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  • History
  • Plate XXII · section 03 of 12

    The label, statement by statement

    THE PROCESS IN MOTION

    What must a bag of coffee say, and what may it leave unsaid?

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

    The empty bag

    A bag of pure coffee, nothing on it. The European regulation on consumer information, known as the FIC Regulation, first sets the size of the letters: an x-height, that of a lowercase letter without a descender, of at least 1.2 mm, or 0.9 mm if the largest face measures less than 80 cm².

    Read the stages without animation
    1. The empty bagA bag of pure coffee, nothing on it. The European regulation on consumer information, known as the FIC Regulation, first sets the size of the letters: an x-height, that of a lowercase letter without a descender, of at least 1.2 mm, or 0.9 mm if the largest face measures less than 80 cm².
    2. The particulars“Ground coffee,” “250 g,” the best-before date, that is, the date of minimum durability, a lot number, a name and an address each take their place, each with its article. The name of the food and the net quantity fit in the same field of vision. The lot may be omitted if the best-before date carries the day and the month.
    3. The crossed-out boxesThe list of ingredients, the nutrition declaration and the caffeine warning try to appear and are struck out by their exemption: single-ingredient product, coffee beans exempted by Annex V, a drink named “coffee” excluded from the warning of Annex III.
    4. The weightThe pack goes on the scale. For 250 g, the law tolerates a shortfall of 9 g: a pack of 243 g is within the margin. No pack may be short by more than double, 18 g: a pack of 231 g is outside the law. And the average of the lot must reach the stated weight.
    5. The origin“Ethiopia” is written large. If the pack is a blend, an arrow asks: and the rest? A displayed origin that is not that of the primary ingredient, the one that makes up more than half, requires giving its own, in the same field of vision, in letters at least 75% the size of the displayed origin.

    To remember: A bag of pure coffee carries at most seven particulars; no ingredient list, no nutritional values, no caffeine warning, and a displayed origin calls for that of the bean.

    In history: In history: since October 11, 2012, no State may impose a pack size for coffee any longer; 250 g, 227 g or 340 g are free.

    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 European regulation on food information to consumers applies to coffee as to any food, with three exemptions that make it singular: no list of ingredients for a pure coffee, no nutrition declaration, no caffeine warning. And origin is mandatory only if its absence misleads.

    Three exemptions that make coffee a special case

    European Union (EU) Regulation No 1169/2011, known as the FIC Regulation (food information to consumers), has applied since December 13, 2014, and its nutrition declaration since December 13, 2016 (Article 55, source 1). The version read is the version consolidated as of April 1, 2025, the latest published as of October 21, 2026. Its Article 9 lists the mandatory particulars, and three of them fall away for pure coffee. The list of ingredients is not required for a single-ingredient product whose name is that of the ingredient (Article 19, paragraph 1, point (e)). Annex V, point 7, exempts from the nutrition declaration the extracts of Directive 1999/4/EC and “whole or ground coffee beans,” decaffeinated or not. Finally, Annex III, point 4.1, which requires “High caffeine content. Not recommended for children or pregnant or breast-feeding women” above 150 mg/L, excludes coffee-based beverages whose name includes the word “coffee.” An ordinary cup contains far more: the absence of a figure is a deliberate exemption, not an oversight.

    The list, particular by particular

    The table applies to a coffee in beans or ground, prepackaged, with no other ingredient. The date of minimum durability is the “best before” date, not to be confused with the use-by date of perishable products.

    ParticularFor a pure coffeeTextWhat to know
    NameYesFIC Art. 9 and 17; Decree No. 91-340The legal name: “coffee,” “ground coffee,” “decaffeinated coffee”
    Net quantityYesFIC Art. 9 and Annex IX; Decree No. 78-166In the same field of vision as the name
    Best-before date (DDM)YesFIC Art. 9 and Annex XPeriod chosen by the operator, none is set by law
    LotYes, with exceptionsDirective 2011/91/EU, Art. 2 to 5Not needed if the best-before date shows at least the day and month
    Name and address of the operatorYesFIC Art. 8 and 9Whoever’s name the coffee is sold under
    Storage conditionsIf necessaryFIC Art. 25After opening, “where appropriate”
    Country of originOnly if its absence misleadsFIC Art. 26; Regulation 2018/775See below
    Instructions for useIf their absence hinders useFIC Art. 9Rarely required for a coffee
    List of ingredientsNoFIC Art. 19Yes as soon as a flavoring or anything else is added
    AllergensNoFIC Art. 21 and Annex IICoffee is not an allergen on the list; an addition may be
    Nutrition declarationNoFIC Annex V, point 7Exemption specific to coffee and instant coffee
    Caffeine warningNoFIC Annex III, point 4.1Exemption for beverages named “coffee”

    A bag of pure coffee therefore carries five to seven useful particulars, not twelve. Decaf sometimes adds one: the statement required by the French decree when the waxy layer of the beans has been treated (Article 5 of Decree No. 91-340, source 12).

