Labels and certifications: the law and the contract
What happens the day the organic auditor visits a roaster?
Start the scene or choose a stage. The animation simplifies the mechanism; what follows gives the details and the available references.
A list of ten certification bodies scrolls by, each with its FR-BIO code printed on the labels. The roaster chooses one, only one for its category, notifies its activity to the Agence Bio and signs the contract. Above, the French National Institute of Origin and Quality approves these bodies, the French Accreditation Committee accredits them: the inspector is private, but exercises a power delegated by the State.
Read the stages without animation
- The bodyA list of ten certification bodies scrolls by, each with its FR-BIO code printed on the labels. The roaster chooses one, only one for its category, notifies its activity to the Agence Bio and signs the contract. Above, the French National Institute of Origin and Quality approves these bodies, the French Accreditation Committee accredits them: the inspector is private, but exercises a power delegated by the State.
- The announced visitThe auditor arrives with a plan: the register of green coffee intake, the suppliers’ certificates, the roasting records, the labels. The auditor weighs a lot that has gone out and relates it to the bags that came in, roast loss included. The audit is first of all materials accounting, the tracking of quantities received, processed and shipped, lot by lot.
- SeparationThe auditor goes down to the roastery. The same roaster roasts organic and conventional: the auditor asks for proof of cleaning between the two and looks at where the bags are stored. The rule concerns physical separation or separation in time when both pass through the same premises, not different machines.
- The samplingA sample goes to the laboratory: the body takes samples from at least 5% of operators each year. Superimposed, an alert from the European rapid alert system: chlorpyrifos, an insecticide banned in the Union, found in an organic coffee from Peru in 2024. Organic guarantees controlled practices, not a bean free of residues.
- The other logosOn the counter, three other contracts: the license of Max Havelaar France, which validates each packaging and receives the sales declaration each quarter; the chain certificate of regenagri, valid for one year; the declaration to Rainforest Alliance of each transaction, within the two weeks following the quarter. Each private logo adds its auditor, its license and its register.
- UnannouncedA few months later, someone rings the bell without warning: at least one control in ten is done this way. The certificate, renewed after a full inspection, appears in TRACES, the Union’s IT system, with its end date: no later than March 31 of the second year that follows. The register must be right every day, not only on the announced day.
To remember: Roasting organic coffee makes the roastery a controlled operator: an approved body, one full inspection a year, spot checks and unannounced visits, a certificate in TRACES, and a register right every day.
In history: In history: the word “organic” is reserved by Regulation (EU) 2018/848, applicable since January 1, 2022.
Read the full article and its sources ↓State of the law as of October 21, 2026. 2 deadlines fall after this date; they are listed at the end of the section.
“Organic” is a Union law: a regulation, control bodies approved by the State, an electronic certificate for each operator and for each imported lot. Fairtrade, Rainforest Alliance, 4C, Demeter, Bird Friendly or regenagri are private brands: their owner writes the rule, a body it approves audits, and a license agreement says who may print the logo. A roaster that displays several therefore signs as many contracts and receives as many auditors, and since September 27, 2026 European law forbids any sustainability label that does not rest on independent verification.
One law, many contracts
For organic, the word is reserved by a regulation: using it without a certificate is an offense, and the control is public or delegated by the State. For the other signs, the owner of a brand sets a specification, approves its auditors and grants its logo by contract; a breach costs the license and, if the logo misleads, falls under misleading commercial practices. Minimum prices, premiums and certification costs are not here: they live in the signed and dated viewpoints.
