THE PROCESS IN MOTION

Who bears the ochratoxin risk, from the dock to the pack?

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

▶ Play the process01The dock02Pesticides03Ochratoxin04The roaster05The pack

The dock

A bag of green coffee arrives at the port. Three doors await it before the pack. For now, it is only an agricultural product: the law sets limits for it only for pesticide residues. Coffee contaminants arise elsewhere, ochratoxin A at drying and storage, acrylamide and furan in the roaster.

Read the stages without animation

1. The dockA bag of green coffee arrives at the port. Three doors await it before the pack. For now, it is only an agricultural product: the law sets limits for it only for pesticide residues. Coffee contaminants arise elsewhere, ochratoxin A at drying and storage, acrylamide and furan in the roaster.
2. PesticidesAn inspector takes beans. The maximum residue limit, the MRL, targets the green bean, under code 0620000; failing a value specific to a substance, it is 0.01 mg/kg, and many are set at the limit of quantification: any measurable residue is already an exceedance. Here, nothing is found, the lot passes.
3. OchratoxinThe second door is wide open, unguarded, with a sign: no limit for green coffee. The regulation sets no maximum level of ochratoxin A for green coffee; as early as 2006, a line was reserved for it, with no value, and in 2022 cocoa, spices and dried fruits received their figure, not it. The defect born at drying enters with no legal check.
4. The roasterThe bag is poured, heated, cooled. A light cloud depicts the acrylamide that forms from asparagine and sugars. The law sets no limit for it but a benchmark level, 400 µg/kg for roasted coffee, which serves to check that the method works: critical roasting conditions, a register, at least one analysis per year, except for those who sell directly.
5. The packThe coffee comes out roasted, in a pack. A door closes behind it, marked 3.0 µg/kg: the ochratoxin A limit targets the roasted coffee as placed on the market, therefore the roaster. The authority samples: for a lot of 15 tonnes or more, one hundred incremental samples of about 100 g, 10 kg. The lot is rejected only if the result, minus the uncertainty, exceeds the limit “beyond doubt.”

To remember: The ochratoxin A limit applies to roasted coffee as it is sold; green coffee has none, and it is by contract that one obtains an analysis certificate for the lot.

In history: In history: the 3.0 µg/kg limit comes from the regulation of August 5, 2022, applicable on January 1, 2023; it replaces the 5.0 µg/kg of 2006.

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.

Two origins, two regimes

Ochratoxin A (OTA in what follows) is a mycotoxin, that is, a toxin produced by microscopic fungi, here of the genera Aspergillus and Penicillium. The regulation that sets its limits says it in one sentence: it “forms during the sun drying and storage of agricultural products,” and good drying and storage practices make it possible to prevent it (source 3, recital 2). Acrylamide and furan, for their part, form in the heated bean, from asparagine and sugars for the former, and owe nothing to the country of origin (source 4, recital 3; source 5).

The law treats these two families in two ways. For OTA, it sets a maximum level: beyond it, the food may be neither placed on the market nor used as an ingredient (source 1, Article 2, paragraph 1). For acrylamide, it sets a benchmark level, which the regulation defines as a “performance indicator” used to check that the reduction measures work (source 4, Article 3): exceeding it obliges one to review one’s method, not to destroy one’s lot. For furan, it sets nothing, it asks for measurement. The texts themselves give the reasons for this gradation: OTA is prevented by drying; for acrylamide, the regulation admits that staying under the benchmark “may not be possible for all types of coffee” (source 4, Annex II, Part B, point 4); for furan, reliable analysis of certain methylfurans has yet to be developed (source 5, recital 3).

Ochratoxin A: a limit on roasted coffee, none on green

Regulation (EU) 2023/915, in its version consolidated as of August 19, 2026, sets 3.0 µg/kg (micrograms per kilo, that is, three millionths of a gram in a kilo of coffee) in roasted beans and roasted ground coffee, and 5.0 µg/kg in instant coffee (source 1, Annex I, points 1.2.14 and 1.2.15). These values do not date from 2023: they come from Regulation (EU) 2022/1370 of August 5, 2022, applicable from January 1, 2023, which lowered the former limits of 5.0 and 10.0 µg/kg after the 2020 opinion of the European Food Safety Authority (EFSA), according to which, given its carcinogenic effects, the toxin “could pose a problem for the health of certain groups of consumers” (source 3, recital 3; source 2, annex, points 2.2.4 and 2.2.5). The 2023 regulation took them over while replacing the old text of 2006, and provides that a coffee lawfully placed on the market before January 1, 2023 could stay on the shelf until its best-before date (source 1, Article 10, paragraph 1, point (f)).

