Soluble coffee enters the EUDR scope: the 13 July 2026 Delegated Act and the December 2027 compliance timeline

Soluble Coffee Enters the EUDR Scope: What the 13 July 2026 Delegated Act and the December 2027 Timeline Mean for Instant Coffee

The European Commission adopted a Delegated Act on 13 July 2026 that adds soluble (instant) coffee to the product scope of the EU Deforestation Regulation (EUDR), under CN code 2101 11 00. Products newly added to scope, including soluble coffee, become subject to EUDR obligations from 30 December 2027, one year after the general application date. For instant coffee producers and the green coffee exporters who supply them, this closes a loophole that previously let soluble coffee reach the EU market without deforestation due diligence.

The Delegated Act amends Annex I of Regulation (EU) 2023/1115, the list of in-scope products, and was adopted alongside an Implementing Act setting the technical rules for the EUDR Information System. Both instruments close out the simplification package the Commission announced on 4 May 2026, according to EUDR.today. The Commission's stated rationale is that excluding soluble coffee 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, as reported by Comunicaffe.

The act adds soluble coffee, certain palm oil derivatives, frozen cattle tongues, and certain soap products to Annex I, while removing cattle hides, skins and leather, retreaded tyres, soybean seeds for sowing, certain rubber products, and aircraft and motor vehicle seats, per Linklaters. The specific entry is HS/CN code 2101 11 00, "extracts, essences and concentrates of coffee," which brings instant coffee into EUDR scope for the first time, as confirmed by Coolset.

The Delegated Act is not yet in force. Under Article 34 of the EUDR, the European Parliament and the Council have two months, extendable by a further two, to object. Neither body can amend the text, only veto it, and observers consider that unlikely. If no objection is raised, the final product list is expected to enter into force around mid-September 2026, according to EUDR.today. The separate Information System Implementing Regulation (EU) 2026/1565 is already law, having entered into force on 17 July 2026.

What this means for buyers

The December 2027 timeline is the single most important detail for procurement planning. The general EUDR application date is 30 December 2026 for large and medium-sized operators and traders, and 30 June 2027 for micro and small operators and traders, per Linklaters. Soluble coffee gets a full year beyond that, with obligations applying from 30 December 2027. That transition period is designed to give manufacturers, importers and exporters time to update supplier records and compliance systems, as New Food reported.

For buyers sourcing green coffee from Uganda, the practical effect is that the same deforestation-free documentation now required for green beans will eventually be required for the soluble coffee made from them. The heavy obligations sit with the operator first placing goods on the EU market, while the first downstream buyer only collects the due diligence statement reference number, and companies further down carry no EUDR paperwork, per EUDR.today. Instant coffee producers should therefore expect their green coffee suppliers to provide the same geolocation and due diligence data they already supply for whole-bean shipments.

The December 2027 date is not a reason to delay. Because the Delegated Act is still in scrutiny, the working baseline for portfolio mapping is the published list, and the Information System API specifications are now stable. Buyers who handle soluble coffee should re-map their product portfolios now, confirm which of their suppliers can provide deforestation-free documentation, and plan Information System integration if they file at volume. Uganda green coffee exporters who already document their supply chains for green bean shipments are well positioned to extend that documentation to the soluble coffee channel.

FAQ

When does soluble coffee have to comply with the EUDR?
Soluble coffee, added to Annex I under CN code 2101 11 00, becomes subject to EUDR obligations from 30 December 2027, one year after the general application date. This is confirmed by EUDR.today, Linklaters, Coolset and the European Coffee Federation.

Is the Delegated Act already in force?
No. The Annex I Delegated Act is in scrutiny under Article 34 of the EUDR, with the European Parliament and Council having two months, extendable by two, to object. It is expected to enter into force around mid-September 2026 if no objection is raised, per EUDR.today. The separate Information System Implementing Regulation (EU) 2026/1565 entered into force on 17 July 2026.

Does the December 2027 date change the deadline for green coffee?
No. Green coffee was already in Annex I and stays on the general timeline of 30 December 2026 for large and medium operators and 30 June 2027 for micro and small operators, per Linklaters. Only the newly added products, including soluble coffee, get the later 30 December 2027 date.