Instant coffee and coffee extracts are no longer exempt from the European Union Deforestation Regulations.
The European Commission has closed a long-standing gap in its flagship deforestation law. On July 13, the commission adopted two measures to support the implementation of the EU Deforestation Regulation (EUDR), including the formal addition of soluble coffee to the list of products covered by the law. For an industry segment that has largely operated outside deforestation-due-diligence requirements until now, this is a significant shift in compliance obligations.
The Soluble Loophole
Instant (or soluble) coffee, made by dehydrating brewed coffee beans into a powder or crystals, had escaped scrutiny for unclear reasons even though green, roasted, and decaffeinated coffee were already covered by the EUDR. The new Delegated Act updates Annex I of the regulation and specifically adds the customs code CN 2101 11 00, which covers coffee extracts, essences, and concentrates. According to legal analysis by Bird & Bird, this broader classification means that liquid coffee concentrates, coffee flavoring agents, coffee and espresso powders used in the food industry, and syrups and pastes now fall within the scope as well.
Why Brussels Decided the Gap Wasn't Grounds for Exemption
The commission's own delegated act explains the reasoning bluntly. The exclusion of soluble coffee from the scope of Regulation (EU) 2023/1115 created a fragmented and incoherent approach for the coffee sector, since soluble coffee could be placed on or exported from the Union market without complying with the regulation's obligations, risking the relocation rather than elimination of deforestation pressure. The European Coffee Federation had pushed for this change, arguing that soluble coffee is produced directly from green coffee, which is already covered by the EUDR, and that consistent treatment within the same product category would create a more level playing field.
A Robusta Reckoning
The timing matters for sourcing strategy. Soluble coffee is typically produced from robusta coffee, which has been associated with increased deforestation linked to full-sun monocrop cultivation. That link places instant coffee manufacturers, and the robusta supply chains feeding them, squarely in the spotlight. Companies will now need to prove geolocation traceability back to the farm plots where that robusta was grown, not just for the green beans but for every downstream extract or concentrate.
The Blend Complicates the Bill
Soluble coffee production typically relies on mass-balance blending, mixing beans from multiple origins to achieve a consistent flavor profile. Under the EUDR, every component of that blend must be individually verified as deforestation-free, which complicates traceability for large-scale instant coffee plants that have historically sourced opportunistically across markets. Roasters and manufacturers accustomed to flexible blending will need origin-level documentation for each batch going forward.
The Clock Coffee Companies Can't Ignore
Micro and small companies already covered under the old Timber Regulation must meet the EUDR obligations for timber products by December 30, 2026, the same date as larger operators. For most core coffee operators, the applicable deadlines remain December 30, 2026, for large and medium operators, and June 30, 2027, for most micro and small operators.
The draft delegated act was open for public feedback until June 1, 2026, and the commission has signaled it does not intend to delay further. For instant coffee producers, importers, and blenders selling into the EU, the message is clear: traceability systems built for green and roasted coffee now need to extend to every soluble product on the shelf.