Understanding Acrylamide in Coffee
Acrylamide is a process contaminant that forms naturally when certain foods are heated above 120°C under low moisture conditions. In coffee, it develops during roasting through the Maillard reaction between reducing sugars and the amino acid asparagine. Green coffee does not contain acrylamide before roasting.
Regulatory Framework: EU and Great Britain
Acrylamide in food is regulated in the European Union through Commission Regulation (EU) 2017/2158, which sets out mitigation measures and benchmark levels for several food categories, including roasted and instant coffee. These benchmark levels are not maximum limits. They are used to check whether mitigation measures are effective.
In Great Britain, the Food Standards Agency states that these same requirements apply as assimilated law, meaning food businesses must manage acrylamide in line with the specifications in Regulation (EU) 2017/2158. Northern Ireland follows EU law directly.
No Requirements for Green Coffee Importers
Acrylamide forms only during roasting and other heat based processing steps. It is not present in green coffee. As a result, there are no acrylamide obligations placed on green coffee importers. Compliance responsibilities begin at the stage where coffee is roasted or processed into instant coffee.
Roaster Responsibilities
Roasters are responsible for ensuring that acrylamide levels in roasted coffee are kept as low as reasonably achievable. Regulation (EU) 2017/2158 requires roasters to apply appropriate mitigation measures within their food‑safety management systems and to verify that these measures are effective.
For coffee, the regulation includes two benchmark reference levels(BML) in Annex IV:
- Roasted coffee: 400 μg/kg
- Instant coffee: 850 μg/kg
These values are used as investigation points. When they are exceeded, a review of roasting controls and mitigation steps is expected. They do not function as legal limits.
Mitigation Measures for Roasting
Roasters and soluble coffee manufacturers are expected to adopt practical steps suited to their processes. These may include controlling early‑stage roasting profiles, managing time–temperature curves, assessing any post‑roast heat treatments, and reviewing heat‑based extraction or concentration stages for instant coffee. The chosen measures should reflect the scale and nature of the operation. Products based on Robusta beans tend to have higher acrylamide levels than products based on Arabica beans.
Verification and Monitoring
Where appropriate, representative sampling and analysis may be used to confirm that mitigation measures are effective. If benchmarks are exceeded, operators are expected to investigate the cause and update their controls. Benchmark levels (BMLs) are generic performance indicators for the food categories covered by the Regulation. They are not maximum limits and are not intended to be used for enforcement purposes. BMLs are to be used by food businesses operators to gauge the success of the mitigation measures. All mitigation activities and verification steps must be documented. In Great Britain, the FSA confirms that these expectations apply through assimilated law.
