THE PROCESS IN MOTION

What must a roasting workshop do, month by month, between now and 2028?

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

▶ Play the process01October 202602End of 202603January 202704Summer 202705202806The empty box

October 2026

A calendar, a red line at October 21, 2026: everything to the left is already law. Coffee law changes by dates of application, often far from the date of adoption. Bisphenol A took effect on July 20, packaging PFAS on August 12, the blacklist of environmental claims on September 27. From now on, the roastery rereads the environmental words on its bags and asks its packaging supplier for declarations free of PFAS and bisphenol A.

Read the stages without animation

1. October 2026A calendar, a red line at October 21, 2026: everything to the left is already law. Coffee law changes by dates of application, often far from the date of adoption. Bisphenol A took effect on July 20, packaging PFAS on August 12, the blacklist of environmental claims on September 27. From now on, the roastery rereads the environmental words on its bags and asks its packaging supplier for declarations free of PFAS and bisphenol A.
2. End of 2026On December 30, 2026, the European deforestation regulation, the EUDR, becomes applicable to operators, downstream operators and traders, excluding micro and small enterprises. For a roastery that buys its green coffee in Europe, the box fills with a number: the reference of its supplier’s declaration, copied onto the invoice, and the list of its suppliers and customers kept five years.
3. January 2027A bag of organic green coffee arrives with its inspection certificate; the stamp of the equivalent third country fades. The recognition of equivalent third countries for organic stops on December 31, 2026, unless extended, under discussion between the Parliament, the Council and the Commission. On January 1, 2027, the roastery checks that each imported lot carries a certificate issued by a recognized body.
4. Summer 2027On June 30, 2027, the EUDR applies to micro and small enterprises. A roastery that imports its own green coffee and remains a small enterprise receives the plot geolocation page in turn. Six months later, on December 30, 2027, coffee extracts, instant coffee, enter the regulation in turn.
5. 2028The bag changes label: a harmonized label for packaging materials is printed on the back. The packaging regulation sets it for August 12, 2028 at the earliest, or 24 months after the implementing act if later; yet that act, due on August 12, 2026, was not published as of October 21, 2026.
6. The empty boxA box stays gray, marked “French law on claims: date unknown.” The bill adapting French law to Union law, adopted by the Senate on February 18, 2026, would transpose Directive 2024/825; it was at first reading in the National Assembly as of October 21, 2026. What is not passed cannot be dated.

To remember: A date in a bill is not a legal date: the timeline keeps only published texts, and flags those that are waiting.

Read the full article and its sources ↓

State of the law as of October 21, 2026. 8 deadlines fall after that date; they are listed at the end of the section.

Why a timeline

Coffee law does not change all at once. It changes by dates of application, often far from the date of adoption: a regulation published in 2023 on deforestation applies at the end of 2026, a 2024 regulation on bisphenols leaves stocks until 2028, a 2025 regulation on packaging announces a label for 2028. In between, a roastery can believe itself compliant because it was last year. The timeline below takes up the deadlines written by each section of the plate, with the text that sets them; a past date stays when it has just changed the rule. The dates in sections 1 to 9 are those that their writers read in the texts; some were cross-checked by this section in the same acts (sources 1 to 6).

Two words are often confused. Entry into force is the day a text exists in law, generally twenty days after its publication; application is the day its obligations bite, sometimes years later. The deforestation regulation entered into force on June 29, 2023 and applies only on December 30, 2026; the regulation that registers Café Antigua, published on October 15, 2026, enters into force on November 4. The timeline gives application dates, those that change something in a roastery.

The timeline of deadlines

Three dates in the timeline were reread by this section in the acts themselves, in addition to their writers: December 30, 2026, June 30, 2027 and December 30, 2027 in the version of Regulation 2023/1115 consolidated on September 18, 2026 (source 1); August 12, 2026, February 12, 2028 and the formula “August 12, 2028 or 24 months” in Regulation 2025/40 (source 2); July 26, 2029 in the consolidated Directive 2024/1760 (source 3). The bisphenols (source 4), organic (source 5) and Directive 2024/825 (source 6) were verified in the same way. The residue limits come from the Commission pesticides database read by section 4; the dates in the timeline are those of their regulations, not the values, which this section does not give again.