    Legible, grouped, in the right language

    The mandatory particulars appear on the packaging or on a label attached to it (Article 12). They are printed with an “x-height,” that is, the height of a lowercase letter without a descender, of at least 1.2 mm, reduced to 0.9 mm when the largest face of the packaging measures less than 80 cm² (Article 13). Below 10 cm², only the name, the allergens, the net quantity and the best-before date remain mandatory on the packaging (Article 16), which concerns certain pods sold individually. The particulars are written in a language “easily understood” by the consumers of the State of sale, which may impose its own (Article 15): in France, it is French, which Law No. 94-665 of August 4, 1994 also imposes, a text not reopened for this pass.

    The weight: what the law tolerates

    Since October 11, 2012, no Member State may impose coffee pack sizes: 250 g, 227 g or 340 g are free (Directive 2007/45/EC, Article 2, source 7). What remains regulated is the gap between the stated weight and the real weight. Directive 76/211/EEC, transposed by Decree No. 78-166 of January 31, 1978, lays down three rules: the average content of a lot may not be less than the stated weight; only a small proportion of packs may exceed the tolerated error; no pack marked with the lowercase “e” may fall short by more than double (sources 5 and 6).

    Stated quantityMaximum tolerable negative errorMinimum height of figures
    7 g pod9%, or 0.7 g2 mm
    125 g4.5%, or 5.7 g3 mm
    250 g9 g4 mm
    500 g15 g4 mm
    1 kg15 g4 mm

    The tolerated errors are those of the table in the directive consolidated as of July 26, 2019, which the decree takes up; the grams in the percentage lines are calculated and rounded up to the next tenth, as the text requires. The figure heights are those of the directive; the French ministerial order to which the decree refers was not opened. The “e,” at least 3 mm tall, is optional: it signals a packer who checks its lots by the European statistical method.

    The date and the lot

    A coffee does not carry a use-by date, reserved for foods that are highly perishable microbiologically, but a best-before date. Its form follows Annex X: the day and month suffice for a period of less than three months, the month and year between three and eighteen months, the year alone beyond. The period itself is set by no text: the operator chooses it and answers for it. The best-before date says nothing about aromatic freshness, which plays out over weeks (page on degassing). A “roast date” remains optional information, permitted provided it does not mislead (Article 36).

    The lot identifies packs made under practically identical circumstances. It is determined by the manufacturer or packer, preceded by the letter “L” unless it is clearly distinguishable from the other particulars (Directive 2011/91/EU, Article 3), and it may be omitted when the best-before date shows at least the day and month (Article 5, source 4). It is what makes it possible to recall a single lot rather than a whole stock.

    Origin: mandatory only when silence misleads

    Article 26, paragraph 2, of the FIC Regulation makes origin mandatory only if omitting it may mislead the consumer. Its paragraph 3, applied since April 1, 2020 through Implementing Regulation (EU) 2018/775, adds a finer rule: when an origin is shown for the product and it is not that of its “primary ingredient,” the one that makes up more than half of it, the origin of that ingredient must be stated or it must be said that it is different, in the same field of vision and in characters at least 75% of the x-height of the main indication (Articles 2 to 4, source 2). The regulation does not apply to protected geographical indications, GIs, or to registered trademarks that count as an indication of origin (Article 1).

    For coffee, the trap lies in roasting. It changes the customs origin of the product, which becomes that of the country where it is roasted (section 6). The Commission considers that the statements “made in” or “produced in” followed by a country indicate the origin of the product, and so does a visible flag or map (Notice 2020/C 32/01, points 2.4.1 and 2.4.5, source 3). It does not mention roasting, but a “roasted in France” reads, in our opinion, the same way, and calls for the origin of the green coffee.

    On the packEffectBasis
    “Coffee from Ethiopia,” 100% EthiopianExact origin, nothing to addFIC Art. 7 and 26
    “Ethiopia” in large type on a blend that contains 30% of itMisleadingFIC Art. 7, inferred
    “Roasted in France” on a Brazilian coffeeState the origin of the green coffee, or “non-EU” (outside the European Union)Regulation 2018/775; notice, point 2.4.1, inferred
    Roaster’s address in LyonNot an indication of originNotice, point 2.1.1
    Flag or map of a countryIndication of origin, in principleNotice, point 2.4.5
    “Italian style,” “recipe”Not in principle, unless the presentation is misleadingNotice, point 2.4.4
    Protected geographical indication (Café de Colombia)Outside Regulation 2018/775Regulation 2018/775, Art. 1

    Allergens, online sales, loose coffee

    Coffee is not on the list of the fourteen allergens in Annex II, but a syrup, a coating or a flavoring can bring in tree nuts, milk or soy. The allergen is then emphasized in the list of ingredients, or announced by “contains” when there is no list (Article 21). The statement “may contain traces” is governed by no implementing text: Article 36 provided for one, which was not found in this pass.

    For distance selling, all particulars except the best-before date must be legible before purchase, on the product page, and all of them on delivery (Article 14). For coffee sold non-prepacked, over the counter or loose, the Union imposes only the allergens and leaves the rest to the Member States (Article 44). France answered with Decree No. 2015-447 of April 17, 2015, in force since July 1, 2015: the name of the food and the allergen information appear on the food or close to it, with no uncertainty about the product concerned (source 8). The rules specific to loose sales fall under packaging (section 7).

