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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 often 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 Regulation 669/2009.

Tips:

  • Make sure your products comply with the General Food Law (Regulation EC 178/2002) and the General rules on Food Hygiene (Regulation EC 852/2004).
  • Check the European Commission’s guidance document for information on certain key questions related to import requirements and the European rules on food hygiene and official food controls.
  • Read more about health control on the European Union’s Trade Helpdesk.
  • Check EUR-Lex website for the most recent list included in the Annex of European Commission Regulation 669/2009 (see under Amended by). The list of products and countries subjected is updated regularly. It is important to keep up-to-date on developments despite the limited increased levels of controls for coffee.
  • Refer to the EU’s Rapid Alert System for Food and Feed (RASFF) database to see examples of withdrawals of coffee from the market and the reasons behind these withdrawals. Under ‘Product’, choose the category ‘cacao and cacao preparations, coffee and tea’. In addition, you can choose your country under ‘Country’ to see examples of non-compliances. This can be a basis for your own risk management system and to avoid future border rejections.
  • Carry out a HACCP scheme to reflect on critical points (potential hazards) in your supply chain that you need to control. Your scheme needs to be based on the seven basic principles of the HACCP-system. Read more about how to manage HACCP for coffee on the website of International Trade Centre: Coffee Guide.
  • Refer to the website of SGS, the world’s leading inspection, verification, testing and certification company, for further information on HACCP and other food safety standards.
  • Familiarise yourself with food safety and Quality Management Systems (QMS). Read more on the different Food Safety Management Systems at the International Trade Centre’s Standards Map.

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
  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.

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. As of December 2019, a group of four countries (France, Hungary, the Netherlands and Sweden) is assessing the renewal of approval of glyphosate after 2022. The controversial herbicide has been under global attack from politicians and environmentalists alike, and a prohibition coming in the next years.

For organic coffee, it goes without saying that Pesticide Residue Levels should be (next to) zero, which has been difficult for some exporters in the case of glyphosate, causing the coffee to lose its organic status.

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 MRL. This should not cost more than a few hundred euros.
  1. Mycotoxins

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 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:

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 or dry process, washed or natural)
  • 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

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 topics 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 what the cupping score of your coffee is. Although it is not mandatory, it could be relevant to add this information to the documentation for the coffee you are exporting. Note, however, that your coffee will most likely be cupped again at the destination market.

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 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.

Sustainable 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 (Common Code for the Coffee Community). 4C is a verification rather than certification scheme and is generally not seen as a value-adding standard. Rainforest Alliance/UTZ has large-scale operations and reaches mainstream markets in Europe. Although UTZ and Rainforest Alliance merged in 2018, they do not offer a mutual recognition option for coffee yet. Organic and Fairtrade, once considered standards for niche markets, are increasingly present in the mainstream (super)market.

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.
  • See our study on sustainable coffee for more information about the demand on the European market, trends and specific trade channels.

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 certification is a non-legal requirement for coffee. In order for a company to market their product as such in the European market, it must comply with the European Union’s regulations for organic production and labelling – which is in itself a legal requirement. The requirements for organic production and labelling are laid down in European Union legislation and an accredited certifier must audit your growing and processing facilities.

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, this largest market for products certified by this standard is the United Kingdom.

Tips:

Fair trade certification

Securing fair-trade certification for your coffee is the most reliable way of showing your business performance with regards to social conditions in your supply chain. After certification by an independent third party, you are allowed to put a fair trade logo on your product, of which Fairtrade is the most common one. In general, prices for fair-trade products consist of a minimum price plus a premium.

Fairtrade International (FLO) is the leading standard-setting and certification organisation for fair trade. Products that carry the Fairtrade label indicate that 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.

Other fair-trade standards available in the European market are Fair Trade Ecocert and Fair for Life. Fair Trade Ecocert checks for for guaranteed minimum prices, producer support and good agricultural practices. For this standard, an organic certification is required. Fair for Life has a similar proposition and is a standard for companies that demonstrate decent working conditions and commit to fair sourcing and responsibilities towards their primary producers. Fair for Life certification of products also confirms traceability of all certified products from production to sales. Organic certification is not compulsory for Fair for Life holders.

The Small Producers' Symbol (SPP) also 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 far beyond certification.

Buyers of high-end specialty coffee will visit your coffee farm, may be your partners in product development and may try to establish a long-term relationship with you. 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.

Tip:

  • Read our tips on finding buyers and doing business in Europe to learn more about, amongst others, how you can invest in sharing your story online and prepare well for future buyer visits.

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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