Green coffee, for its part, appears nowhere in the list. The absence is not an oversight. As early as 2006, the regulation of the time announced that the advisability of a limit for “green coffee” “will be studied,” and reserved in its annex a line without a value for green coffee, next to cocoa, spices and dried fruit (source 2, recital 24 and annex, point 2.2.11). In 2022, cocoa, spices and dried fruit received their figure; green coffee did not (source 3, recital 4). None of the texts read says why.

Three articles of the 2023 regulation weigh on the roastery. A compliant coffee may not be mixed with a coffee that exceeds the limit (source 1, Article 2, paragraph 2): a contaminated lot is not diluted in a sound lot. The limit applies to the coffee “as placed on the market” (Article 2, paragraph 3), that is, to the pack, not the sack. And no chemical decontamination is permitted (Article 4). The roaster is therefore legally responsible for a defect born in drying, at a producer it has sometimes never seen, on a raw material that, for its part, circulated freely.

Acrylamide: an obligation of method, not of result

Regulation (EU) 2017/2158, applicable since April 11, 2018 (source 4, Article 6), asks the roaster for three things for coffee (Annex I, Part V). To take into account, when composing its blends, that beans “of the Robusta type,” that is, of the species canephora, “tend to have higher acrylamide levels” than arabica. To determine the “critical roasting conditions” that limit its formation “while respecting the target aroma profile.” To build the control of these conditions into a prerequisite program of good manufacturing practice, and to consider asparaginase, an enzyme that destroys the precursor before heating, if it is effective.

To this is added a sampling and analysis program, with a record of the measures taken and of the results (Article 4, paragraphs 1, 2 and 4): at least one analysis per year for a product whose level is known and controlled, more if it risks exceeding the benchmark level (Annex III, Part III). Analysis may be replaced by measuring color or a cooking parameter, if a statistical correlation with acrylamide is proven (Annex III, point II.4), which opens the door to the roastery’s colorimeter. The results are kept available to the authority each year (Annex III, Part V).

The small roaster escapes almost all of this. The operator who sells at retail or delivers directly only to local retail applies Annex II, Part A (Article 2, paragraph 2), which speaks of French fries, bread and sandwiches but not of coffee, and is exempt from the analysis program (Article 4, paragraph 6). Only the outlets of a chain or a franchise must make sure that the coffee delivered to them stays under the benchmark level, the supplier justifying any deviations (Annex II, Part B, point 4).

Furan: monitor, with no threshold

Furan and methylfurans are volatile compounds formed by heating. EFSA concluded in 2017 that current exposure is a “source of concern for health,” and the Commission answered with a mere recommendation, on March 25, 2022: the States, “with the active participation” of operators, monitor these substances “in particular in coffee,” with a method whose limit of quantification does not exceed 20 µg/kg, and send their results to EFSA before June 30 of each year (source 5, recital 2 and points 1, 3 and 5). A recommendation creates no obligation for the roastery. This does not prevent an authority from acting: in January 2023, Poland raised an alert for “high” levels of furan in a roasted ground coffee from Germany (case 3).

Pesticides: this time the limit falls on the green coffee

For pesticide residues, it is the reverse: the maximum residue limit (MRL) targets the green bean, entered in the list of products under code 0620000, “coffee beans” (source 6, Annex I; source 7). Failing an MRL specific to a substance, the default value is 0.01 mg/kg (source 6, Article 18, paragraph 1, point (b)). It is forbidden to mix a non-compliant lot in order to dilute it (Article 19), and roasted coffee is judged on the MRL of the green, corrected for variations due to processing (Article 20). On October 21, 2026, the Commission’s database counted 667 MRLs in force for coffee beans, 314 of them at 0.05 mg/kg (source 7, counted in this pass, duplicates removed). Many are marked with an asterisk, which means the value is set at the limit of quantification: any measurable residue is already an exceedance.

