THE PROCESS IN MOTION

How many texts touch a single bag of coffee, and who applies them?

Start the scene or choose a stage. The animation simplifies the mechanism; what follows gives the details and the available references.

▶ Play the process01The plot02The port03The border04The roastery05The shelf06The trash bin

The plot

The bag begins on a plot in a producing country. The European regulation against imported deforestation, the EUDR, will require whoever places this coffee on the Union market to prove, with geolocation, that no forest was cut there after December 31, 2020. The law of the producing country applies too.

Read the stages without animation

1. The plotThe bag begins on a plot in a producing country. The European regulation against imported deforestation, the EUDR, will require whoever places this coffee on the Union market to prove, with geolocation, that no forest was cut there after December 31, 2020. The law of the producing country applies too.
2. The portAt the port of export, each bag carries the identification mark of the International Coffee Organization, and each export a certificate of origin, a copy of which goes to the Organization within 60 days. This is an obligation of the exporting country: no Union text read for this section makes it a condition of entry.
3. The borderAt the Union border, customs classifies the bag in the combined nomenclature, heading 0901. Pesticide residues are judged on the green bean, and an official control may take a sample, without prior notice. The importer carries the proof, organic certificate included if the coffee is organic.
4. The roasteryAt the roastery, the roasted bean becomes subject to the ochratoxin A limit, a mold toxin born at drying and storage: 3.0 µg/kg, whereas the green coffee had none. The roaster also answers for acrylamide, the hygiene of its roastery and the word “coffee,” reserved by the French decree of 1991.
5. The shelfOn the shelf or on the online store, the pack carries the name of whoever sells it, and it is that seller who answers for the label, even if a roaster bagged it for them. The fairness of the label, the weight and fraud fall to the DGCCRF; food safety has passed to the DGAL, which stays in the background here.
6. The trash binThe empty bag falls under yet another text, the European packaging regulation, and the French anti-waste law. The whole picture becomes clear: six stations, each under an authority that sees only its own. None looks at the bag as a whole.

To remember: The first party responsible for the compliance of a coffee is the company under whose name it is sold, not the administration or the supplier.

In history: In history: the decree that reserves the word “coffee” in France dates from April 3, 1991, issued to apply the law of August 1, 1905 on fraud.

Read the full article and its sources ↓

State of the law as of October 21, 2026. 4 deadlines fall after this date; they are listed at the end of the section.

A layering, not a mess

When people say that coffee regulation is a jungle, they describe a fair impression with a wrong cause. Coffee has almost no text of its own: in France, a decree of 1991 on what may be called coffee; in the Union, a directive of 1999 on extracts. Everything else comes from general texts, written for all foods or for seven agricultural commodities, and which apply to coffee because it is one of them. The difficulty is not the number of rules, it is that none looks at the whole bag: each step falls under an authority that sees only its own.

Regulation, directive, decree: three ways to oblige

The European Union (EU) legislates in two ways, and the difference explains why some rules are identical everywhere and others are not. A regulation applies as it stands in all twenty-seven Member States, on the same day, without passing through national law: this is the case of Regulation (EU) No 1169/2011, the FIC Regulation (food information to consumers), which governs the label; of Regulation (EU) 2023/915 on contaminants; of Regulation (EU) 2023/1115 against imported deforestation, the EUDR (EU Deforestation Regulation). A directive sets a result and leaves each Member State to write it into its own law: Directive 1999/4/EC on coffee extracts was transposed in France by Decree No. 2001-977 of October 26, 2001. This directive has one feature that matters: its Article 3 forbids Member States from adopting, for extracts, national provisions that it does not provide for (source 4). For instant coffee, harmonization is therefore total.

