Specialty green coffee traders, sourcing from 26 origins on behalf of over 1000 roasters.


Why does soluble coffee escape EUDR compliance regulations?
Regulatns Tabs

The Surprising Exclusion of Instant Coffee   

To date, our preparation for achieving compliance with EUDR has focused on the process and requirements for coffee’s initial entry into the EU. This has mainly included gathering the relevant, accurate geolocation data from each coffee farm that will need to be submitted with each coffee, proving that it is deforestation-free.

Yet, for many coffee businesses submitting EUDR documentation, this may be the first of many interactions they will have with EU customs during the shipping and processing of their green coffee within the EU. If your coffee enters the EU for the first time after 30th December 2024, it will receive a reference number, and this reference number must be included with the coffee at all onward stages of its transportation to prove that it continues to be deforestation-free1.

This rule will apply to green coffee, coffee that has been decaffeinated and roasted coffee. But in a surprising plot twist, soluble coffee (or as it’s commonly known, “instant” coffee) appears to be excluded. Given that Europe is the world’s largest consumer of instant coffee, with Perfect Daily Grind estimating its market share at 37%2, this is an interesting detail.   

Why the exclusion?   

The reason for exclusion is found in HS (Harmonized System) Codes. These codes standardise names and numbers for all products traded globally3. More than two hundred countries use the system to describe products entering or leaving their borders. The purpose is to accurately identify the content of shipments to charge the correct tariffs, determine quotas and inspection criteria, and more.   

Why is that important?  

A country can raise tariffs on an industry it wishes to protect against lower cost foreign imports. As an example, a country wishing to protect its green tea industry (heading 0902), it can do so without impacting import of herbal teas (1211). There’s no confusion because each carries a distinct number.

There are seven commodities impacted by EUDR and, for everything other than coffee, they list four or more HS headings, capturing the many transformations that a commodity can take as it’s turned into various goods. For wood, there are more than twenty headings listed for EUDR. Yet, for coffee? Just one.    

0901 Coffee, whether or not roasted or decaffeinated; coffee husks and skins; coffee substitutes containing coffee in any proportion”   

Here is the detail that enables soluble coffee to slip the fine print of EUDR: it’s traded under heading 2101, not 0901, therefore excluding it from the regulation.   

It will be very interesting to see how, if at all, this impacts coffee product availability and consumption in the EU in 2025 and beyond.