Chlorpyrifos shows how the rule bites. The MRL of this insecticide was lowered in 2020 to the limit of quantification, so that any measurable residue is illegal. It is nonetheless found on coffees from several producing countries, and the Union’s rapid alert system for food and feed (the Rapid Alert System for Food and Feed, RASFF) counts ten reports on coffee since 2020, including three refusals of the same green coffee from Cameroon by Spain (case 2).

Who measures, and how

The operator first: it is up to the operator to make sure its foods comply with the law and to check it (source 8, Article 17, paragraph 1). In practice, the roaster requires from its supplier an OTA analysis certificate for each lot, or has the analysis done itself, because no text obliges the importer to do it on its behalf. The authority next, by sampling. Since April 1, 2024, Implementing Regulation (EU) 2023/2782 describes how it samples: for a coffee lot of 15 tonnes or more, divided into sublots, one hundred incremental samples of about 100 g form an aggregate sample of 10 kg; under 15 tonnes, from ten to one hundred incremental samples depending on weight; at least 1 kg at the retail stage (source 9, annex, Part G). The lot is rejected only if the result, reduced by the expanded measurement uncertainty, exceeds the limit “beyond reasonable doubt” (Part G.7). A published measurement of 3.3 ± 0.1 µg/kg on a ground coffee, in 2025, was thus classed as simple information and not as an alert (case 1), without the notification saying why.

The RASFF, created by Article 50 of Regulation (EC) No 178/2002, connects the authorities of the States, the Commission and EFSA: a State notifies a withdrawal, a recall or a border rejection there (source 8, Article 50, paragraph 3). Queried on October 21, 2026, its public portal gives 107 notifications whose subject contains “coffee,” from July 5, 2019 to October 20, 2026, 26 of them for OTA (source 10). None of these 26 targets a coffee described as green: all concern ground coffee, instant coffee, capsules or beans without further detail. The law and the controls say the same thing: the green passes, the pack is judged.

What has no limit yet: mineral oils

Mineral oil aromatic hydrocarbons (MOAH) have no maximum level in the 2023 regulation, version of August 19, 2026 (source 1). They nonetheless gave rise to four RASFF notifications on coffee in 2024 and two recalls in France, one of which states in so many words that there is “no regulation” and that it follows “the precautionary principle” (case 4; source 11). The absence of a figure is not an authorization: a dangerous food remains forbidden (source 8, Article 14).

The sources for this section

1. Regulation (EU) 2023/915 of April 25, 2023, maximum levels of contaminants, consolidated version of August 19, 2026 (CELEX 02023R0915-20260819), Articles 2, 4, 10 and Annex I, points 1.2.7, 1.2.14, 1.2.15, 5.1.2 · online · primary
2. Regulation (EC) No 1881/2006 of December 19, 2006 (repealed), original version, recital 24 and annex, points 2.2.4, 2.2.5, 2.2.11 · online · primary
3. Regulation (EU) 2022/1370 of August 5, 2022, ochratoxin A, recitals 2 to 4 and annex, point 2.2.8 · online · primary
4. Regulation (EU) 2017/2158 of November 20, 2017, acrylamide, Articles 1 to 6, Annex I Part V, Annex II Parts A and B, Annexes III and IV · online · primary
5. Recommendation (EU) 2022/495 of March 25, 2022, monitoring of furan and alkylfurans · online · primary
6. Regulation (EC) No 396/2005, pesticide MRLs, original version, Articles 18, 19 and 20 · online · primary
7. Commission pesticides database (DG SANTE), API v3.0, product 244, code 0620000 “Coffee beans,” queried on October 21, 2026; Regulation (EU) 2016/1785 (phosphine, recital 4 and annex) read in full, the other values read in the API · online · primary
8. Regulation (EC) No 178/2002, general principles of food law, consolidated version of January 1, 2026, Articles 14, 17 and 50 · online · primary
9. Implementing Regulation (EU) 2023/2782 of December 14, 2023, sampling and analysis of mycotoxins, Article 5 and annex, Part G · online · primary
10. RASFF Window, public search, subject “coffee,” 107 notifications from July 5, 2019 to October 20, 2026, queried on October 21, 2026 · online · primary
11. Rappel Conso, open dataset rappelconso-v2-gtin-trie, notices 2024-02-0162 and 2024-04-0013, queried on October 21, 2026 · online · primary
12. Directive 2009/32/EC, extraction solvents, consolidated version of February 16, 2023, Annex I, Part II · online · primary