Roasted coffee, for its part, has never been harmonized. That is why France keeps a text of its own, Decree No. 91-340 of April 3, 1991, issued for the application of the law of August 1, 1905 on fraud, in force as of October 21, 2026 and last amended on April 3, 1997 (source 5). It reserves the word “café” and sets the maximum water, ash and residual caffeine contents (section 2). This decree does not close the border: a product lawfully made and named in another Member State may keep its original name in France, which must be supplemented if it does not let the consumer know the true nature of the product (Article 17, paragraph 2, of the FIC Regulation, source 6).

The foundation: the food business operator answers first

Beneath all these texts, one regulation serves as a constitution: Regulation (EC) No 178/2002, which lays down the principles of food law. Its Article 17 overturns what one might imagine: it is not the State that guarantees a coffee is compliant, it is the operator, at every stage under its control; the State checks that it does so (source 1). Article 18 imposes traceability known as “one step back, one step forward”: everyone must be able to name who supplied the coffee and to whom it was delivered, and tell the authorities that ask. Article 19 requires withdrawing a product from the market, and informing the authorities, as soon as the operator “considers or has reason to believe” that it is not safe; if the product may have reached the consumer, the consumer must be informed and, if necessary, the product recalled. A distributor that touches neither the packaging, nor the label, nor the product acts only “within the limits of its own activities,” but it must pass on the information and cooperate (Article 19, paragraph 2).

For the label, the same logic points to a specific person: the operator “under whose name or business name the food is marketed,” or the importer if that operator is not established in the Union (Article 8 of the FIC Regulation, source 6). A coffee sold under a retail chain’s brand therefore binds the chain, even if a roaster bagged it for them. Official controls follow Regulation (EU) 2017/625: regular, proportionate to risk, and carried out “without prior notice” unless justified (Article 9, source 2). A roastery must also be known to the administration: every establishment that produces, processes or distributes food is notified to the competent authority for registration (Article 6 of Regulation (EC) No 852/2004, source 3).

Who inspects in France, since 2024

For decades, two administrations shared food: the DGCCRF (the Directorate-General for Competition, Consumer Affairs and Fraud Control, Ministry of the Economy) and the DGAL (the Directorate-General for Food, Ministry of Agriculture). In mid-2022 the government decided to create a “single police” for food safety. The calendar published by the DGCCRF on December 15, 2023 is as follows: missions transferred at central administration level since January 1, 2023; withdrawal of DGCCRF officers from production inspections since September 1, 2023, then from direct retail inspections on December 31, 2023; mission “fully entrusted” to the DGAL from January 1, 2024 (source 7). The DGCCRF keeps “the fairness of labeling and value-adding claims, as well as the fight against fraud.”

For a bag of coffee, the split can be stated simply. Too high a level of ochratoxin A or a pesticide residue falls to the DGAL and its departmental services, the DDPP (departmental directorates for the protection of populations). A “pure arabica” that is not one, a missing weight or a decaf too rich in caffeine fall to the DGCCRF. In the field, the boundary is less sharp, and the DGCCRF itself writes that safety and fairness are “sometimes closely linked.” Above the two, the RASFF (the Union’s rapid alert system for food and feed) connects the authorities of the States: from 2019 to October 20, 2026, 107 notifications match the search “coffee,” and the most frequent named cause is ochratoxin A (source 11).

The bag, station by station

The table follows a bag from the plot to the bin. It keeps only the texts that oblige. Private standards (labels, audit frameworks, standards of the International Organization for Standardization, ISO) oblige only if a contract takes them up; section 9 treats them separately.

The surprising fact: the limit falls on the roaster

Regulation (EU) 2023/915, consolidated as of August 19, 2026, sets a maximum level of ochratoxin A, a toxin produced by molds during drying and storage, of 3.0 µg/kg for roasted coffee beans and roasted ground coffee, and of 5.0 µg/kg for instant coffee (Annex I, points 1.2.14 and 1.2.15, source 9). It sets none for green coffee. The defect is born on the farm or in the warehouse, but the legal limit applies to the roaster’s product, which is the first to process and therefore the first to sell a product subject to the threshold. The French decree of 1991 does require that green coffee have undergone “no alteration or contamination, notably by rot or mold” (Article 2, source 5), but without a figure. It is through the purchase contract, and through analysis on receipt, that the roaster passes this risk back upstream.

