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  • Plate XXII · section 02 of 12

    Names and composition: what may be called coffee

    THE PROCESS IN MOTION

    What may be called coffee?

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

    Green coffee

    A Coffea bean freed from its parchment, the envelope that surrounds it, without alteration or contamination, “notably by rot or mold”: it may be called “green coffee” or “raw coffee.” The same 1991 decree also reserves the names of species and varieties: the word “arabica” is regulated like the word “coffee.”

    Read the stages without animation
    1. The green beanA Coffea bean freed from its parchment, the envelope that surrounds it, without alteration or contamination, “notably by rot or mold”: it may be called “green coffee” or “raw coffee.” The same 1991 decree also reserves the names of species and varieties: the word “arabica” is regulated like the word “coffee.”
    2. The roasted coffeeRoasting removes nothing: the bean becomes “coffee,” a product that has undergone “no subtraction of its constituent principles.” The decree’s annex limits it with three maximum levels by weight, each against an old fraud: 5% water, 6% ash, 1% stones or foreign matter.
    3. ChicoryChicory is added: the word “coffee” falls. Chicory, barley and blends must carry the qualifier “roasted” or be called “roasted substitutes,” with no possible confusion with coffee. This is the only article touched since 1991, in 1997.
    4. DecafDecaf has two thresholds and two texts. In bean or ground form, it is the French decree: 0.1% anhydrous caffeine at most, on the dry product. For instant, it is the 1999 European directive: 0.3% of the dry matter. No Union text sets the threshold for roasted coffee.
    5. Words without a text“Pure arabica” and “specialty coffee” are displayed with no article of law. No text says what share of canephora makes a “100% arabica” false, nor what a specialty is. Only the ban on misleading in the European regulation on consumer information catches them: one must be able to justify what the word suggests.

    To remember: In France, the word “coffee” is reserved for the product of roasting Coffea beans from which nothing has been removed; a blend with chicory or cereals is called a roasted substitute.

    In history: In history: each level in the 1991 annex targets an old fraud, water, stones and soil sold at the weight of coffee.

    Read the full article and its sources ↓

    State of the law as of October 21, 2026. One deadline falls after this date; it is at the end of the section.

    The word “café” is reserved, and the rule that reserves it is French, dating from 1991, still in force. The Union defines only extracts. Between the two, “pure arabica,” “specialty” or “flavored” live under a single rule: do not mislead.

    A word reserved by a decree of 1991

    Decree No. 91-340 of April 3, 1991 was reread on screen on Légifrance on October 21, 2026, in its version in force, table included (source 1). Its Article 1 goes further than one might think: it reserves for the products it defines not only the name “café,” with or without a qualifier, and any derivative of that word, but also the name of a coffee species “or of a variety of these species.” The word “arabica” on a pack is therefore governed by the same text as the word “café.” A second paragraph opens a door: the term remains permitted, according to usage, for foods or drinks “whose preparation required the use of coffee,” which covers a coffee cake or ice cream.

    The following articles set out four definitions in a chain. “Green coffee” or “raw coffee” means the beans from the cultivated species of the genus Coffea, freed of their parchment, with no “alteration or contamination, notably by rot or mold” (Article 2). Roasted “coffee” is the product of roasting that green coffee, “having undergone no removal of its constituent principles” (Article 3): nothing can have been taken out of it. “Ground coffee” is the grind of that roasted coffee (Article 4). “Decaffeinated coffee” is a roasted coffee from which the caffeine has been removed, or the roasting of a decaffeinated green coffee (Article 5). For the drink, finally, “coffee” means the product obtained from water and coffee (Article 6), and substitutes, chicory, barley, blends, must bear the qualifier “roasted” or be called “roasted substitutes” (Article 7, the only article amended since 1991, by Decree No. 97-298 of March 27, 1997).

    The figures in the annex, and why those

    Each line of the annex targets an old fraud. Foreign matter, stones and twigs, added weight; so did water, since water was sold at the price of coffee by weight; ash, that is, what remains after combustion, betrays added soil, husks or minerals (source 1).

