European Coffee Federation
ECF
The European Coffee Federation (ECF) is the single voice of the European coffee trade and industry, facilitating the development of an environment in which the industry can meet the needs of consumers and society, while competing effectively to ensure the resilience and long-term sustainability of the coffee supply chain, from farm to cup.
ID: 958482431512-92
Lobbying Activity
Response to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)
12 May 2025
The European Coffee Federation (ECF) welcomes the opportunity to contribute to the public consultation on the Delegated Regulation amending Annex I of the EU Deforestation Regulation. Please find attached the ECF's feedback, with a focus on the non-inclusion of soluble coffee (HS code 2101 11) in the annex, as well as on the aspects related to the exclusion of samples from the EUDR scope.
Read full responseMeeting with Nils Torvalds (Member of the European Parliament, Shadow rapporteur for opinion) and Nestlé S.A. and
26 Apr 2023 · Packaging and packagingwaste
Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
21 Apr 2023
The European Coffee Federation (ECF) welcomes the European Commissions proposal to update the EU legislative framework for packaging and packaging waste (PPWR) by giving Member States and businesses adequate support to achieve waste reduction targets to diminish the environmental impact of packaging. For over a decade ECF and its members have remained committed to ensure that Single Serve Units (SSUs), referred to in the proposal as coffee bags and coffee system single serve units, meet a proper end of life that enables full circularity and maximization of resource efficiency for the category. Regretfully, all proactive proprietary and collective investments made over the years have been compromised by the wording of the Packaging and Packaging Waste Regulation proposal. Although the preamble to the PPWR reinforces the criticality of recycling as a vital enabler of a circular economy, the proposed PPWRs explicitly prohibits recyclable coffee system single serve units being placed on the market. Moreover, it mandates that full after use SSUs be compostable, utterly undermining the coffee industrys efforts to operate on a circular model. In line with the spirit of the EU Green Deal and Circular Economy Action Plan, ECF and its members will continue to be committed to Single Serve Units (SSU's) circularity, contributing to diminishing the impact of packaging in the environment. The European coffee sector respectfully requests the European Commission adequate support to achieve waste reduction targets to diminish the environmental impact of packaging by: Ensuring that all coffee single serve units are classified as packaging. (Art 3 (f), (g), Annex I) No material being mandated. Coffee SSU's should have the right to be recyclable or compostable (Art. 6, Art. 8). A multi-material approach that considers the benefits of all available options to meet the requirements for safety, functionality, quality and circularity would be today the best way forward. A fair collective approach (industry + competent authorities + waste management) that promotes an enabling environment by the development of adequate infrastructures for the different waste streams and the harmonization of waste management requirements across the EU. Launching consumer campaigns aiming to create awareness to boost consumer engagement in circularity and promoting harmonized EU-wide sorting instructions to bring further clarity to consumers. Clear labelling is to be ensured so there is no consumer confusion regarding disposal in the appropriate waste stream. Appropriate time for the implementation of the new requirements. (Art. 8, Year 2030) No disproportionate requirements for SSU's such as a double regulatory burden resulting in coffee SSU's being required to be compostable and recyclable, at the same time.
Read full responseMeeting with Salvatore De Meo (Member of the European Parliament, Rapporteur) and Carlsberg Breweries A/S and
7 Mar 2023 · PPWR
Response to Effectively banning products produced, extracted or harvested with forced labour
30 Nov 2022
The European Coffee Federation welcomes this opportunity to provide feedback on the European Commissions regulation proposal to prohibit products made with forced labour on the EU market. The European Coffee Federation and its members strongly support the objective of the EU to address the issue of products made with forced labour, in view of rooting out forced labour from global supply chains. We advocate for this regulation to create a level playing field and a harmonised EU legal framework, whilst promoting partnerships and capacity-building measures to effectively tackle the root causes of forced labour. Please find attached the feedback of the European Coffee Federation.
Read full responseResponse to Effectively banning products produced, extracted or harvested with forced labour
17 Jun 2022
Please find attached the feedback from the European Coffee Federation (ECF) to the call for evidence for the initiative “Effectively Banning Products Produced, Extracted or Harvested with Forced Labour”.
We would appreciate the opportunity to contribute to this discussion.
Read full responseResponse to Sustainable corporate governance
19 May 2022
The European Coffee Federation (ECF) supports the European Commission’s proposal for a Directive on Corporate Sustainability Due Diligence for companies to identify and mitigate risks linked to human rights or environmental adverse impacts in their own operations and supply chains.