| sign | standard and owner | who authorizes use, by what act | who controls | frequency | text or standard |
|---|---|---|---|---|---|
| EU organic, the word “organic” | Regulation 2018/848, Union legislator | the law, subject to the certificate of Article 35 | body approved by the INAO, accredited to ISO 17065, chosen by the operator; border post for imported lots | at least once a year; 10% without notice; in France, processors and importers: a full inspection and spot checks | 2018/848, Art. 34, 35, 38, 40; 2021/279, Art. 7; INAO-DEC-CONT-AB-4 |
| AB logo | national brand, usage rules not reread | same certificate as EU organic | the same body | the same | 2018/848, Art. 33, para. 5 |
| Fairtrade, Max Havelaar | Fairtrade International standards | license from Max Havelaar France for the mark; FLOCERT contract for whoever buys and sells | FLOCERT, accredited to ISO 17065 by DAkkS | trader: five-year cycle, up to four confirmation audits; producers: three years; unannounced | ISO 17065; Fairtrade standards |
| Rainforest Alliance | 2020 standard and chain requirements, Rainforest Alliance | Rainforest Alliance, seal rules not reread | approved bodies, accredited to ISO 17065 | three-year certificate, annual audit, surprise audits on 10% of holders | ISO 17065; traceability annex v1.4 |
| 4C | code of conduct, 4C Services GmbH | 4C, claim rules not reread | bodies approved by 4C; 4C integrity audits | three-year cycle, surveillance at one and two years | 4C system rules |
| Demeter | biodynamic specification, Demeter International and Demeter France | Demeter France attestation | physical audit, unnamed body; prior organic certification | not verified | Demeter specification |
| Bird Friendly | shade criteria of the Smithsonian Migratory Bird Center | the center’s licenses and marks | body subcontracted by the center; prior organic certification | one inspection per year | Bird Friendly standards |
| C.A.F.E. Practices | Starbucks standard, v4.3 | no consumer logo presented | verifiers approved by SCS Global Services | not verified | C.A.F.E. Practices standard |
| Nespresso AAA | Nespresso purchasing program with Rainforest Alliance | Nespresso; combined AAA and Rainforest Alliance seal | program verifications; Rainforest Alliance bodies for the certified share | annual from 2003 to 2015, then not verified | AAA criteria; Rainforest Alliance standard |
| regenagri | farm standard v4.0 and chain standard, Regenagri CIC | Regenagri license; claim approved in writing by the certifier | bodies accredited to ISO 17065 and approved; Control Union | annual surveillance, three-year cycle; one-year chain certificate | ISO 17065; Regenagri standards |
| the word “équitable” | Law No. 2005-882, Art. 60 | reserved since 2023 to products under a recognized label | Plateforme RSE, recognition for three years, not implemented in 2023 | not applicable | law of August 2, 2005, Art. 60 |
| “house” logo | the seller | no one | no one | not applicable | banned since September 27, 2026 (Directive 2024/825) |
The law: who writes, who approves, who controls organic
The word “organic” and its derivatives, “bio” or “eco” included, are reserved by Regulation (EU) 2018/848, applicable since January 1, 2022 (Article 61), read here in its version consolidated as of March 25, 2025: no more recent amending act was found in the Publications Office database on October 21, 2026 (sources 1, 34). Every operator that produces, prepares, stores, imports or places an organic product on the market notifies its activity and submits to the control of a body, from which it receives a certificate (Articles 34 and 35). A roaster that roasts and bags organic coffee is a controlled operator; only the retailer that resells prepackaged organic without preparing it, storing it anywhere but in the shop or importing it is exempt (Article 34, paragraph 2). For loose sales, a State may exempt the seller to the consumer from a certificate under several ceilings, including 5,000 kg of sales per year (Article 35, paragraph 8); France’s choice was not found. Loose sales are precisely the weak link, as the recall of September 2024 shows (see the cases).
This control is official within the meaning of Regulation (EU) 2017/625, but the State may delegate it to private bodies that it audits “at least once a year” and that meet the standard for bodies certifying products, ISO/IEC 17065 (Article 40, paragraphs 1 and 3). In France, the INAO, the French National Institute of Origin and Quality, the public body in charge of supervision, approves and evaluates these bodies (source 17); their accreditation, that is, the recognition of their competence and impartiality, is issued by COFRAC, the French Accreditation Committee, whose certificates refer to Regulation 2018/848 (source 18: Certis until December 31, 2030, Control Union Inspections France until January 31, 2030, Ocacia until October 31, 2029). The operator chooses its body (source 17), only one per product category in a given State (Article 35, paragraph 4).
The INAO list of August 6, 2024, the most recent found, names ten certification bodies approved for organic, each with the code number it prints on labels: Ecocert France (FR-BIO-01), Certipaq Bio (FR-BIO-09), Bureau Veritas Certification France (FR-BIO-10), Certisud (FR-BIO-12), Certis (FR-BIO-13), Bureau Alpes Contrôles (FR-BIO-15), Qualisud (FR-BIO-16), Control Union Inspections France (FR-BIO-19), Ocacia (FR-BIO-20) and Foodchain ID (FR-BIO-24); it indicates for each the approved categories, including the preparation of processed agricultural products intended for human consumption, the one that covers roasting (source 15). The format of the code is set by the regulation: “AB-CDE-999,” two letters for the country, three letters that say organic in the chosen language, a number assigned by the authority (Annex V, point 2, source 1).