    Roasted coffee parameterMaximum content by weightDetail in the text
    Stones or other matter foreign to coffee1 %Article 3 and annex
    Water5 %Does not apply to prepackaged coffees if dry matter makes up at least 95% of the net weight indicated
    Ash6 %Also apply to ground coffee (Article 4)
    Residual anhydrous caffeine of decaffeinated roasted coffee0,1 %Expressed on the “assumed dry product” (Article 5)

    The 0.1% threshold is therefore French, and calculated on dry matter. The DGCCRF (the Directorate-General for Competition, Consumer Affairs and Fraud Control) applies it by wording it “0.1 g / 100 g” in its 2018 survey (source 10). No European Union (EU) text sets a caffeine content for decaffeinated roasted coffee: several pages of the site attribute this figure to the European directive, which the review corrects.

    Decaf: two thresholds, two texts

    Decaf obeys two regimes depending on its form. As beans or ground, it is the decree of 1991 and its 0.1%. As instant coffee, it is Directive 1999/4/EC: the term “decaffeinated” is permitted only if anhydrous caffeine does not exceed 0.3% of the dry matter coming from coffee, and it must appear in the same field of vision as the name (Article 2, source 2). The decree adds a statement that almost nobody knows: when the coffee has been treated to remove part of the waxy layer of the beans, the labeling must say so “in an appropriate manner” (Article 5).

    Decaffeination solvents fall under a general text, Directive 2009/32/EC on extraction solvents (consolidated as of February 16, 2023, source 9). Dichloromethane is limited to 2 mg/kg in roasted coffee; methyl acetate and methyl ethyl ketone to 20 mg/kg in coffee or tea; ethyl acetate is among the solvents usable “in compliance with good manufacturing practice,” with no numerical residue. Section 4 treats these residues with the other contaminants.

    Instant coffee: a closed European definition

    Directive 1999/4/EC defines “coffee extract,” also called “soluble coffee” or “instant coffee”: a concentrate obtained by extracting roasted beans “using only water,” without hydrolysis by acid or base, which contains only the soluble and aromatic principles of coffee (Annex, point 1, source 2). The solid or paste extract may contain nothing else. The liquid may contain sugars, at 12% at most, and must then bear a statement such as “with sugar”; it may be called “concentrated” above 25% coffee dry matter; the paste and the liquid state their minimum dry matter content (Article 2). The directive expressly excludes “soluble torrefacto coffee,” made from coffee roasted with sugar.

    The big table of words

    The empty cells of the table are the point: these are words that sell without a definition.

    NameTextConditionWho controls
    Green coffee, raw coffeeDecree No. 91-340, Art. 2Coffea beans without parchment, sound, free of moldDGCCRF
    Coffee (roasted)Decree No. 91-340, Art. 3 and annexNo removal; foreign matter 1%, water 5%, ash 6%DGCCRF
    Ground coffeeDecree No. 91-340, Art. 4Grind of the roasted coffee, same water and ash contentsDGCCRF
    Decaffeinated coffee (beans, ground)Decree No. 91-340, Art. 5Anhydrous caffeine 0.1% at most, on dry productDGCCRF
    Coffee (beverage)Decree No. 91-340, Art. 6Water and coffeeDGCCRF
    Coffee extract, soluble coffee, instant coffeeDirective 1999/4/EC, Annex 1(a)Water only; coffee dry matter at least 95%DGCCRF
    Coffee extract pasteDirective 1999/4/EC, Annex 1(b)70 to 85% coffee dry matterDGCCRF
    Liquid coffee extractDirective 1999/4/EC, Annex 1(c)15 to 55%; sugars 12% at most; “concentrated” above 25%DGCCRF
    Decaffeinated coffee extractDirective 1999/4/EC, Art. 2(b)Anhydrous caffeine 0.3% of dry matter at mostDGCCRF
    Chicory extractDirective 1999/4/EC, Annex 295% (solid), 70 to 85% (paste), 25 to 55% (liquid, sugars 35% at most)DGCCRF
    Roasted substitute, roasted substitutesDecree No. 91-340, Art. 7Qualifier “roasted”; no confusion with coffeeDGCCRF
    Coffee cherry pulp, cascaraImplementing Regulation (EU) 2022/47Mandatory names; warning above 150 mg/L caffeineSplit not established (novel food)
    Coffee plant leaf infusionImplementing Regulation (EU) 2020/917Mandatory name; caffeine under 80 mg/LSplit not established (novel food)
    “Pure arabica,” “100% arabica”DGCCRF, under the ban on misleading
    “Specialty coffee”DGCCRF, under the ban on misleading

    The “who controls” column is deduced from the 2024 split (section 1): the name of the food is a matter of fairness, hence of the DGCCRF. For novel foods, the DGCCRF was still handling the files in 2018 (source 10); the current split with the DGAL, which holds food safety, is written in no text read.

