What’s new in the EUDR review?
- Soluble coffee proposed in EUDR scope closing a compliance gap
- Instant coffee imports could trigger mandatory EUDR due diligence
- Commission rejects negligible risk category keeping low, standard and high tiers
- Updated IT system and legal databases aim to reduce compliance burden
- Palm oil derivatives included and leather excluded
The European Commission’s long-awaited review of the European Deforestation Regulation (EUDR) is now here – offering clarity to food and drink manufacturers around the world.
Among the proposed changes is the addition of soluble coffee to the regulation’s scope. While coffee was already covered alongside cocoa, palm oil, cattle, soy, timber and rubber, instant coffee had previously been excluded for unclear reasons.
Soluble coffee: An odd omission’s been rectified
Coffee has been included in the scope of EUDR from day dot, in almost all its forms: green coffee, roasted coffee, decaffeinated coffee, coffee extracts, concentrates and oils. But for unknown reasons, instant coffee has escaped scrutiny – until now.
What is soluble coffee?
Instant coffee is a convenient, shelf-stable beverage made from brewed coffee beans.
The primary difference between ground coffee beans and instant coffee is in the processing: to make instant coffee, brewed beans are dehydrated into powder or crystals that dissolve instantly in hot water – hence the name.
Like ground coffee, instant coffee is made from 100% coffee beans.
It’s been speculated that soluble coffee’s omission from the EUDR was simply an oversight that’s now being amended.
Whatever the reason, when the law comes into force, instant coffee’s customs code could trigger EUDR due-diligence checks at the border.
Without soluble coffee in scope, a company could technically source, process and package instant coffee entirely outside Europe, then import the finished product into the bloc without scrutiny.
It’s hoped this change closes loopholes that could otherwise allow imports to bypass deforestation checks.
‘Negligible’ or ‘no risk’ category off the table
The review also settles debate around the possible introduction of a ‘negligible’ or ‘no‑risk’ benchmarking category, which some countries – including the US – had lobbied for.
From the Commission’s side, that seems to have been ruled this out. The three existing tiers – low, standard and high risk – remain.
Other updates relate to the EUDR IT system, which the Commission will reopen with new features, including simpler declarations and tools that allow companies to submit “group submissions” – which stakeholders had requested to ease due diligence admin.
By the end of the year, the Commission also plans to launch databases covering relevant laws in producing countries, as well as recognised certification schemes.
And finally, in significant news for food‑adjacent sectors, the Commission wants to bring certain palm oil derivatives, such as soap made with palm oil, into scope. Leather, however, will be excluded.
With no mention of another EUDR delay – the legislation has already been set back twice – the Commission is pushing forward with the agreed deadline: 30 December 2026 for larger companies, and 30 June 2027 for smaller ones.
Public feedback now open
The draft legislation, in which the Commission proposes changes to the list of products in scope, is open for public feedback until 1 June.
