Why Instant Coffee Could Be Added to EUDR - and Implications for Industry

Why It Matters

Including instant coffee would close a major compliance loophole, ensuring all coffee products entering the EU meet deforestation standards and reinforcing the bloc’s sustainability agenda.

Key Takeaways

• Instant coffee excluded from EUDR due to likely oversight.
• Omission lets imports avoid deforestation due‑diligence checks.
• Adding it would trigger border scrutiny under same customs code.
• Brands could face higher compliance costs and supply‑chain adjustments.
• EU enforcement dates set for late 2026 and mid‑2027.

Pulse Analysis

The EU Deforestation Regulation was designed to curb forest loss linked to high‑risk commodities, covering everything from cocoa to timber. While coffee in its various forms—green beans, roasted, decaf, extracts—was explicitly listed, instant coffee slipped through, likely due to a coding error in the annex. This omission is not merely administrative; it creates a regulatory blind spot for a product that, despite its processed state, originates from the same beans and therefore shares the same deforestation risk profile.

From a supply‑chain perspective, the current customs code for instant coffee bypasses the EUDR’s due‑diligence requirements, allowing producers to import finished products without proving forest‑friendly sourcing. Multinational roasters could exploit this gap by sourcing beans from regions with lax forest governance, processing them abroad, and shipping the final instant mix into Europe. Should the Commission amend the annex, importers will need to implement traceability systems, potentially increasing costs, reshaping logistics, and prompting a reevaluation of sourcing contracts to meet the upcoming 2026‑2027 enforcement deadlines.

Industry reaction is mixed. Some firms view the amendment as a logical step toward uniform compliance across all coffee formats, while others warn of added operational burdens and label the regulation as a form of neocolonial oversight. The pending delegated act, slated for public consultation, signals the EU’s intent to tighten the loophole. If adopted, the move will reinforce the bloc’s credibility on global sustainability standards and could pressure non‑EU producers to adopt greener practices to retain market access.