HOW THE EU’S 2025 ORGANIC REGULATION RESHAPES COFFEE VALUE CHAINS

Over the last two years, the coffee sector has weathered extraordinary turbulence. Climate disruptions, plant diseases, shifting markets, and unprecedented price swings have redefined the landscape for coffee farmers and roasters alike.

In parallel, the European Union has introduced a series of regulatory measures with direct consequences for coffee imports. These include the EU Deforestation Regulation (EUDR) -aimed at ensuring that supply chains are not linked to deforestation, and mandatory Due Diligence requirements, which establish obligations for actors at every stage of the chain. Together, these measures reflect a broader EU commitment to greater transparency, sustainability, and accountability.

Added to this, since October 1, 2025, the EU’s organic regulation (Regulation EU 2018/848) has applied in full. This law harmonises the requirements for organic certification across all imports, replacing the former system of equivalence agreements for non-EU origins.

CONTEXT: ORGANIC COFFEE IN A CHANGING EU LANDSCAPE

Globally, coffee production reaches approximately 11 million metric tons per year, with certified organic coffee representing only a small share of that total -typically estimated in the very low single-digit percentages. Despite its modest volume, certified organic coffee plays a key role in premium and specialty markets, where consumers value traceability, sustainability, and chemical-free farming -principles often linked to agroforestry and biodiversity.

Much of this coffee is grown by smallholder farmers in Latin America, Africa, and Southeast Asia, whose traditional methods often align naturally with organic principles. These producers have long supplied the EU’s high-value organic market under a system of equivalency, allowing non-EU countries to certify products using their own national standards, provided they broadly matched EU requirements.

That flexibility ended on October 1, 2025. From that date, all organic coffee imports into the EU must fully comply with EU Organic Regulation (EU) 2018/848. Non-EU producers are now required to meet the same standards as EU-based farmers, covering soil fertility, crop rotation, internal control systems, and the legal structure of producer groups -requirements that often differ from traditional certification practices in origin countries.

For coffee -a crop largely grown outside the EU, this regulatory shift represents a significant moment. Producers previously certified under national systems or private schemes may need to restructure operations, formalise cooperatives, and implement robust compliance systems to maintain access to the EU organic market.

What was once a relatively accessible premium segment is now more structured and regulated. Stricter compliance requirements are affecting supply, increasing operational responsibilities, and influencing sourcing decisions across the entire coffee value chain, from smallholder communities and cooperatives to EU roasters.

These changes represent a clear shift in the certified organic coffee market. While the regulatory updates aim to harmonise standards and protect the integrity of the organic label, they also require adaptation from producers and roasters throughout the value chain.

KEY CHANGES IN EU ORGANIC LEGISLATION IMPACTING THE COFFEE VALUE CHAIN

From October 1, 2025, all organic coffee imported into the EU must fully comply with EU organic standards, not just be equivalent.

Below are the most significant changes and what they mean in practice for coffee producers

MAIN CHANGES AND THEIR IMPACTS ON COFFEE PRODUCERS

1. End of Equivalence: Full Alignment Now Required

Until now, non-EU producers could export coffee under national organic standards deemed ‘equivalent’ to EU rules. From October 2025, this flexibility disappears. Producers must now comply directly with EU standards, including:

Strict crop rotation and soil fertility rules
Prohibition of synthetic inputs (as before)
Stricter definition of the “production unit” -the entire farm must be certified organic

The loss of flexibility is especially challenging for smallholders in coffee agroforestry or mixed-farming systems. Practices that once fit under local standards may no longer qualify, forcing producers to adapt methods or risk losing EU organic market

2. Who Gets to Be Certified? New Limits on Certification Holders & Group Models
The new regulation reshapes how organic certification is structured in origin countries.