What the timeline says, read as a whole

Three movements overlap in it. The first is proof: the EUDR asks coffee to prove where it grew, organic passes to recognized control bodies one by one, environmental claims may no longer be vague. The second is packaging, which concentrates the largest number of dates, because Regulation 2025/40 was written in stages and the bisphenols leave different deadlines depending on the object. The third is the name: a new GI every two or three years, a Spanish application in 2026, a Hawaiian law that raises its threshold. For a roastery, the dates that call for action before summer 2027 number four: check that the green coffee bought carries an EUDR due diligence statement reference (December 30, 2026, or June 30, 2027 if it imports itself and remains a small enterprise), ask the packaging supplier for declarations of conformity free of PFAS and bisphenol A, reread every environmental word on its bags and its site, and check the organic inspection certificate of each lot imported as of January 1, 2027.

What is under discussion and is not yet law

Four projects could move the timeline. The French law adapting to Union law, adopted by the Senate on February 18, 2026, would transpose Directive 2024/825, repeal the French carbon neutrality regime and soften the ban on “biodegradable”; it was at first reading in the National Assembly as of October 21, 2026 (source 7). The extension of organic equivalence for third countries beyond December 31, 2026 was under discussion between the Parliament, the Council and the Commission, according to section 9. The Commission proposed in September 2026 to take French Guiana out of the territorial scope of the EUDR, a proposal not adopted according to section 8. And the implementing act for the harmonized packaging label, due on August 12, 2026, was not published according to section 7, which may push back the 2028 deadline. In the GI register, two Indonesian coffees await their registration regulation and a coffee from the Canary Islands its publication (source 8).

What we do not know, and why

The gaps in the plate come from two causes, which must be told apart. Some are silences of the law: nothing sets a limit for ochratoxin A, the mold toxin that forms during drying, for green coffee, although limits exist for roasted and instant coffee; nothing sets a limit for furan or for aromatic mineral oils (MOAH); acrylamide remains at benchmark levels, with no binding threshold; “pure arabica,” “specialty,” “direct trade” have no definition; the declaration route for a roastery that handles only plant products is written nowhere; a blend of arabica and canephora is classified by no text as a product with one or two ingredients. Others are limits of access: Légifrance and the site of the Directorate-General for Competition, Consumer Affairs and Fraud Control (DGCCRF) block scripts, TARIC (the database of customs duties by country) and the GIview database of GIs protected by agreement did not respond, the grounds of two General Court judgments are not online in French, the price lists of laboratories and certifiers are not public. The first are facts about the law; the second are facts about this plate, to be filled in when the sources open.

There remain boundary questions, which only an inspector or a judge would settle: what the “local retail trade” is that exempts a small roaster from analyzing acrylamide when it also sells online; whether “roasted in France” counts as an indication of origin; whether a sample of green coffee sent free by an exporter falls within the EUDR; what becomes in France of the “carbon neutral” claim between the application of the directive and the vote of the law. On each, the plate says what the texts write and stops there.

The sources for this section

1. Regulation (EU) 2023/1115 (EUDR), version consolidated on September 18, 2026, Article 38 and Annex I · online · primary
2. Regulation (EU) 2025/40, packaging and packaging waste, Articles 5, 9, 12 and 71 · online · primary
3. Directive (EU) 2024/1760 (CSDDD), version consolidated on March 18, 2026, Article 37 · online · primary
4. Regulation (EU) 2024/3190 of December 19, 2024, bisphenols, transitional provisions · online · primary
5. Regulation (EU) 2018/848, organic production, version consolidated on March 25, 2025, Article 48 · online · primary
6. Directive (EU) 2024/825 of February 28, 2024, Article 4 · online · primary
7. Bill adapting to Union law, text No. 63 (2025-2026) adopted by the Senate on February 18, 2026; legislative files of the Senate (updated September 4, 2026) and the National Assembly, accessed October 21, 2026 · online · primary
8. eAmbrosia, Union register of geographical indications, accessed October 21, 2026; Implementing Regulation (EU) 2026/2301 · online · primary