    What this changes, and what is coming

    • Roaster: five to seven well-made particulars are enough for a pure coffee, but writing a country in large type on a blend, or “roasted in France” without the origin of the green, exposes one to Article 7.
    • Importer: nothing, unless it bags under its own name.
    • Online seller: the product page carries the particulars before the basket.
    • Consumer: the caffeine in a coffee is never quantified, by exemption.

    The latest consolidated version of the FIC Regulation dates from April 1, 2025, and the Publications Office’s Cellar knows of no more recent one on October 21, 2026. The label will nonetheless grow heavier through other texts: a harmonized packaging sorting label by August 12, 2028 at the latest (Article 12 of Regulation (EU) 2025/40, source 9, section 7), and environmental claims that Directive (EU) 2024/825 regulates, applied by the Member States since September 27, 2026 (section 11).

    Public cases

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

    · DGCCRF, survey “Authenticity and quality of coffee”

    Out of 21 samples, two packs weigh less than the stated weight, but remain within the tolerances of the decree on the metrological control of prepackages. They are classed “to watch,” with no legal proceedings (source 10).

    What the case shows The stated weight is not a minimum per pack: the law tolerates a bounded shortfall and checks the average of the lot.

    · RASFF 2022.1721

    Sweden raises an alert, classified serious, for fish, an undeclared allergen, in an instant coffee from Thailand (source 11).

    What the case shows A prepared coffee is no longer a single-ingredient product: its allergens must appear on the label.

    · RASFF 2026.0568

    Germany raises an alert for an allergen, tree nuts, unlabeled or mislabeled in a coffee syrup from the United States (source 11).

    What the case shows Products that accompany coffee carry the allergen risk that the bean does not.

    Key points

    • A bag of pure coffee carries at most seven particulars: name, net quantity in the same field of vision, best-before date, lot unless the best-before date gives the day and month, name and address, storage if necessary, origin if its silence would mislead.
    • No list of ingredients, no nutrition values, no caffeine warning for a pure coffee; as soon as it is flavored, the list and the allergens return.
    • A “roasted in France,” a flag or a map displays an origin: that of the green coffee must then follow, in the same field of vision.
    • The real weight may fall short by 9 g on a 250 g pack, but the average of the lot must reach the stated weight.
    • Online, all particulars except the best-before date must be visible before purchase.

    Gray areas

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

    • “Roasted in France” as an indication of origin: the Commission’s notice covers “made in” and “produced in,” not roasting; treating them alike is a reading made by this section.
    • Precautionary statements on allergen traces have no known implementing framework; the act provided for in Article 36 of the FIC Regulation was not found.
    • Decree No. 78-166 was read through a Légifrance summary, not in full text; the tolerated errors match the consolidated Directive 76/211/EEC, read in full. The ministerial order that sets figure height in France was not opened.
    • Decree No. 2015-447 was read in the Journal officiel of April 19, 2015, in its numbering of the time (Articles R. 112-10 to R. 112-15 of the Consumer Code); its current numbering after the recodification was not checked.
    • Is a blend of arabica and canephora a product with one ingredient or two? No text or guide read settles it, which leaves open the question of the percentage of arabica when the label puts it forward.

    Deadlines

    DateWhat changesSource
    Harmonized sorting label on coffee packaging, or 24 months after the implementing act if that date is later (Article 12 of Regulation (EU) 2025/40).source 9

    The sources for this section

    1. Regulation (EU) No 1169/2011 (FIC), Articles 2, 7 to 9, 12 to 17, 19, 21, 22, 25, 26, 36, 44 and 55, Annexes II, III, V, IX and X, consolidated version of April 1, 2025 (CELEX 02011R1169-20250401) · online · primary
    2. Implementing Regulation (EU) 2018/775 of May 28, 2018, primary ingredient, Articles 1 to 4 · online · primary
    3. Commission Notice on the application of Article 26, paragraph 3, of Regulation (EU) No 1169/2011 (2020/C 32/01), OJ C 32 of January 31, 2020 · online · primary
    4. Directive 2011/91/EU of December 13, 2011, lot identification, Articles 1 to 5 · online · primary
    5. Directive 76/211/EEC, prepackages, Annex I, points 2.4 and 3, consolidated version of July 26, 2019 · online · primary
    6. Decree No. 78-166 of January 31, 1978, metrological control of prepackages, Articles 4 to 8 · online · primary · reading: summary
    7. Directive 2007/45/EC of September 5, 2007, nominal quantities, Article 2 · online · primary
    8. Decree No. 2015-447 of April 17, 2015, allergens and non-prepacked foods, JORF of April 19, 2015 (FAOLEX copy) · online · primary
    9. Regulation (EU) 2025/40, packaging, Article 12 · 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 2022.1721 and 2026.0568 · online · data
    12. Decree No. 91-340 of April 3, 1991, Article 5, version in force on October 21, 2026, read on screen · online · primary
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