ECF and its Members are committed to minimising and preventing adverse impacts on human rights and the environment in their own operations and value chains, while preserving their competitiveness on the EU single market. We consider the proposal for an EU Directive as an important step toward the development and promotion of more socially and environmentally sustainable and responsible value chains, sustainable sourcing approaches and the prevention of loss of biodiversity and natural resources.
While we expect the European Parliament and the Council to provide further clarity on certain aspects of the EU Directive, ECF and its Members stand ready to offer our sector-specific knowledge and experience to contribute to the achievement of the EU Directive’s objectives and to ensure it is made operational in practice.
ECF and its Members welcome the European Commission’s proposal for an EU Directive on Corporate Sustainability Due Diligence. In moving forward with the design of the EU Directive proposal, we call on policymakers to take into account the following priorities for the European coffee sector:
1. Ensure alignment with the existing EU provisions and the international standards
2. Mandate a proportionate and risk-based due diligence approach
3. Re-frame the scope of due diligence to the value chain, while clarifying appropriate action expected by companies
4. Set an appropriate role for contractual assurances and audit/verification processes, while promoting other instruments
5. Ensure a harmonised approach on sanctions and a proportionate civil liability regime
6. Strengthen stakeholder engagement throughout the due diligence process
7. Strengthen bilateral engagement and partnerships between the EU and third Countries
8. Assure an on-time publication of guidelines and model contract clauses
9. Clarify certain key concepts
Read full responseResponse to Application of EU health and environmental standards to imported agricultural and agri-food products
16 Mar 2022
The European Coffee Federation (ECF) appreciates the opportunity to contribute to the discussion.
• We call upon the EU to promote trade enabling policies that prevent market disruptions.
• Each coffee producing country is unique, facing its own challenges when it comes to protecting their crops and adapting to climate change.
• Maximum Residue Levels (MRLs) are trading standards that ensure consumers safety and encourage good agricultural practices. MRLs should not be considered as a direct tool to manage environmental challenges in other countries.
Over the past centuries coffee has become one of the most widely consumed and well-loved beverages in the world. Every year, 10 million tonnes of green coffee are produced in over 70 different coffee producing countries located in the area known as the Coffee Belt, located 23 degrees North and South of the Equator. According to Eurostat, in 2020, the EU imported 2.9 million tonnes of green coffee beans out of which 1.9 million tonnes of roasted coffee were produced with the remaining green coffee having been reexported or stocked.
For many developing countries coffee plays a pivotal role in the development of their economies with the EU being a key export market for many of them. Such would be the case for Honduras, Brazil, Perú and Vietnam that export 60%, 55% and over 40% of their green coffee to the EU.
Each coffee producing country is unique, facing its own challenges when it comes to protecting their crops from weeds, pests and diseases as well as when it comes to adapting to climate change. Each producing country will have developed their own regulatory frameworks for evaluating the risks of pesticides and their use, also bearing in mind biodiversity and environmental risks. Therefore, farmers should not be penalized when legally treating their crops in their own country. Attempting to apply EU law to non-EU countries should be carefully considered as at it will be the smallholder farmers who shall end up bearing the direct consequences of the inexistence of an international MRL harmonization.
Coffee producing countries are keen to adapt. However, we need to bear in mind that we are referring to 12.5 million smallholders that are producing 70-80% of the world’s coffee in an average size plantation of 4 hectares.
Taking the above into consideration, aiming to apply mirror clauses to coffee producing countries would create considerable trade disruptions. Generally speaking, it could also easily lead to endless reciprocal market access measures and legal disputes. Trade enabling policies avoid trade disruptions and have a fundamental role in fostering the development of agriculture in coffee producing countries and in ensuring the continuous flow of coffee into the EU so consumers may continue to enjoy drinking their cup of coffee.
ECF fully supports the need of addressing global environmental concerns, understanding that this can only be effectively tackled at the global level. Thus, we would encourage the European Commission to prioritize multilateral engagements with the appropriate international counterparts, rather than adopting a unilateral approach. We find a perfect example with the CODEX MRLs, a pesticide trading standard that was successfully established to protect consumer health. Moreover, CODEX has contributed to driving good agriculture practices and ensured fair practices in food trade by creating a level playing field for farmers all around the globe.
ECF believes that any EU initiative on the application of EU health and environmental standards to imported agriculture and agri-food products should promote an adequate framework that encompasses collaboration with all relevant stakeholders and supports existing commitments, initiatives and best practices.
It goes without mentioning that ECF remains open and willing to continue to engage with policy makers and civil society in view of achieving a sustainable coffee value chain.