A roaster’s path is written by the decision of the INAO director setting the common control provisions, in force since January 1, 2024 (source 16). It notifies its activity to the Agence Bio, signs a contract with a body, receives a commitment attestation stating that it cannot yet sell organic, then undergoes an initial on-site inspection before any certification decision. The certificate has been issued electronically in TRACES, the Union’s IT system for exchanges, since January 1, 2023 (Implementing Regulation (EU) 2021/2119, source 14); its validity may not go beyond March 31 of the second year following the last full inspection, and it is renewed only after such an inspection (source 16). Every operator must also check its suppliers’ certificates (Article 35, paragraph 6), which the Agence Bio public directory makes possible.
How often organic is checked
The regulation sets a floor: every certified operator undergoes a compliance check “at least once a year,” with a physical on-site inspection; the interval may go up to twenty-four months only if three years of controls have revealed no breach and the risk is judged low (Article 38, paragraph 3). The rest depends on risk: type and size of the operator, seniority, past results, possible mixing of organic and conventional, subcontracting (paragraph 2). Implementing Regulation (EU) 2021/279 quantifies each body’s annual minimums: at least 10% of controls carried out without notice, at least 10% additional controls, samples taken from at least 5% of operators (Article 7, source 12).
The INAO decision translates these minimums by category. A processor, a category that includes the roastery, receives one full on-site inspection a year, and the body must carry out in the category a number of spot-check inspections equal to at least 100% of operators, that is, on average a second visit; same rule for importers; 50% for distributors, wholesalers of prepackaged goods, online sales or bulk retail; a secondary establishment of the same company that first receives imported products is inspected once a year. Unannounced controls make up 10% of the total (source 16). The inspector checks what Article 38 lists: precautionary measures, physical or time separation between organic and conventional when both pass through the same premises, cleaning, identification of lots at all times, and the records the operator must keep (Article 34, paragraph 5, and Article 38, paragraph 1, source 1).
Breaches are minor, major or critical; a critical breach, “serious, repeated, persistent or intentional,” entails suspension or withdrawal of certification; in between, the body may downgrade a lot out of the organic chain. A broken traceability is enough to trigger these measures, and a withdrawn certificate lapses (source 16).
What a pack of organic coffee prints
On the label of a prepackaged organic coffee appear the code number of the body of the last operator that prepared it and, with the Union logo, the origin of the raw materials: “Non-EU agriculture” for a coffee, or the name of the country if everything comes from the same one (Article 32); the code is placed in the same field of vision as the logo, the origin just under the code (Regulation 2021/279, Article 3, source 12). The star leaf is at least 9 mm high; it is optional for an imported product, and a national logo such as AB may be added to it (Article 33 and Annex V, source 1). In stores, the DGCCRF, the Directorate-General for Competition, Consumer Affairs and Fraud Control, checks the fairness of the statements; a coffee sold as organic that was not was recalled in 2024 (source 9), and organic does not guarantee the absence of residues (source 10, see the cases).
Imported organic: a certificate per lot
Almost all organic coffee comes from third countries, and import follows Article 45: the coffee complies with the regulation and all operators in the chain, exporter included, have been controlled by a body recognized by the Commission (Article 46), or it comes from a country recognized by a trade agreement (Article 47), or from a country recognized as equivalent under the old regulation of 2007 (Article 48) (source 1). For each shipment, the importer notifies arrival at the border control post or at the point of release for free circulation in TRACES; the certificate of inspection, bearing a qualified electronic seal and accompanied by supporting documents, is endorsed by the competent authority before release for free circulation, and its number appears in the customs declaration; a shipment divided under customs receives an extract of the certificate for each lot; on receipt, the first consignee fills in box 31, its declaration on the condition of the consignment (Regulations 2021/2306 and 2021/2307, source 2 and source 13). The frequency of physical checks of lots depends on the likelihood of non-compliance, assessed by the authority and never delegated to a private body (Article 40, paragraph 4(d)). For the roaster that buys from an importer, the practical step is simple: check that its supplier’s certificate covers the coffee, and keep the lot reference.
Since December 31, 2024, the bodies that certified in third countries under merely “equivalent” rules have lost their recognition (Article 57): an organic coffee from Peru or Ethiopia follows the Union’s rules, controlled by a body recognized under Article 46, which certifies the exporter under Implementing Regulation (EU) 2021/1378 (source 1).
