Skip to content
PPXLROASTERS
PXL Roasters
  • History
    • Plate XXII · section 11 of 12

    Claims: what may be written about coffee, and what no longer may

    THE PROCESS IN MOTION

    What is left on a coffee pack when each word goes up against its text?

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

    The talkative pack

    A pack covered in words: “wakes you up,” “natural,” “carbon neutral,” “biodegradable,” “French coffee,” “artisanal.” Nothing is judged yet. Only the name of the food, the weight and the required origin are mandatory; everything else is a claim, a voluntary message, and the burden of proof lies with whoever writes it.

    Read the stages without animation
    1. The talkative packA pack covered in words: “wakes you up,” “natural,” “carbon neutral,” “biodegradable,” “French coffee,” “artisanal.” Nothing is judged yet. Only the name of the food, the weight and the required origin are mandatory; everything else is a claim, a voluntary message, and the burden of proof lies with whoever writes it.
    2. Health“Wakes you up” goes up against the Union list and falls. A health claim is forbidden unless it is authorized and entered on the list; the word “caffeine” does not appear in it, and the sixteen register entries that cite caffeine, coffee or its chlorogenic acids are all refused.
    3. The planet“Carbon neutral” falls before the 2024 European directive, which forbids asserting a neutral impact on the basis of offsetting. “Biodegradable” falls before Article L. 541-9-1 of the Environment Code, which forbids it on a product or packaging. In France, the transposition law has not been passed: two regimes overlap.
    4. The origin“French coffee” hesitates, then falls: “made in” asserts an origin, and that of the green coffee should follow. It becomes “roasted in Lyon on October 3,” which describes a step, like “packed in.” A line appears all the same: the origin of the green coffee, in the same field of vision.
    5. The honest pack“Natural” falls because all coffees in beans are: presenting as particular what all similar foods possess is misleading. “Artisanal” falls because the word is reserved for those with artisan status. What remains is the place, the roasting date and the origin of the green coffee, on an emptier pack.

    To remember: No health claim on caffeine is authorized; “roasted in [city] on [date]” is safe, “French coffee” requires giving the origin of the green coffee, and what can be proven fits on three lines.

    In history: In history: in 2021, the Advertising Ethics Jury still allowed a “carbon neutral” coffee; in 2025, it condemned a “more sustainable coffee.”

    Read the full article and its sources ↓

    State of the law as of October 21, 2026. The deadlines this section notes have already passed.

    Health, nature, origin, craft, planet: five families of words, five legal regimes. The most recent, that of environmental claims, was due to change on September 27, 2026 across the Union; in France, the law that transposes it has not been passed, and two regimes overlap in the meantime.

    A claim is everything one is not required to write

    Regulation (EC) 1924/2006 calls a claim “any message or representation, which is not mandatory,” images included, that states or suggests that a food has particular characteristics (Article 2) (source 1). Directive 2005/29/EC on unfair commercial practices, in its version amended by Directive (EU) 2024/825, likewise defines the environmental claim, “label, brand name, company name or product name” included (Article 2) (source 8). What is mandatory (name, origin when required, weight) follows its own text. What is voluntary must be provable, and the burden of proof lies with the one who writes.

    Health: nothing on caffeine

    A health claim, that is, any message that suggests a relationship between a food and health, is prohibited unless it is authorized and entered on the Union list (Article 10, paragraph 1) (source 1). A general message about well-being is allowed only if it accompanies an authorized specific claim (paragraph 3). The list is Regulation (EU) 432/2012, in its version consolidated on August 20, 2025: the word “caffeine” does not appear in it (source 2). The Union register, consulted on October 21, 2026, holds 262 authorized claims and 2,067 unauthorized ones; the sixteen entries that cite caffeine, coffee or its chlorogenic acids are all “not authorized,” from “Caffeine helps to increase alertness” (between 40 and 75 mg per serving) to fat-burning promises and the antioxidants of coffee (source 3).

    One nuance prevents writing “prohibited” without reservation. Regulation 432/2012 announces that the claims on which the Commission “has not yet ruled” are published separately and “may continue to be used” under Article 28, paragraphs 5 and 6, of Regulation 1924/2006, under the responsibility of the operator (source 2). If the favorable opinions of the European Food Safety Authority (EFSA) on alertness and concentration are on this waiting list, they remain usable on that basis; neither those opinions nor that list was read. For a roaster, the prudent course does not change: “wakes you up,” “boosts concentration,” “burns fat” have no registered authorization. “Rich in antioxidants” neither: the entry “Antioxidants in coffee” in the register is refused. The Directorate-General for Competition, Consumer Affairs and Fraud Control (DGCCRF) applied this to a coffee seller in 2018 (source 18), the Advertising Ethics Jury to a drink competing with coffee in 2026 (source 19).