    What is not defined: “pure arabica,” “specialty”

    No food text defines “pure arabica.” The decree of 1991 reserves the name of the species but does not say what share of canephora makes a “100% arabica” false. These statements fall under the general rule of Article 7 of Regulation (EU) No 1169/2011, the FIC Regulation (food information to consumers): information “shall not be misleading,” notably as to “nature, identity, properties, composition” or the country of origin (source 4). What remains is to measure. The marker used is 16-O-methylcafestol, a compound present in canephora and absent from arabica. Switzerland, outside the Union but associated with the joint action on coffee of operation OPSON VIII, conducted against food fraud under the coordination of Europol and Interpol, published its action threshold: above 50 mg/kg, the presence of canephora is no longer “technically unavoidable” (source 12). The Union has no equivalent threshold, and the DGCCRF says only that it is building a database of coffees by origin at the Service commun des laboratoires (Joint Laboratories Service) (source 10).

    “Specialty coffee” has no legal definition either. The score of 80 points out of 100 on the SCA scale (Specialty Coffee Association) is a private convention that no text takes up. Writing “specialty” engages only Article 7: one must be able to justify what the word implies.

    What is added to coffee: flavorings, mushrooms, pulp

    A flavored coffee is no longer a single-ingredient product: it carries a list of ingredients, any allergens, and, on our reading of Article 22 of the FIC Regulation, the percentage of coffee, since coffee appears in the name of the food (source 4, inferred). The word “natural” is regulated: “natural hazelnut flavor” requires that at least 95% of the flavoring part come from hazelnut (Article 16 of Regulation (EC) No 1334/2008, source 5).

    Any ingredient whose consumption was “negligible” in the Union before May 15, 1997 is a novel food, which can be sold only once authorized and entered on the Union list (Articles 3 and 6 of Regulation (EU) 2015/2283, source 6). Dried coffee cherry pulp has been one since Implementing Regulation (EU) 2022/47 of January 13, 2022, as a traditional food from a third country, with mandatory names, “coffee cherry pulp” or “cascara (coffee cherry pulp),” and the statement “high caffeine content” above 150 mg/L (source 7). Coffee leaf infusion has been one since Implementing Regulation (EU) 2020/917 of July 1, 2020 (source 8). “Mushroom coffees,” blended with chaga, cordyceps or trametes, are on the contrary unauthorized novel foods: the RASFF (the Union’s rapid alert system for food and feed) counts six notifications from 2020 to 2024, according to our sorting of the subjects (source 11).

    What this changes, and what is coming

    • Roaster: a decaf bought green must stay within 0.1% caffeine after roasting; a blend with chicory or cereals is called a substitute, not coffee.
    • Importer: cherry pulp has been sellable since 2022; any mushroom or extract added is checked against the novel food list.
    • Distributor: a flavored coffee carries a list of ingredients and its allergens.
    • Consumer: “decaffeinated” does not mean zero, and “pure arabica” refers to no legal threshold.

    As of October 21, 2026, the decree has not moved since 1997 and the directive since its consolidation of 2013; no revision proposal was sought beyond that. The only deadline that touches these products comes from elsewhere: coffee extracts come within the scope of the regulation against imported deforestation, the EUDR, on December 30, 2027 (source 13, section 8).

    Public cases

    Notifications, decisions and public investigations, each dated and sourced. None comes from a lived case.

    · DGCCRF, survey “Authenticity and quality of coffee”

    The National Investigation Service checks importers, roasters and resellers: 20 establishments, 32 visits, 21 samples, 8% “to watch.” One decaf exceeds 0.1 g / 100 g but becomes satisfactory again once the measurement uncertainty is taken into account. A green coffee importer who wanted to sell cherry pulp is warned: it is a novel food, not authorized at the time (source 10).

    What the case shows The parameters in the annex of Decree No. 91-340 are indeed measured, and cascara was not sellable before its authorization in 2022.

    · RASFF 2026.4883

    Belgium notifies an excessive caffeine content in a decaf coffee produced in Belgium, classified as a non-serious risk and forwarded for follow-up to the other Member States.

    What the case shows Decaf is a numerical promise, checked even when there is no danger to health.

