifier must audit your growing and 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. After being audited and receiving an organic certificate, you can use the EU organic logo on your products.

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 markets for products certified by this standard are the United Kingdom and France.

Tips:

  •  
  • Consult the International Trade Centre’s Standards Map database for a full overview of different organic labels and standards.
  • Familiarise yourself with the requirements of organic certification, for example the standard of the International Federation of Organic Agriculture Movements (IFOAM).
  • Only use a certifier accredited by the EU. Otherwise you will risk your certificate not being recognised by European buyers. Periodically, changes are made in the area of ​​accredited inspection bodies. This is incorporated in TRACES.
  • If you have any questions about issuing a COI and what this means for your export, it is best to contact your inspection body. They are the first point of contact for further questions regarding any changes. Your (potential) client also may have information that can help you.
  • Read our study on Exporting organic coffee to the European market to learn more about the market for organic coffee in Europe.

Fair trade certification

Fairtrade International (FLO) is the leading standard-setting and certification organisation for fair trade. Products that carry the Fairtrade label indicate that producers have been audited by FLOCERT (the accredited certifier for Fairtrade). 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.

Note that Fairtrade has introduced new requirements for certification on 1 June 2020. This will require coffee cooperatives and traders 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.

Other fair trade standards used on the European market are Fair for Life (by Ecocert IMO) and Fair Choice (by Control Union). 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.

Tip:

  • Before engaging in any sustainability certification programme, make sure to check (in consultation with your potential buyer) that this label has sufficient demand in your target market and whether it will be cost-beneficial for your product. For Fairtrade certification, you can use this calculation cost tool.

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 the stories behind the origins of your product, your coffee farm and the coffee growers. 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.

Tip:

This study has been carried out on behalf of CBI by ProFound – Advisers In Development.

Please review our market information disclaimer.

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