Instant coffee falls under the EU deforestation rules in 2027

SABy Sander · September 26, 2026 · 3 min read

One line in the Official Journal put soluble coffee on the same list as the beans it is made from, a year later than the beans.

Instant coffee sat outside the European Union’s deforestation law for three years while the beans it is made from sat inside it. That changed on 17 September 2026, when the Official Journal carried one new line into the product list of Regulation (EU) 2023/1115, with effect from 30 December 2027.

One line, slotted in under the entry for beans

The annex names the goods that carry obligations, by customs heading rather than in plain words. Coffee has been there from the start as “0901 Coffee, whether or not roasted or decaffeinated; coffee husks and skins; coffee substitutes containing coffee in any proportion”. Commission Delegated Regulation (EU) 2026/2102, adopted on 13 July 2026, slides a second coffee heading in directly beneath it: “2101 11 00 Extracts, essences, and concentrates of coffee”. In force since 18 September 2026, the day after publication.

Why soluble coffee was left out in the first place

Recital 6 is unusually blunt about the gap. It describes the product as coffee made from brewed beans, dried into a powder or granules, and notes that while roasted or green coffee beans are inside the product scope, the powder is not, “despite its contribution to deforestation and forest degradation”. Leaving it out, the text says, “creates a fragmented and incoherent approach for the coffee sector” and “may result in the relocation rather than the elimination of the deforestation risk”. Relocation is the pointed word: a risk that moves is not a risk removed, which is easier to see now that the coffee supply chain has been mapped in public.

Folk art illustration of a sack of green coffee beans and a jar of soluble coffee granules enclosed by one dotted outline in front of a row of trees

Three dates, one shelf

The timetable underneath is three dates, not one. Regulation (EU) 2025/2650, agreed on 19 December 2025, moved the main obligations to 30 December 2026: Articles 3 to 13, 16 to 24 and 26, 31 and 32, which is where the due diligence sits. Natural persons and micro and small undertakings established as such by 31 December 2024 get until 30 June 2027. The jar of granules gets a third date, a full year behind the beans on the same shelf.

What else moved in the same act

Coffee was not the only line edited. Three entries for cattle hides, skins and leather, ex 4101, ex 4104 and ex 4107, are struck out. Frozen cattle tongues, ex 0206 21 00, are added on that same 30 December 2027 timetable, because fresh tongues were already covered. The two live cattle headings, 0102 21 and 0102 29, collapse into a single ex 0102. Leather is not gone for good: recital 2 puts it back on the table for the general review in 2030. Whether the crops behind these lists hold up as the climate shifts is another question, and a recent review of robusta took that one apart.

Folk art illustration of a coffee branch, a cocoa pod, a palm frond and a cow in four framed panels, the commodities named by the EU deforestation rules

What the whole list rests on

Seven commodities carry the regulation: cattle, cocoa, coffee, oil palm, rubber, soya and wood. Everything on the product list derives from one of them. The definition doing the heavy lifting sits in Article 2, where a forest is land spanning more than 0.5 hectares with trees higher than 5 metres and a canopy cover of more than 10 percent. Agricultural plantations are excluded from it. What counts as deforestation-free coffee is settled by that threshold rather than by anything printed on a jar.

Coffee imports into the bloc now split across two customs headings and two dates. Find the two coffee lines one under the other and the gap between beans and granules reads as one year: 30 December 2026 against 30 December 2027.