    · FSVO (Switzerland), OPSON VIII: checking of coffee labeling

    The Swiss cantons sample 58 coffees labeled “100% arabica” from February 11 to 22, 2019, at large retailers and at artisanal roasters. Three exceed 50 mg/kg of 16-O-methylcafestol, including a capsule produced in Italy reported to the Italian authorities. None exceeds the ochratoxin A limit.

    What the case shows Without a legal definition, it is an analytical threshold set by the authority that makes a “100% arabica” a breach.

    · RASFF 2024.2141

    Lithuania reports a “mushroom coffee” from China containing unauthorized novel foods, including chaga and cordyceps.

    What the case shows An ingredient with no history of consumption in the Union requires prior authorization.

    Key points

    • In France, the word “café” is reserved for the product of roasting Coffea beans from which nothing has been removed; a blend with chicory or cereals is called a roasted substitute (Decree No. 91-340, Articles 3 and 7).
    • A decaffeinated roasted coffee sold in France holds at most 0.1% caffeine on dry product, measured on the roasted coffee: the decaffeinator’s analysis report, which covers the green coffee, does not exempt one from checking after roasting.
    • Roasted coffee stays under 1% foreign matter, 5% water and 6% ash, and the DGCCRF measures it.
    • “100% arabica” and “specialty” have no legal definition, but misleading is forbidden: keep the evidence for what you claim, invoices and analyses.
    • Mushrooms, extracts, pulp: any ingredient with no history of consumption before May 15, 1997 must be authorized before being put on sale.

    Gray areas

    What the law does not settle, or what could not be read.

    • “Pure arabica”: no 16-O-methylcafestol threshold in the Union; the 50 mg/kg one is Swiss, and the DGCCRF publishes neither a method nor a threshold.
    • Coffee roasted with sugar (torrefacto): the decree of 1991 does not mention it, the directive excludes only the soluble of this type; status unsettled in France.
    • “Artisanal” for a coffee: the regime for artisan status was not read.
    • The percentage of coffee in a flavored coffee is deduced from Article 22 of the FIC Regulation; no official guide confirms it.
    • Decree No. 2001-977 was not reread, Légifrance having raised an anti-robot check on October 21, 2026 (source 3); all we know is that it repealed Decree No. 81-104 on October 28, 2001.
    • The table of Regulation 2022/47, read as plain text, seems to list coffee and its blends among the categories into which the pulp may go; the name of such a blend in France is fixed by no text read.
    • Who controls a novel food since 2024: not found.

    Deadlines

    DateWhat changesSource
    Coffee extracts, essences and concentrates (CN 2101 11 00) come within the scope of Regulation (EU) 2023/1115 (EUDR).source 13

    The sources for this section

    1. 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 with its table · online · primary
    2. Directive 1999/4/EC of February 22, 1999, Articles 1 to 3 and annex, consolidated version of November 18, 2013 (CELEX 01999L0004-20131118) · online · primary
    3. Decree No. 2001-977 of October 26, 2001 (coffee and chicory extracts) · online · primary · not read directly
    4. Regulation (EU) No 1169/2011 (FIC), Articles 7, 17 and 22, consolidated version of April 1, 2025 · online · primary
    5. Regulation (EC) No 1334/2008, flavorings, Article 16 (original version; consolidation of February 16, 2026 not reopened) · online · primary
    6. Regulation (EU) 2015/2283, novel foods, Articles 3 and 6, consolidated version of March 27, 2021 · online · primary
    7. Implementing Regulation (EU) 2022/47 of January 13, 2022, dried coffee cherry pulp (OJ L 9 of January 14, 2022) · online · primary
    8. Implementing Regulation (EU) 2020/917 of July 1, 2020, coffee leaf infusion (OJ L 209 of July 2, 2020) · online · primary
    9. Directive 2009/32/EC, extraction solvents, Annex I, Parts I and II, consolidated version of February 16, 2023 · online · primary
    10. DGCCRF, “Authenticité et qualité du café,” April 24, 2018, archive capture of July 28, 2021 · online · primary
    11. RASFF Window, public API: notifications 2026.4883, 2020.4534, 2024.2141, 2024.2490 · online · data
    12. Federal Food Safety and Veterinary Office (FSVO, Switzerland), “OPSON VIII : Vérification de l’étiquetage du café,” June 2019 · online · primary
    13. Regulation (EU) 2023/1115 (EUDR), Annex I, consolidated version of September 18, 2026 · online · primary
    14. eCFR, Title 21, Part 163, “Cacao Products” (structure accessed on October 21, 2026) · online · primary
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