Coffee, cocoa, tea and packaged food imports

• Regulation (EU) No 1169/2011 — food information
• Regulation (EC) No 178/2002 — general food law
• Regulation (EU) 2023/1115 — EUDR for coffee and cocoa
• Regulation (EC) No 852/2004 — food hygiene

Who has to appoint one

Anyone placing packaged food on the EU market. The operator whose name appears on the label must be established in the Union and registered with its national food authority. For coffee, cocoa and products derived from them, the deforestation Regulation adds an operator duty with geolocation-based due diligence before the goods may be placed on the market.

Thresholds and exemptions

No threshold for food law. EUDR gives micro and small operators later deadlines and lighter procedures, but the products remain in scope and the statement is still required.

What must appear on the label

Name of the food, ingredient list with allergens emphasised, quantitative ingredient declaration where relevant, net quantity, minimum durability or use-by date, storage and use conditions, the name and EU address of the responsible operator, country of origin where its omission would mislead, and the nutrition declaration. For coffee and cocoa, the due diligence statement reference travels with the consignment.

Marketplace fields

Marketplaces require the EU operator details and the full label image. Food is also subject to import controls, so cross-border listings without a compliant EU supply chain fail at the border rather than at the listing.

Documentation you must hold

Registration as a food business operator. HACCP procedures and traceability one step back and one step forward. Specifications and certificates of analysis. Import documentation and, where the product is subject to reinforced controls, the results of the required testing. For EUDR: the due diligence statement, geolocation of the plots, evidence of legality in the producing country and the risk assessment.

Standards and testing

Mycotoxin testing for coffee, cocoa, spices and dried fruit; pesticide residue screening; heavy metals, in particular cadmium in cocoa; and microbiological testing appropriate to the food. Consignments from listed origins face reinforced border testing under Regulation 2019/1793.

Language requirements

The entire mandatory label in the official language of each member state of sale. This is the strictest language regime of any category and is checked in routine retail inspections.

When it applies

Registration and labelling before the first sale. EUDR applies from 30 December 2025 for large and medium operators and 30 June 2026 for micro and small enterprises, subject to the adopted postponements.

How long records are kept

Traceability records per national law, generally at least five years, and EUDR due diligence records for five years.

What happens if you do not comply

Border rejection and destruction, withdrawal, and fines. Under EUDR, fines of at least 4% of EU turnover, confiscation of the goods and the revenue, and exclusion from public procurement. Undeclared allergens are treated as a public health matter and prosecuted in several member states.

Who enforces it

National food safety authorities, border control posts, and the competent authorities designated for EUDR.

Where the boundary lies

Two regimes on the same bag of coffee: food law for what is in it and how it is labelled, EUDR for where the beans grew. Neither substitutes for the other, and they are enforced by different authorities. A food supplement is a further separate regime with national notification.

Questions we are asked

Can a GPSR responsible person cover food?

No. Food law requires a registered food business operator established in the Union with substantive duties including traceability and withdrawal.

Does EUDR apply to roasted coffee we buy in Europe?

If you place it on the market you are an operator or trader with duties, though a downstream trader can rely on the reference numbers of the statements already lodged upstream.