    “Natural,” “free from,” “pure”: deception by the obvious

    “Natural” has a definition in only one place: flavoring. A “natural flavoring” may contain only natural flavoring preparations or substances (Article 16 of Regulation (EC) 1334/2008) (source 5). On a pure coffee, the word refers to nothing defined and falls under the general rule. That rule, Article 7 of Regulation 1169/2011, known as the FIC Regulation (food information to consumers), forbids suggesting that a food has a particular characteristic “when in fact all similar foods have such characteristics,” notably through the presence or absence of an ingredient (paragraph 1, point (c)) (source 4). “Gluten-free,” “no added sugar,” “100% natural” on a coffee in beans tell the truth and mislead all the same, because all coffees in beans are like that. Directive 2024/825 added a neighboring rule to the list of prohibited practices: presenting as distinctive a requirement imposed by law on all products of the category (Annex I, point 10a, of Directive 2005/29/EC) (source 8).

    “Roasted in France”: true, permitted, and not an origin

    Customs law gives roasted coffee the origin of the country of roasting (section 6 of this plate). Label law does not follow. The Commission Notice published in the Official Journal of the Union on January 31, 2020 says that “made in” and “produced in” are understood as an indication of origin, that “packed in” is not, and that the rule covers a single-ingredient product when “its last substantial transformation was carried out in a place different” from that of the raw material (source 6). In that case, Implementing Regulation (EU) 2018/775 requires giving the origin of the green coffee, or stating that it does not come from France, in the same field of vision and in characters at least 75% of the height of the origin displayed (Article 3) (source 7). The Notice does not mention roasting. “Roasted in Lyon on October 3” describes a step, like “packed in”; “French coffee” or a tricolor flag asserts an origin. The first is safe, the second requires adding where the bean comes from.

    “Artisanal”: a quality, not a style

    The Craft Code reserves the word “artisan” “and its derivatives,” for the sign, promotion and advertising “of the product,” to artisans, art artisans, master artisans and companies whose manager has that status (Article L. 241-1, from Ordinance No. 2023-208 of March 28, 2023); Article L. 241-2 punishes use without the status with a criminal fine, and allows four months to bring oneself into compliance (source 14). A roaster not registered as an artisan, or an industrial brand, therefore cannot write “artisanal coffee.”

    The planet: two regimes at the same time

    The French regime has existed since the Climate and Resilience Law. Article L. 229-68 of the Environment Code, created by Article 12 of Law No. 2021-1104 of August 22, 2021, forbids claiming in an advertisement that a product is “carbon neutral” unless one makes public a report of direct and indirect emissions, a reduction trajectory and the terms of offsetting residual emissions (source 10). Decree No. 2022-539 of April 13, 2022, in force on January 1, 2023, specifies: a report over the whole life cycle according to standard NF EN ISO 14067, updated every year, a summary report online, a link or QR code on the packaging, withdrawal of the claim if emissions rise from one year to the next (Articles D. 229-106 to D. 229-109) (source 11). Since the law of February 10, 2020 against waste (Article 13), Article L. 541-9-1 also forbids “biodegradable” and “environmentally friendly” on a product or packaging; the Conseil d’État rejected the appeal against its implementing decree on May 31, 2024 (No. 464945) (source 12).

    The European regime is blunter. Directive 2024/825 adds to the blacklist of Directive 2005/29/EC, the list of practices prohibited in all circumstances, three bans that target coffee directly: a generic environmental claim (“eco-responsible,” “sustainable”) without “recognized excellent environmental performance” (point 4a); a claim about the whole product when it holds only for one aspect (point 4b); and the assertion, “on the basis of emissions offsetting,” that a product has a neutral, reduced or positive impact (point 4c) (source 8). It also forbids sustainability labels that rest neither on a certification nor on a public authority (point 2a), and regulates promises about the future (“neutral by 2030”), which require a plan verified by an independent expert (Article 6, paragraph 2, point (d)). Member States had to transpose before March 27, 2026 and apply from September 27, 2026 (Article 4) (source 9).

    France has not finished. The bill adapting French law to Union law, adopted by the Senate on February 18, 2026 (text No. 63), sent to the National Assembly on February 20, had not been passed there as of October 21, 2026 (source 13). Its Article 20 copies the blacklist into the Consumer Code. Its Article 21 repeals the section of the Environment Code that contains Article L. 229-68 and rewrites the ban on “biodegradable”: the statement would become permitted if excellent environmental performance is demonstrated; these two articles would enter into force on September 27, 2026, a date already past. In the meantime, a directive that has not been transposed creates no obligation on a company (Court of Justice, Faccini Dori judgment of July 14, 1994, C-91/92, point 20) (source 15): French law in force remains L. 229-68 and the general ban on misleading practices, which the judge reads in light of the directive.