A. Only co-ops and producer associations can hold certificates
Private companies are no longer allowed to hold organic certificates on behalf of farmers. Certification must now rest with cooperatives or legally recognised producer associations – a fundamental shift from the previous system, where exporters often organised and managed supply chains

B. Stricter rules on group certification

Group certification -long a cornerstone for smallholder farmers, now comes with tighter restrictions:

Maximum of 2,000 producers per certified group
Previously, groups could include thousands of farmers. Now, groups must be split into smaller units, which increases the cost and complexity of certification.
Mixed farms allowed, but mixed groups not allowed
Under the new EU organic regulation, individual organic farmers canoperate mixed farms as long as there is clear separation (e.g. organic coffee for export and non-organic crops for local sales).
What is not allowed is for a group of operators to include both organic and non-organic members. This is a major challenge for many certified organic cooperatives that currently have both types of members.
Transition deadlines
The regulation is already fully applicable in third countries since 1 January 2025. However, the derogation period for import consignments expires on 15 October 2025. After that date, products not certified in full compliance with Regulation (EU) 2018/848 can no longer be imported into Europe as ‘organic’.
Individual audits required for farms over 5 hectares or €25,000 in sales
Farmers who exceed these thresholds can no longer be certified as part of a group. Instead, they must undergo a full individual audit – which is often prohibitively expensive.

The new rules significantly increase administrative and compliance requirements for coffee producers. Some may manage the necessary reorganisation into legal producer associations or smaller groups, but for others, the changes could be a breaking point. Smallholder farmers, particularly in countries without strong cooperative systems or with diverse farming practices, risk being pushed out of the organic sector entirely, which could reduce the availability of certified organic coffee for the EU market.

3. Mandatory Three-Year Transition Period

Previously, producers in remote or ‘clean’ areas without chemical input could sometimes obtain certification after just one year. Under the new regulation, all farms must now undergo a minimum three-year transition period, regardless of history or location before becoming eligible for certification.
Impacts include:

Significantly raises the barrier for new farmers or regions to enter the organic market
Producers must follow organic practices during transition without receiving organic premiums
Slower return on investment, discouraging expansion of organic coffee
Agroforestry systems and traditionally ‘organic by default’ farms lose their fast-track path to certification

This blanket rule makes certification more uniform -but also less accessible, and potentially limits the future growth of organic coffee origins.

4. Tighter EU Controls Bring Auditor Shake-Ups & Testing Delays

With the introduction of Regulation (EU) 2021/1378, the rules governing organic coffee certification have tightened significantly – affecting both the certification process and product verification. These changes are already creating bottlenecks and uncertainties across the supply chain.

A. Certification Process – Who can certify?
From 1 January 2025, only control bodies formally recognised by the EU are authorised to certify organic coffee destined for the European market.
This represents a fundamental shift from the previous equivalence system, where national or private certifiers could issue valid certificates as long as they broadly aligned with EU standards. Under the new rules, full compliance with the EU Organic Regulation is required.
This change has also raised the bar for certifiers themselves. During the transition, several established certification bodies faced uncertainty regarding their recognition status. While some ultimately secured EU approval, others were (temporarily) suspended, creating gaps in certification coverage. As a result, many exporters and cooperatives were left in limbo -unable to confirm shipments, sign contracts, or plan effectively during a critical period.

B. Product Verification – stricter, more frequent testing
Organic certification is no longer based solely on documentation and audits -it now hinges just as heavily on direct testing of coffee lots. Residue testing has become more frequent and more precise, with laboratories using advanced technology to detect even trace amounts of contamination.

To obtain or maintain certification, companies must:

Regularly sample their coffee lots
Send those samples to EU-accredited laboratories
Wait one to two weeks for results

These tests are mandatory for passing audits conducted by recognised control bodies.
While this strengthens the integrity of certified organic coffee, it also introduces delays, administrative burdens, and higher costs -pressures that fall disproportionately on smallholder-based supply chains.

Impacts include:

Certification disruptions have created bottlenecks across the supply chain
Cash flow is constrained, as producers cannot invoice or ship coffee while awaiting lab results
In volatile markets, the 1–2 week delay may force producers to skip certification altogether in order to sell quickly and secure pricing
Testing and admin costs are eating into already thin margins
The constant need to prove organic status at every stage makes it increasingly difficult for smallholder-led supply chains to remain compliant -or even operational, under the new EU rule.

5. Rising Costs, Shrinking Supply & Marketing Shift away from Europe
The new EU organic regulations are driving up costs, complexity, and risk -especially for smallholder cooperatives. Stricter certification rules, audits, and administrative burdens are shrinking the supply of certified organic coffee. Scarcity has pushed premiums higher, and some exporters are actively seeking markets outside Europe where regulations are less demanding. In the EU, these pressures are squeezing smallholder margins and limiting availability.

➤ NEWS FROM THE FIELD – How our Specialty Producer Partners are adapting to the new organic rules.