The end of equivalence on December 31, 2026
There remains the route of countries recognized as equivalent. Article 48 says this recognition “ends on December 31, 2026” (source 1). It concerns the countries listed in Annex I to Implementing Regulation (EU) 2021/2325, including two notable coffee producers: Costa Rica, for products grown and processed on site, and India, for products grown on site; the others, such as the United States, Canada, Japan or Switzerland, count mainly for coffee roasted there and re-exported (source 3, version consolidated as of July 27, 2026). The Commission proposed on December 16, 2025 to extend this recognition to December 31, 2036 (COM(2025) 780, source 4). The Council adopted its negotiating mandate on May 11, 2026, keeping 2036; the trilogues, these three-way negotiations among Parliament, Council and Commission, were postponed to the autumn (source 5). As of October 21, 2026, no text is published: without it, an organic coffee from Costa Rica certified only under Costa Rican rules will no longer be able to enter as organic on January 1, 2027, and the importer is checking now under which route each supplier is certified. The same proposal draws the consequences of the Herbaria Kräuterparadies judgment of October 4, 2024 (C-240/23), which refuses the Union logo to a food from an equivalent country that does not respect a Union production rule (source 4 and source 6).
Fairtrade: FLOCERT audits, Max Havelaar France grants the mark
The standards are written by Fairtrade International. Certification is done by FLOCERT, a company based in Germany, accredited to ISO 17065 since 2007 by the German national accreditation body, the DAkkS, whose certificate runs until 2027; it is audited every year by the DAkkS and by Fairtrade International, which supervises it as an “independent assurance provider” (source 20). The cycle is not the same for everyone: a producer organization follows a three-year cycle, with up to two confirmation audits; a trader receives a temporary authorization to trade of nine months, then up to four confirmation audits over five years and a renewal in the fifth year; FLOCERT also carries out unannounced audits (source 19).
If it buys and sells Fairtrade coffee, the roaster signs a certification contract with FLOCERT. If it wants to print the mark, it becomes a “license holder” and signs a label use contract with Max Havelaar France: it submits for validation, product by product, the recipe, the packaging and the communication materials, declares its sales of labeled products every quarter and pays license fees; it sources only from certified operators, and in a labeled recipe, all ingredients that exist in Fairtrade must be Fairtrade and weigh at least 20% of the total (source 19). For coffee, the traceability rule is the strictest: “all Fairtrade coffee” is physically traceable, kept separate from non-Fairtrade coffee from field to pack, whereas mass balance, which allows mixing while compensating by volumes bought, is permitted only for cocoa, tea, fruit juices and sugar (source 21). The Minimum Prices and the Premium, revised on July 15, 2026 for contracts signed from December 1, 2026, do not appear on this page, which carries no price (source 7).
Rainforest Alliance, 4C: bodies approved by the owner
Rainforest Alliance writes its 2020 sustainable agriculture standard and its requirements for the supply chain; third-party certification bodies that it approves, all accredited to ISO 17065 and subject to its rules, audit the farms; each certificate is valid for three years, an audit every year checks that conformity and the improvement plan are maintained, and each body carries out surprise audits on 10% of the holders in its portfolio; a Rainforest Alliance team itself evaluates the bodies (source 22, page updated on November 27, 2023). The traceability annex in force since March 1, 2026, common to this standard and to the organization’s new regenerative agriculture standard, has three levels: identity preserved, segregation and mass balance; coffee is not on the list of products admitted to mass balance, and every transaction in certified product is declared in the traceability platform within two weeks after the end of the quarter (source 23).
4C, renamed in 2025 “Certification for Climate, Conservation and Communities,” is run by 4C Services GmbH, in Cologne; the organization’s timeline traces the common code for coffee back to 2004, mentions in 2016 the birth of Coffee Assurance Services, renamed 4C Services in 2022, and dates to 2020 its transformation into a “fully independent” third-party certification system (source 24). Certification bodies must be approved by 4C. A cycle lasts three years: initial audit during or before the harvest, surveillance audits one and two years later, recertification in the third year, and integrity audits conducted by 4C staff according to risk. Since version 5.0 of the system rules, chain certification is mandatory for intermediate buyers, who buy from the producer organization, and optional downstream, for final buyers, distributors and license holders (source 24).