    Statement on a coffeeText that governs itStatus as of October 21, 2026
    “wakes you up,” “helps concentration”Regulation 1924/2006, Articles 10 and 13; list 432/2012no caffeine claim authorized
    “gluten-free” on a pure coffeeRegulation 1169/2011, Article 7, paragraph 1, point (c)misleading: all coffees are
    “roasted in [city]”Notice 2020/C 32/01; Regulation 2018/775permitted; “French coffee” requires the origin of the green coffee
    “artisanal”Craft Code, L. 241-1 and L. 241-2reserved to those with artisan status
    “carbon neutral”L. 229-68 and Decree 2022-539; Directive 2024/825, point 4cpermitted in France under conditions; forbidden by the directive if based on offsetting
    “biodegradable”L. 541-9-1 of the Environment Codeforbidden on the product and the packaging
    “sustainable,” “eco-responsible”Directive 2024/825, point 4a; “Sustainable Development” recommendation of the Professional Advertising Regulation Authority (ARPP)to justify or withdraw

    What remains is self-regulation. The ARPP writes recommendations; the Advertising Ethics Jury (JDP), which anyone may refer a matter to, issues public opinions with no sanction other than the publicity of the opinion. Its opinions on coffee show the line moving, from carbon neutrality accepted in 2021 to “more sustainable coffee” condemned in 2025 (sources 16 and 17).

    Public cases

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

    · DGCCRF, “Authenticity and quality of coffee” survey (source 18)

    The Directorate-General for Competition, Consumer Affairs and Fraud Control (DGCCRF) finds a website that attributed to coffee slimming effects, migraine relief and prevention of Alzheimer’s and Parkinson’s diseases. After a pre-injunction letter, the professional brings itself into compliance with Regulation 1924/2006.

    What the case shows A health promise about coffee does not need to be false to be forbidden: it is enough that it is not authorized.

    · JDP, opinion No. 758/21, complaint unfounded, review rejected (source 16)

    A LinkedIn post by a maker of capsule coffees for professionals claimed that its coffees consumed in France were “carbon neutral” thanks to trees planted on farms. The Jury finds that the “Sustainable Development” recommendation does not proscribe the wording if it is explained, and recalls that it is “not for it to anticipate” the Climate law then under discussion. The Reviewer rejects the request for review.

    What the case shows What passed in 2021 now falls under point 4c of Directive 2024/825, since the neutrality rests on offsetting.

    · JDP, opinion No. 1089/25, Relay, complaint well founded (source 17)

    Point-of-sale posters announced a “More sustainable coffee” and an espresso “made from more sustainable coffee beans,” without saying in what way. The Jury finds the claim unexplained and recalls that an unqualified “sustainable coffee” cannot be justified “given the ecological impact of coffee growing.” The advertiser had not responded.

    What the case shows The retailer answers for its own posters: a vague word on the cup binds whoever prints it.

    · JDP, opinion No. 1136/26, complaint well founded (source 19)

    A mushroom drink sold as an “alternative to coffee” was presented in a video as relieving fibromyalgia, digestion and memory, “not the palpitations you can get with coffee.” The Jury finds it contrary to Regulation 1924/2006 and to the code of the International Chamber of Commerce, and notes that this is the same advertiser’s second advertisement in seven months.

    What the case shows Products sold against coffee often play on health, and the text is the same for them.

    Key points

    • No health claim on caffeine or coffee is entered in the Union register: “wakes you up,” “concentration,” “burns fat” are to be removed from a bag as from a website.
    • “Roasted in [city] on [date]” is safe; “French coffee” or a flag requires giving the origin of the green coffee in the same field of vision.
    • “Artisanal” is permitted only to those with artisan status within the meaning of the Craft Code.
    • “Carbon neutral” based on offsetting is forbidden by Directive 2024/825; in France, as long as the law is not passed, it remains subject to the heavy conditions of the 2022 decree: the simplest is not to write it.
    • “Sustainable,” “eco-responsible,” “environmentally friendly”: without proof of recognized performance, withdraw; “biodegradable” is forbidden on packaging in France.

    Gray areas

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

    • The list of “pending” health claims (Article 28, paragraphs 5 and 6, of Regulation 1924/2006) was not read: we do not know whether the EFSA opinions on caffeine and alertness, which the trade press dates to 2011 and which were not reread, are still on it, nor what tolerance the DGCCRF applies to them.
    • French transposition of Directive 2024/825: bill adopted by the Senate on February 18, 2026, at first reading in the Assembly as of October 21, 2026; the final text, its date and the fate of Article L. 229-68 remain unknown. A formal notice letter from the Commission to France of May 28, 2026, cited by the press, was not read.
    • “Roasted in”: the 2020 Notice does not name roasting; the equation with “packed in” is a reading by this section, which section 3 of the plate shares.
    • The French texts on carbon neutrality were read through the Légifrance summary, not in full text; Decree No. 2022-538 on penalties was not opened.
    • The foreign opinions cited by the plan (the UK Advertising Standards Authority on “compostable” capsules, the Competition Bureau of Canada on “recyclable” capsules) and JDP opinion No. 976/23, attributed by the plan to a poster at a Relay point, were not found in the sources read: they are not included.