Read full responseResponse to Policy framework on biobased, biodegradable and compostable plastics
27 Oct 2021
The European Coffee Federation (ECF) and its members are committed to ensure that Single Serve Units (SSU) meet a proper end of life that enables full circularity and maximization of resource efficiency for the category, in line with the policy objectives of the European Green Deal and the new Circular Economy Action Plan (CEAP).
For over a decade, our members have been actively working to ensure an appropriate end of life to the SSU´s they place on the market. There is a strong sector commitment, having heavily invested in different proprietary and collective approaches that have been implemented on a national level in many Members States.
There is a broad variety of SSU (aluminium, plastic, paper and compostable) on the European market that require a different approach as to how they are best recycled depending on their classification as packaging (empty after use SSU) or casing (rigid and soft SSU). Moreover, the recycling and disposal methods and regulations differ per EU country and even per region within a country, adding another layer of complexity to the collection, sorting and recycling of SSU´s.
A coherent and predictable regulatory landscape is fundamental for sustainable investments and needs to provide industry with freedom of material choice that allows space to innovate and to compete, while focusing on improved overall product environmental footprint.
Today, our members continue to work on both packaging and casing that is reusable or recyclable via material recycling systems as well as compostable. ECF and its members support the use of compostable materials that can be disposed of jointly with bio-waste, provided their use is aligned with the bio-waste treatment infrastructure (home or industrial) in selling markets. Composting (or “organic recycling”) is a dedicated recovery option for biodegradable materials for which the EU needs to ensure policy coherence between European and National legislation.
ECF and its members welcome the European Commission initiative to establish a credible and harmonised regulatory framework for biobased plastics (BBP), biodegradable and compostable plastics (BDCP) based on recognised international standards and science, calling upon the EU to:
• Maintain business operators’ freedom of material choice. Innovation in packaging and casing materials and end-of-life infrastructure solutions is crucial for a competitive European industry. A political framework should enable this freedom and focus on conditions supporting circularity.
• Ensure clarity of definitions. A clear distinction is to be made between, biobased, biodegradable and compostable plastics to ensure that there is an appropriate end-of-life infrastructure and to avoid consumer confusion.
• Develop an EU Standard establishing technical requirements and evaluation criteria for packaging and casing materials aimed to be composted in home composting units.
• Launch consumer campaigns aiming to create awareness on correct disposal of BBP and BDCP and to boost consumer engagement in circularity.
• Ensure the integrity of the Single Market by defending policy coherence between European and National legislations such as the French and German biowaste management policies.
The European coffee sector is committed to ensure that Single Serve Units meet a proper end of life. The European coffee sector is ready to work collaboratively and invest accordingly, to ensure, that there is an infrastructure in place and that consumers are provided with the necessary information to enable the full circularity of the Single Serve Unit category.
ECF is the representative organisation for the European coffee trade and industry, speaking for over 750 companies ranging from SMEs to internationally operating companies, representing approximately 35% of the world coffee trade volume.
Read full responseResponse to Commission Regulation setting maximum residue levels for chlorate in or on certain products
15 Feb 2019
The European Coffee Federation (ECF), welcomes discussions on setting achievable Maximum Limits for Chlorate as well as the opportunity to provide comments.
Nevertheless, ECF considers that Regulation (EC) 396/2005 is not the appropriate legal framework. According to Commission Decision 2008/865/EC all authorizations for plant protection products containing chlorate have been revoked following the non-inclusion of Chlorate in Annex I to Council Directive 91/414/EC. Thus, chlorate is no longer used in plant protection products and therefore falls out of the scope of the definition of ‘pesticide residues’.
Therefore, any reference made to processed foods or finished products would be inappropriate under Regulation (EC) 396/2005 as the possible presence of chlorate residues would not be a direct consequence of the use of plant protection products but of multiple sources during the processing of the product that imply the use of water or disinfectants.
ECF is concerned about the draft chlorate MRLs currently subject to public consultation, and in particular those related to processed foods, as the multiple sources of chlorate are not covered by Annex I to Regulation (EC) 396/2005. Thus, the suggested MRLs would not be realistically achievable because of the use of drinking water during the process or in our attempt to ensure/maintain microbiological safety.
It is for all these reasons that ECF believes that no feasible solution for MRLs may be achieved under Regulation (EC) 396/2005. Thus, we would welcome discussions on the setting of achievable Maximum Limits for chlorate, under the appropriate legal framework and having sufficiently assessed from a technical and legal standpoint the various origins of chlorates. The discussion should also be based on a solid risk assessment considering real consumers’ exposure to chlorate from all possible sources, taking into account the microbiological safety of foods and the compromises that would certainly occur should the use of chlorine-based disinfectants need to be reduced or replaced.
Read full response