The impact of the new regulation on producers differs depending on the farming model and origin. Adaptation to the new regulation is either a rather ‘easy’ update or a real challenge.

Fazendas Dutra, Brazil
For a producer like Fazendas Dutra in Brazil, being compliant with the new regulation has been more about a new ‘cross check’. Since 2015, all Dutra farms have been fully organic and Rainforest Alliance certified. The region’s natural suitability for organic farming and historically low pesticide use made the transition to organic certification a natural progression for the farm.

In 2024, Fazendas Dutra won 2nd place as one of the most sustainable farms in Brazil, organised by Rabobank. The Sustainable Farm Award 2024 recognises agricultural properties that demonstrate exemplary sustainability practices. The award is divided into 3 categories based on the size of the farm: small, medium, and large, with each category honouring 3 top-performing farms. Out of nearly 100 competing farms, 15 finalists were selected. Fazendas Dutra secured 2nd place in the medium property category due to its significant sustainable coffee production practices. More recently, the farms also became Regenerative Organic Certified (ROC). Founded in 2017, ROC builds upon existing organic and social fairness certifications while adding three core pillars focused on improving the social and environmental conditions of coffee production. The pillars for coffee production are soil health, animal welfare, and social fairness.

Gujoo Trading PLC, Ethiopia
From an Ethiopian exporter point of view, adaptation to this new regulation has been much more challenging. According to our partner Biniyam Aklilu from Gujoo Trading PLC, a specialised organic green coffee exporter established in Addis Ababa since 2018, the re-organisation of well-established organic smallholder supply chains into separate new group entities risks jeopardising business relations, functional structures, and organic control integrity.

It also means a significant increase in certification costs. “There will be around two audits every year -before harvest and during harvest,” he explains. As a result, there is lower profitability and increased business risk of organic exports to the EU. Only groups with strong technical and financial support are able to adapt to this new regulation. Biniyam Aklilu is currently preparing a first audit before a second one in November to hopefully get the green light for the new certification.

Coopfasi, Peru
In Cajamarca, Peru, the cooperative Coopafsi has exported organic coffee to Europe for over 20 years. Luzmila Loayza, Sales and Certification Manager, describes the shift from equivalence to full EU compliance as a major change.“Before, our certification body validated ‘equivalent’ standards. Now we must comply exactly with the EU rules, which are more detailed and demanding.”

The transition has doubled the documentation, verification, and internal inspections required. Key challenges include adapting the group certification structure, managing legal registration, traceable production, and land titles, as well as geo-referencing plots and recording yields in areas with limited connectivity.“At first, farmers were frustrated, but once they understood the importance for market access, they became part of the solution.”
Coopafsi has invested in GPS tools, digital records, training, and workshops to support members in meeting the stricter requirements. Looking ahead, Luzmila adds: “We’ll continue to adapt -with stronger systems, better data, and more transparency. Compliance isn’t just paperwork; it shows that small producers in Cajamarca can meet the world’s highest standards while protecting our forests and our culture.”

These stories illustrate how some of our partner producers are responding to the new EU organic regulation. Fazendas Dutra has integrated the updated requirements into existing sustainable practices. Gujoo Trading is reorganising smallholder groups, managing additional audits, and adjusting operations to maintain certification. Coopafsi is strengthening internal systems, digitalising records, and training farmers to meet stricter traceability and compliance standards. Across all cases, adaptation involves administrative work, financial investment, and careful coordination, reflecting the practical steps producers are taking to continue exporting organic coffee to Europe under the new rules.

NAVIGATING THE NEW EU ORGANIC REGULATIONS: STRATEGIC CONSIDERATIONS FOR COFFEE ROASTERS

Brand Philosophy

What does ‘organic’ truly represent for your brand? Consider whether your packaging will feature the EU organic logo or if your focus will be on a broader philosophy that highlights clean farming, biodiversity, and sustainable practices -even if your coffee is not yet certified under the updated EU rules.

Sourcing Viability
Is your current sourcing model still sustainable? Some origins may lose certification under the new regulations, and availability of certified organic lots could fluctuate. Building flexibility into your sourcing portfolio is essential to manage potential disruptions.

Supplier Due Diligence
Who are your partners in the supply chain? Work with specialty producers, cooperatives, and green coffee sourcers familiar with the new EU rules to help navigate compliance. Verify certification bodies, farmer group structures, and testing procedures to ensure a consistent and reliable supply.