The countries of origin: rules that Europe does not ask for

Producing countries add their own layers. The oldest is the certificate of origin of the International Coffee Organization (ICO). Under its rules revised on October 7, 2022, “each export” of coffee, in all its forms, must be covered by a certificate issued in the country of origin, each bag carries an ICO identification mark, and a copy goes to the Organization within 60 days of shipment (source 10). Since the end of the export quotas of the International Agreement in 1989, the system mainly serves statistics. None of the Union texts read for this section makes it a condition of entry: it is an obligation of the exporting country. To this are added institutions that manage names, such as the National Federation of Coffee Growers of Colombia (FNC) or the Jamaican authority that controls Blue Mountain, and export standards specific to each country, which section 10 and the page on institutions of origin detail.

What this changes, and for whom

• Roaster: as the first operator to process, it receives ochratoxin A and acrylamide in the roasted coffee, the name of the food, the label if it sells under its own name, the registration of its roastery and the traceability of each lot.
• Importer: it carries customs, the EUDR if it is the first to place the coffee on the Union market, the organic certificate and the pesticide residues of the green coffee.
• Distributor: it answers only for what it touches, except when the coffee carries its brand; it must relay a withdrawal or a recall.
• Consumer: sees only the label, the most visible and least complete part of the system.

What comes into force after October 21, 2026

Three dates fall on coffee within the next fourteen months. The due diligence obligations of the EUDR apply from December 30, 2026, and from June 30, 2027 for micro and small enterprises (Article 38, source 8). Coffee extracts, essences and concentrates (heading 2101 11 00 of the Combined Nomenclature) enter Annex I of the EUDR from December 30, 2027 (source 8). The harmonized packaging sorting label is due by August 12, 2028 at the latest, or 24 months after the implementing act that will define it if that date is later (Article 12 of Regulation (EU) 2025/40, source 12).

The sources for this section

1. Regulation (EC) No 178/2002, Articles 17, 18 and 19, consolidated version of January 1, 2026 (CELEX 02002R0178-20260101) · online · primary
2. Regulation (EU) 2017/625, official controls, Article 9 · online · primary
3. Regulation (EC) No 852/2004, hygiene of foodstuffs, Article 6 · online · primary
4. Directive 1999/4/EC of February 22, 1999, coffee and chicory extracts, Article 3, consolidated version of November 18, 2013 · online · primary
5. Decree No. 91-340 of April 3, 1991 (coffee), Articles 1 to 7 and annex, version in force on October 21, 2026, read on screen · online · primary
6. Regulation (EU) No 1169/2011 (FIC), Articles 8 and 17, consolidated version of April 1, 2025 · online · primary
7. DGCCRF, “La sécurité sanitaire des aliments prise en charge par la DGAl,” December 15, 2023, archive capture of December 14, 2024 · online · primary
8. Regulation (EU) 2023/1115 (EUDR), Articles 2 and 38, Annex I, consolidated version of September 18, 2026 · online · primary
9. Regulation (EU) 2023/915, contaminants, Annex I, points 1.2.14 and 1.2.15, consolidated version of August 19, 2026 · online · primary
10. International Coffee Organization, Rules on Statistics, Certificates of Origin, ICC-102-9 Rev. 5, October 7, 2022 (introduction, rules 2, 3 and 4) · online · primary
11. RASFF Window, search “coffee,” 107 notifications from January 1, 2019 to October 20, 2026, via the public API; notifications 2026.3936 and 2021.2684 · online · data
12. Regulation (EU) 2025/40, packaging and packaging waste, Article 12 · online · primary
13. Rappel Conso, dataset rappelconso-v2-gtin-trie, notice 2026-04-0324 of April 30, 2026 · online · data