    Deadlines

    DateWhat changesSource
    Application of Directive (EU) 2024/825 by the Member States (date passed; French transposition not adopted as of October 21, 2026).source 9

    The sources for this section

    1. Regulation (EC) 1924/2006, nutrition and health claims, version consolidated on December 13, 2014, Articles 2, 10, 13 and 28 · online · primary
    2. Regulation (EU) 432/2012, list of authorized health claims, version consolidated on August 20, 2025, recitals and annex · online · primary
    3. Commission, Union register of nutrition and health claims (Food and Feed Information portal), accessed October 21, 2026 · online · primary
    4. Regulation (EU) 1169/2011 (FIC), version consolidated on April 1, 2025, Article 7 · online · primary
    5. Regulation (EC) 1334/2008, flavorings, Article 16 · online · primary
    6. Commission Notice on the application of Article 26, paragraph 3, of Regulation 1169/2011, OJ C 32 of 31.1.2020, p. 1 · online · primary
    7. Implementing Regulation (EU) 2018/775 of May 28, 2018, Articles 1 to 3, applicable on April 1, 2020 · online · primary
    8. Directive 2005/29/EC, unfair commercial practices, version consolidated on September 27, 2026, Article 2, Article 6, paragraph 2, Annex I, points 2a and 4a to 4c · online · primary
    9. Directive (EU) 2024/825 of February 28, 2024, Article 4 (transposition by March 27, 2026, application on September 27, 2026) · online · primary
    10. Law No. 2021-1104 of August 22, 2021, Article 12 (Environment Code, L. 229-68 and L. 229-69) · online · primary · reading: summary
    11. Decree No. 2022-539 of April 13, 2022 on carbon offsetting and carbon neutrality claims in advertising (D. 229-106 to D. 229-109) · online · primary · reading: summary
    12. Conseil d’État, May 31, 2024, No. 464945 (L. 541-9-1 of the Environment Code, Decree No. 2022-748), Wayback capture of June 28, 2025 · online · primary
    13. Bill containing various provisions adapting French law to Union law, text No. 63 (2025-2026) adopted by the Senate on February 18, 2026, Articles 20 and 21; legislative files of the Senate and the National Assembly · online · primary
    14. Craft Code, Articles L. 241-1 and L. 241-2 (Ordinance No. 2023-208 of March 28, 2023), codes.droit.org compilation, edition of September 22, 2026 · online · primary
    15. Court of Justice, July 14, 1994, Faccini Dori, C-91/92, point 20 · online · primary
    16. Advertising Ethics Jury, opinion No. 758/21, published September 16, 2021, and Reviewer’s decision · online · primary
    17. Advertising Ethics Jury, opinion No. 1089/25, Relay, adopted November 14, 2025, published December 8, 2025 · online · primary
    18. DGCCRF, “Authenticité et qualité du café,” April 24, 2018, Wayback capture of July 28, 2021 · online · primary
    19. Advertising Ethics Jury, opinion No. 1136/26, adopted June 19, 2026, published July 20, 2026 · online · primary
    Elsewhere on the siteWhat we throw awayThe carbon footprint of a cupAnother page of the site that deals with it.Caffeine and instant coffeeHow to read a coffee studyAnother page of the site that deals with it.Caffeine and instant coffeeSleep, pregnancy, thresholdsAnother page of the site that deals with it.What we throw awayCapsulesAnother page of the site that deals with it.
    Previous sectionGeographical indications and brands: who owns the name of an origin, and who controls itNext sectionWhat changes in 2026-2027, and what is not known
    In this plateThe 12 sections
    1. 01The framework: who regulates what, step by step
    2. 02Names and composition: what may be called coffee
    3. 03The label, statement by statement
    4. 04Safety and contaminants: the thresholds, and who measures
    5. 05Hygiene, traceability, recall: what a workshop must do
    6. 06Importing: customs, origin, VAT, certificates, quarantine
    7. 07Packaging and waste: from the bag to the capsule
    8. 08Sustainability and due diligence: deforestation, reporting, vigilance
    9. 09Labels and certifications: the law and the contract
    10. 10Geographical indications and brands: who owns the name of an origin, and who controls it
    11. 11Claims: what may be written about coffee, and what no longer may
    12. 12What changes in 2026-2027, and what is not known

    The table of contents, with the first sentence of each section

    © 2026 Marco De Sousa Rosa · PXL RoastersTexts under CC BY-NC-SA 4.0 · tools: all rights reserved · images: see the provenanceHome · Colophon · Site map