akar.earthWhich Coffee Products and HS Codes Fall Under the EUDR
EUDR HS codes for coffee: green and roasted coffee under HS 0901, what to check in Annex I for instant coffee, and traceability for Indonesian roasters.
Under the EUDR, coffee products are covered through HS heading 0901, which includes green and roasted coffee, decaffeinated coffee, coffee husks and skins, and coffee substitutes containing coffee. For instant coffee, extracts and other preparations, check the current Annex I of Regulation (EU) 2023/1115 for your specific code, since coverage is code by code and the list was updated by Delegated Regulation (EU) 2026/2102.
How coverage works
Annex I lists relevant products by code. A coffee product is in scope if its code appears there. If not, the EUDR does not apply to that product, although EU buyers may still require deforestation-free sourcing under their own policies.
For Indonesian exporters this means two checks:
- What code does each export product carry?
- Is that code listed in Annex I, as currently amended?
The code must also match what the EU importer declares at customs and in the due diligence statement.
Indonesian coffee products
| Product | Code reference | Covered? | Indonesian context |
|---|---|---|---|
| Green coffee, not decaffeinated | 0901 | Yes | The bulk of Indonesian coffee exports, robusta and arabica |
| Green coffee, decaffeinated | 0901 | Yes | Small volumes |
| Roasted coffee, beans or ground | 0901 | Yes | Growing specialty and domestic roasting sector |
| Coffee husks and skins (cascara) | 0901 | Yes | Niche specialty product |
| Coffee substitutes containing coffee | 0901 | Yes | Rare in exports |
| Instant coffee, extracts, concentrates | Outside 0901 | Check Annex I | Indonesian soluble coffee plants export to many markets |
| Ready-to-drink and mixed preparations | Various | Check Annex I | Mostly regional exports |
Traceability for roasted and blended products
Roasting does not end traceability. A roaster in Indonesia exporting roasted coffee to the EU must know which green coffee lots went into each roast batch, and which plots supplied those lots. Practical steps:
- Batch records. Record green lot IDs for every roast batch.
- Blend recipes. For blends of several origins, keep the share and lot of each component.
- Segregation. Store green coffee from verified lots separately. Mass balance is not accepted.
- Origin mixing. If an Indonesian blend includes imported coffee from other countries, each component needs its own plot data.
For specialty exporters selling single-origin, single-farm or single-cooperative lots, traceability is often simpler, because the lot already maps to a defined group of farmers.
Green coffee: where the work is
Since green coffee is the main Indonesian export, most of the effort is in making green lots traceable. Green coffee is assembled from many farmers through collectors, hullers and warehouses. Sorting and grading in export mills can split one farmer’s coffee across several grades and lots, and combine many farmers into one lot. Mills need lot tracking that survives sorting:
- Assign intake lot IDs linked to the farmers or collectors who supplied them.
- Record which intake lots went into each export lot after sorting and grading.
- Keep rejected and lower-grade fractions traceable too, since they may be sold to other EU buyers.
See coffee due diligence for the full process.
By-products and secondary markets
Coffee husks and skins (cascara) are under 0901, so a specialty exporter selling cascara to the EU needs the same plot data as for the beans. Exporters selling lower grades to EU instant coffee manufacturers should check how the buyer’s final product is classified and what data the buyer needs.
When codes are uncertain
If you are unsure which code applies, ask your customs broker and the EU importer. Classification errors can cause a statement to be rejected or a shipment to be held. Keep a product register listing each product, its code, whether it is in Annex I, and the supply chain behind it.
Specialty coffee and micro-lots
Indonesia’s specialty sector, from Gayo and Flores arabica to fine robusta from Java and Lampung, sells smaller lots at higher prices to EU roasters. Specialty exporters often have an advantage: they already know the farmers or washing stations behind each lot. To turn that into EUDR evidence, they need geolocation for every garden in the lot, deforestation screening, and a record that the lot was kept separate from commercial coffee during processing. Samples and pre-shipment lots sent to EU buyers for cupping are usually small, but check with the buyer whether they need data for samples too.
Next steps
Start with classification, then trace each covered product to its plots. See coffee and the EUDR for the origin overview, the glossary entry on traceability, and the EUDR hub for the full topic map. For help linking roast and export lots to farm data, see our EUDR compliance services or message us on WhatsApp.
Frequently asked questions
Which HS code covers coffee under the EUDR?
HS heading 0901, which covers coffee whether or not roasted or decaffeinated, coffee husks and skins, and coffee substitutes containing coffee, is listed in Annex I.
Is instant coffee covered by the EUDR?
Check Annex I for the code of your product. Coverage of extracts, essences and preparations depends on whether their specific code is listed.
Are blends of Indonesian and other coffees covered?
Yes, if the product's code is listed. Each origin in the blend must be traced to its plots and pass due diligence.
Does roasting in Indonesia change the obligations?
No. Roasted coffee under heading 0901 is still covered, and the plots that grew the green beans must be traceable.