Demeter and Bird Friendly: organic first
These two signs are layered on organic instead of replacing it. Demeter, the label of biodynamic agriculture carried in France by the Demeter France association in Colmar and worldwide by the Demeter International federation, requires a processed product to be already labeled organic, with at least 90% Demeter ingredients (66% by derogation); a physical audit takes place on the estate or at the company, “in parallel with or independently of the organic control,” then Demeter France studies the audit reports, recipes and labels and issues the attestation of conformity (source 25). Bird Friendly, owned by the Smithsonian Migratory Bird Center in Washington, requires prior organic certification and quantified shade criteria: a main canopy of at least 12 meters, an upper layer of native trees of at least 15 meters, a dominant species that does not exceed 60% of the shade trees, the rest spread over at least ten species; a body subcontracted by the center inspects once a year; mill, roaster and importer keep this coffee separate and keep records; the center grants licenses and marks and checks their use (source 26).
Buyer programs: C.A.F.E. Practices and AAA
Two signs often cited are not open labels but the purchasing programs of a single company. C.A.F.E. Practices has been, since 2004, the basis of Starbucks’ sourcing; its manager, SCS Global Services, describes it as a third-party verification program “of continuous improvement” rather than a single certification; SCS trains and approves the verification bodies that check suppliers; version 4 of the standard applies with a transition covering 2025 and 2026 (source 27). Nespresso’s AAA program, launched in 2003 and designed with Rainforest Alliance, relying in part on its standard, was subject to annual verifications with the TASQ tool from 2003 to 2015; the seal that has appeared on the sleeves since 2016-2017 combines AAA and Rainforest Alliance; in May 2021, more than 90% of volumes came from AAA farms and more than 40% from Rainforest Alliance certified farms (source 28): the guarantee verified by a third party is that of the certified share.
regenagri: regenerative agriculture under contract
regenagri certifies regenerative agriculture, that is, practices that seek to restore soil and biodiversity rather than merely limit damage. The standard belongs to Regenagri CIC, a community interest company under British law. Its assessment method measures biodiversity (conservation areas, grass strips), soil health (sampling, tillage, rotations), water (irrigation, wastewater), energy and carbon storage, and inputs, crop protection products and mineral fertilizers; soil analyses give the organic matter and organic carbon contents; the farm starts from a score and must improve every year within a three-year cycle, with plans to reduce synthetic fertilizers and pesticides. An appendix put online in July 2026 adds voluntary requirements specific to coffee, and the farm standard version 4.0 was put online in October 2026 (source 29).
The certification bodies are accredited to ISO 17065 and approved by Regenagri; they carry out annual surveillance, between twelve and fifteen months after the anniversary date, unannounced visits according to risk, and keep the files for six years (source 29). Control Union, an inspection and certification group, offers on its site the applications for farms, the traceability chain and the license (source 30); in November 2023, the trade press reported the certification of 5,500 hectares of a cooperative in the Brazilian Cerrado, audited by regenagri and certified by Control Union, for a coffee sold by illycaffè (source 31). Whoever buys, sells or processes a certified product must also be certified under the chain-of-custody standard, which knows only segregation, with at least 80% certified product and at most 20% mixing; the site certificate is valid for one year, and each sale carries a transaction certificate. To print the logo, a brand owner signs a license contract with Regenagri, and the claim is approved in writing by the certification body then reviewed every three years (source 29).
French official signs and the word “équitable” (fair)
No Label Rouge and no French geographical indication for coffee was found in the sources consulted; the INAO products database could not be queried directly (see the gray areas). French law does, however, regulate a word. Article 60 of Law No. 2005-882 of August 2, 2005, amended in 2014, 2019 and by the Climate and Resilience law of 2021, defines fair trade (commitment of at least three years, remunerative price, additional amount for collective projects) and reserves since January 1, 2023 the term “équitable,” in the name of the food, for products subject to guarantee systems or labels recognized for three years by the Plateforme RSE, the national platform for corporate social responsibility (source 32, law text reproduced by the sector federation). A bill registered on September 12, 2023 noted that this scheme was “still not implemented,” for lack of implementing decrees (source 33); its state in 2026 was not checked.
