The European Commission has unveiled a preliminary delegated act that incorporates soluble coffee (instant coffee) and coffee extracts into the European Union Deforestation Regulation (EUDR).
This adjustment aims to address a notable oversight in the initial legislation, guaranteeing that all coffee-related products, irrespective of their processing phase, adhere to stringent environmental criteria prior to their entry into the EU marketplace.
For international coffee producers and the European Coffee Federation (ECF), this shift represents a significant change in their compliance approach, necessitating prompt changes to traceability frameworks for processed items that were previously not subject to these regulations.
Initially, the EUDR focused on unprocessed commodities, such as green coffee beans. However, stakeholders in the industry uncovered a gap: if soluble coffee remained outside the regulation’s purview, producers could process “non-compliant” beans abroad and import the resulting instant coffee without requisite due diligence.
The newly introduced proposal aims to level the playing field by incorporating Combined Nomenclature (CN) codes for soluble coffee and its extracts, thereby ensuring that processed coffee products comply with the same deforestation-free criteria established for raw beans, thus preventing relocations of production to regions with lighter regulation.
Integrating soluble coffee presents specific technical and logistical hurdles for both mid-stream and downstream supply chains:
– Traceability upstream for processed products now requires manufacturers to provide geolocation data pinpointing the exact plots where the beans for soluble extracts were cultivated.
– Soluble coffee production often entails “mass balance” blending of beans from various origins to maintain flavor consistency; under EUDR, each component of the blend must be confirmed as deforestation-free, complicating logistics for large-scale instant coffee manufacturers.
– Given that soluble coffee is a significantly processed product, the chain of custody is extended. Manufacturers will need to establish robust digital tracking systems that monitor the product’s journey from the farm to the extraction site and ultimately to the EU border.
The response from the industry has been a call for comprehensive clarity. The European Coffee Federation (ECF) has advocated for precise guidelines to mitigate market distortion. Although the addition of soluble coffee provides “regulatory consistency,” there are concerns regarding the timeline for implementation.
Manufacturers are requesting that the Commission create a “transition buffer” to facilitate the integration of these new products into the existing due diligence frameworks. There is also a demand for standardized data formats, ensuring that smallholder farmers in regions like Vietnam and Brazil—key suppliers of Robusta beans used in soluble coffee—are not unintentionally sidelined from the EU market due to the financial burden of digital mapping.
On a broader scale, this proposal reinforces the EU’s leadership role in environmental accountability. By closing the loophole related to soluble coffee, the EU ensures that its substantial consumption of “instant coffee”—a common element in both households and vending services—does not contribute to deforestation in biodiversity-rich areas.