Since September 27, 2026: no more labels without verification
Directive (EU) 2024/825 of February 28, 2024 on the green transition forbids in all circumstances to “display a sustainability label which is not based on a certification scheme or not established by public authorities” (Annex I, point 2a), a certification scheme being open to all, accompanied by penalties and controlled by a third party independent of the owner and the seller (Article 2, point (r)); application on September 27, 2026 (Article 4, source 8). A pictogram invented by a brand, “committed coffee” or “direct trade” presented as a seal, with no public standard or outside control, is now banned; direct trade has neither a legal definition nor an audit. The French transposition was not confirmed in this pass. And a real label does not cover the discourse built around it: advertising is still judged by its self-regulation (source 11, see the cases).
The roaster who wants every logo
Putting the organic logo, Fairtrade and a third sign on one pack means running several systems in parallel: an organic certification body that visits at least once a year, sometimes without warning; FLOCERT if the roastery buys its own Fairtrade green, and the license from Max Havelaar France, with validation of each package and quarterly declaration of sales; for Rainforest Alliance, 4C or regenagri, a traceability chain certificate if the roastery owns and processes the coffee. The same body may hold several approvals, Control Union appearing for instance on the INAO organic list and among regenagri’s certifiers (source 15 and source 30): visits can be grouped, but each standard keeps its requirements and its report. The common thread is the lot register: each bag of green entered with its certificate, each roast tied back to its lots of origin, the roast loss justified, each sale linked to the purchases. Three vocabularies, traceability, physical traceability, transaction certificate, for one and the same materials accounting, that is, the tracking of quantities coming in, processed and going out.
Public cases
Notifications, decisions and public investigations, each dated and sourced. None comes from a lived case.
· Rappel Conso 2024-09-0043
Voluntary recall of an “organic Brazil coffee” in 1 kg bags, sold loose in organic stores throughout France between June 19 and September 4, 2024. Published reason: “the coffee marketed is not organic,” it is a conventional product. The notice specifies that there is no risk to the consumer; refund at the point of sale.
What the case shows A false organic claim is a matter of fairness, not safety: it is recalled all the same, and loose sales require that every link that repackages be controlled.
· RASFF 2024.4844 (and 2023.6874)
France notifies as an alert the detection of chlorpyrifos, an insecticide banned in the Union, in an organic coffee from Peru. On October 10, 2023, Germany had notified the same substance in an organic green coffee from Honduras.
What the case shows Organic guarantees a controlled mode of production, not the absence of residues; the residue limit applies to organic as to conventional.
· RASFF 2021.2684
France refuses at the border an organic green coffee from India containing ethylene oxide, an unauthorized substance. On August 25 and November 13, 2023, Finland refuses organic ground coffees from Kenya for excess ochratoxin A (RASFF 2023.5776 and 2023.7816); on August 28, 2024, Belgium alerts on aromatic mineral oils in an organic coffee from Peru (2024.6497).
What the case shows Organic control at the border concerns the product as much as the certificate: an organic lot is refused for the same contaminants as a conventional lot.
· JDP, opinion No. 783/21
The JDP, the Advertising Ethics Jury, the advertising self-regulation body, finds well founded the complaint of an individual against a poster for an organic coffee whose green was certified Rainforest Alliance: two hands holding the globe, the Amazon at the center. The slogan and the name of the range are accepted, but the visual, which suggests that drinking this coffee protects the planet, is judged disproportionate with regard to measures that merely mitigate impact (points 3 and 8 of the ARPP “Sustainable Development” recommendation, the Professional Advertising Regulation Authority). The opinion, adopted on October 8, 2021, does not name the brand.
What the case shows A real label does not cover the discourse built around it: certification guarantees a standard, not an image.
Key points
- Roasting and bagging organic coffee makes the roastery a controlled operator: notification to the Agence Bio, contract with a single body approved by the INAO, full inspection every year, spot-check inspections and unannounced visits, certificate in TRACES.
- An imported organic coffee travels with a certificate of inspection per lot, endorsed before release for free circulation; the recognition of equivalent countries, including Costa Rica and India, expires on December 31, 2026 unless the proposed extension to 2036 is adopted in time.
- Fairtrade rests on two contracts: certification by FLOCERT for whoever buys and sells, the license of Max Havelaar France for whoever prints the mark; Fairtrade coffee is always physically kept separate.
- Rainforest Alliance, 4C, regenagri, Demeter and Bird Friendly are contracts controlled by bodies that their owner approves; C.A.F.E. Practices and AAA are one company’s purchasing programs.
- Since September 27, 2026, a “house” sustainability logo with no public standard or third-party control is banned, and in France the word “équitable” is reserved by law for products under a recognized label.
Gray areas
What the law does not settle, or what could not be read.
- Fate of equivalence on January 1, 2027: proposal COM(2025) 780 was in trilogue on October 21, 2026; neither agreement nor publication found (Publications Office database and web search of October 21, 2026).
- List of organic bodies: the INAO version of August 6, 2024 is the most recent found; a 2025 or 2026 update was not looked for on the INAO site, and the database of official signs (Label Rouge, geographical indications) could not be queried for coffee.
- Not verified: the owner and usage rules of the AB mark (agencebio.org was returning 403), the French penalty texts for a false organic claim, France’s choice on loose sales (Article 35, paragraph 8), the French transposition of Directive 2024/825 and the 2026 state of recognition of fair-trade labels by the Plateforme RSE.
- Not verified: the frequency of C.A.F.E. Practices verifications (SCS manuals not downloadable, 403), the usage rules of the Rainforest Alliance and 4C logos, 4C traceability (segregation or mass balance), the bodies that control Demeter in France, the audit of Fairtrade license holders.
- regenagri: the Control Union page announcing a governance partnership with Solidaridad could not be read (503); the claim that Control Union is the only certifier is reported by a search engine, not verified.
Deadlines
| Date | What changes | Source |
|---|---|---|
| Ban on sustainability labels not based on a certification scheme nor established by a public authority (date passed). | source 8 | |
| New Fairtrade Minimum Prices and Premium for contracts signed from this date (values outside this plate). | source 7 | |
| End of recognition of equivalent third countries (Article 48 of Regulation 2018/848), unless the extension to December 31, 2036 is adopted. | source 1 |
The sources for this section
- Regulation (EU) 2018/848 of May 30, 2018, organic production, consolidated version of March 25, 2025 (the most recent as of October 21, 2026), Articles 30, 32 to 35, 38, 40, 45 to 48, 57, 61, Annex V · online · primary
- Delegated Regulation (EU) 2021/2306 of October 21, 2021, import controls and certificate of inspection, Article 5 and annex · online · primary
- Implementing Regulation (EU) 2021/2325 of December 16, 2021, recognized third countries, consolidated version of July 27, 2026, Annex I · online · primary
- Commission, proposal for a regulation amending Regulation 2018/848, COM(2025) 780 of December 16, 2025, procedure 2025/0417(COD) · online · primary
- Council of the European Union, documents ST 8972/26 of May 7, 2026 (negotiating mandate) and ST 10670/26 of June 17, 2026 (progress report) · online · primary
- Court of Justice of the European Union, Grand Chamber, October 4, 2024, Herbaria Kräuterparadies, C-240/23, operative part · online · primary
- Fairtrade International, coffee price announcement of July 30, 2026 (standards committee of July 15, 2026) · online · primary
- Directive (EU) 2024/825 of February 28, 2024, Article 2, points (q) and (r), Article 4, Annex I, point 2a · online · primary
- Rappel Conso, notice 2024-09-0043 of September 5, 2024, dataset rappelconso-v2-gtin-trie · online · public data · reading: yes (API)
- RASFF Window, notifications 2021.2684, 2023.5776, 2023.6874, 2023.7816, 2024.2490, 2024.4844, 2024.6497 (the seven whose title associates “coffee” with “organic” or “ecológico,” query of October 21, 2026) · online · public data · reading: yes (API)
- Advertising Ethics Jury, opinion No. 783/21, adopted October 8, 2021, published November 8, 2021 · online · primary
- Implementing Regulation (EU) 2021/279 of February 22, 2021, controls and traceability in organic production, Articles 3 (labeling) and 7 (minimum percentages) · online · primary · reading: yes (Publications Office)
- Implementing Regulation (EU) 2021/2307 of October 21, 2021, documents and notifications for the import of organic products, consolidated version of July 1, 2022 · online · primary · reading: yes (Publications Office)
- Implementing Regulation (EU) 2021/2119 of December 1, 2021, operators’ certificate and issuance in TRACES (applicable on January 1, 2023 for TRACES) · online · primary · reading: yes (Publications Office, recitals and provision on TRACES)
- INAO, “Liste des Organismes de contrôle agréés par l'INAO,” August 6, 2024, with the annex of approved categories in organic farming · online · primary · reading: yes (PDF extracted locally)
- INAO, decision INAO-DEC-CONT-AB-4 v5, “Dispositions de contrôle communes relatives à la certification selon le mode de production biologique,” December 14, 2021, revised December 19, 2023, application January 1, 2024, points 2, 3.1, 6 and 7 · online · primary · reading: yes (PDF extracted locally)
- INAO, brochure “Le contrôle des signes officiels” and page “Qu'est-ce qu'un organisme de contrôle ?” · online · primary
- COFRAC, accreditation certificates NF EN ISO/IEC 17065 No. 5-0659 rev. 4 (Certis), 5-0629 rev. 4 (Control Union Inspections France), 5-0063 rev. 20 (Ocacia), citing Regulation 2018/848 · online · primary · reading: yes (PDFs extracted locally)
- Max Havelaar France, pages “Obtenir la certification,” “Obtenir la labellisation” and “Comment fonctionne la certification Fairtrade” · online · primary (label owner) · reading: yes (WebFetch on October 21, 2026, undated pages)
- FLOCERT, “Accreditation and Data Governance” · online · primary (certifier)
- Fairtrade International, “Traceability in Fairtrade supply chains” · online · primary (label owner)
- Rainforest Alliance, “The Rainforest Alliance Assurance System: Supporting Due Diligence across the Supply Chain,” updated November 27, 2023 · online · primary (label owner) · reading: yes (Wayback capture of May 11, 2026, the site was returning 520)
- Rainforest Alliance, Traceability Annex, A-05-SRCL-B-CH, version 1.4, published September 8, 2025, in force March 1, 2026 · online · primary (label owner)
- 4C Services, pages “Our certification system,” “Our history” and home page · online · primary (label owner) · reading: yes (timeline read in the raw HTML)
- Demeter France, “La labellisation Demeter” · online · primary (label owner)
- Smithsonian Migratory Bird Center, “Bird Friendly” standards, certified organic shade grown coffee (accessible version in English) · online · primary (label owner) · reading: yes (PDF extracted locally)
- SCS Global Services, page “Starbucks C.A.F.E. Practices” (standard V4.3, transition 2025-2026) · online · primary (program manager) · reading: yes (raw HTML)
- Rainforest Alliance, “A greener future for coffee farmers: Nespresso AAA,” May 2021 · online · secondary (program partner) · reading: yes (PDF extracted locally)
- Regenagri CIC: Auditing and Certification Requirements v3.0, Chain of Custody Standard Food v3.0, Claims Requirements v2.0, Assessment Methodology v3.0, Standard Farms v4.0 (point 4.14.5), Appendix IX Voluntary requirements for Coffee v1.0, page “Standards and Procedures Documents” · online · primary (label owner) · reading: yes (PDFs extracted locally)
- Control Union, page “regenagri®” (farm forms, traceability chain, license) · online · primary (certifier) · reading: yes (Wayback capture of August 7, 2026, the site was returning 503)
- Tea & Coffee Trade Journal, “Expocacer acquires regenerative certification label,” November 8, 2023 · online · secondary (trade press)
- Law No. 2005-882 of August 2, 2005, Article 60, amended by Laws No. 2014-856, 2019-486 and 2021-1104, text reproduced by Commerce Équitable France, “Réglementation et labels du commerce équitable en France,” August 2021 · online · secondary (law text relayed) · reading: yes (PDF extracted locally; Légifrance not opened)
- Assemblée nationale, bill No. 1639 to secure claims referring to fair trade, registered September 12, 2023, explanatory statement · online · primary
- Publications Office, SPARQL endpoint of the Cellar: acts whose French title cites Regulation 2018/848 since January 2025 (no act amending the regulation itself) · online · public data · reading: yes (query of October 21, 2026)
In this plateThe 12 sections
- 01The framework: who regulates what, step by step
- 02Names and composition: what may be called coffee
- 03The label, statement by statement
- 04Safety and contaminants: the thresholds, and who measures
- 05Hygiene, traceability, recall: what a workshop must do
- 06Importing: customs, origin, VAT, certificates, quarantine
- 07Packaging and waste: from the bag to the capsule
- 08Sustainability and due diligence: deforestation, reporting, vigilance
- 09Labels and certifications: the law and the contract
- 10Geographical indications and brands: who owns the name of an origin, and who controls it
- 11Claims: what may be written about coffee, and what no longer may
- 12What changes in 2026-2027, and what is not known
The table of contents, with the first sentence of each section