Ochratoxin A (OTA) is a naturally occurring mycotoxin that can develop when certain fungi grow on agricultural products, including coffee. It becomes a topic of interest for roasters and buyers because OTA is regulated in roasted and soluble coffee within both EU and UK markets.
This article outlines what roasters and buyers need to know at the green coffee stage and how it relates to regulatory requirements further along the supply chain.
Regulatory Position on Green Coffee
At present, there is no legally defined maximum limit (ML) for OTA in green coffee in either the European Union or the United Kingdom. OTA limits only apply after the coffee has been roasted or processed into soluble form. In the European Union, maximum levels for ochratoxin A are set by Regulation (EU) 2023/915. These replace the old regulations 1881/2006 and 401/2006. From 1 April 2024, mycotoxin sampling and analysis are governed by Regulation (EU) 2023/2782 with a transition period to 1 January 2029.
In Great Britain, mycotoxin controls are enforced under assimilated EU law derived from 1881/2006 and 401/2006, as set out by the Food Standards Agency. This means that green coffee itself is not subject to a fixed OTA threshold at import. However, authorities may still choose to sample consignments as part of broader food safety surveillance. It is important to note that Northern Ireland aligns with applicable EU food law, and operators trading with or in Northern Ireland should check the current EU-aligned requirements accordingly.
Why Moisture Matters
Even without a formal limit, moisture control remains an essential preventive measure. The European Coffee Federation recommends a maximum moisture content of 12.5 percent for green coffee in transit and storage. Keeping moisture low helps reduce the likelihood of fungal growth and OTA formation as the coffee moves through the supply chain. Roasters and buyers should be aware that moisture fluctuations during shipping or storage can affect the risk profile of any green coffee, regardless of origin or variety.
It should also be noted in resolution 420, the International Coffee Organisation (ICO) acknowledge there are exceptions to the target quality standards by specific coffees, such as India Monsooned Malabar. These may increase the risk from an OTA point of view but conform to the European Standard Coffee Contract (ESCC) Article 7 (a), where it states, ‘Quality shall be in accordance with the contract description.’ The ESCC is linked to the ICO Code of Practice “Prevention and reduction of Ochratoxin A contamination in coffee” to determine whether parties have done the necessary to supply coffee of ‘sound and merchantable quality’ as required in Article 7 (b).
What Happens at Import
While green coffee has no OTA limit, EU and UK authorities operate structured surveillance systems for contaminants. Shipments may be sampled, tested or inspected if there is reason to assess mycotoxin risk. This approach is aligned with the EU’s wider contaminant control framework and the sampling and analysis procedures defined in Implementing Regulation (EU) 2023/2782.
The key point for roasters and buyers is that although no ML exists at the green stage, OTA can still trigger scrutiny if elevated levels are detected.
Where Legal Limits Do Apply
Once coffee is roasted or processed into soluble form, the following strict limits come into force within the EU:
- Roasted coffee (beans or ground): 3 µg/kg
- Instant / soluble coffee: 5 µg/kg
These limits were updated under Regulation (EU) 2022/1370, effective from 1 January 2023, lowering previous thresholds. This has been consolidated and replaced by 2023/915 which has adopted the same, lowered, levels.
Great Britain (England, Scotland, Wales) has not adopted 2023/915. The FSA directs businesses to assimilated Regulation 1881/2006 for mycotoxin MLs and assimilated Regulation 401/2006 for sampling, meaning GB continues to enforce the pre‑2023 EU limits unless the UK issues a domestic amendment. Independent regulatory briefings also note that the UK has not formally adopted 2023/915 and continues to enforce via assimilated law.
GB assimilated limits
- Roasted coffee (beans or ground): 5 µg/kg.
- Instant / soluble coffee: 10 µg/kg
Buyers involved in roasting or importing roasted or soluble products must ensure their finished goods meet these legally binding requirements.
Our Approach as a Green Coffee Supplier
We manage OTA risk through working with suppliers that use recognised good practice at origin, including controlled drying, appropriate storage and adherence to the moisture recommendations noted above. Our role is to supply green coffee that meets industry expectations and in doing so, supports buyers in meeting their own compliance obligations.
We do not set or interpret regulatory limits on behalf of customers, but we provide accurate product information and are available to discuss quality parameters where needed.
Customer Considerations
To support compliance further down the chain, roasters may wish to:
- Maintain stable, low humidity storage conditions after arrival
- Monitor OTA levels in roasted or soluble products where legal limits apply
- Ensure that internal quality processes reflect the requirements of the markets they supply
In Summary
Green coffee does not have a legal OTA limit, but roasters and importers should be aware of the strict controls applied to roasted and soluble coffee in EU and UK markets. Moisture management and good storage practices remain essential at every stage of the supply chain. Our role is to provide well-handled green coffee and transparent information so buyers and roasters can meet their own compliance needs confidently.
Documents & Further reading
Regulation 2023/915
ICO Code of Practice for the prevention and reduction of Ochratoxin A Contamination in Coffee (pdf)
ECF Guidelines for the prevention of OTA occurrence in coffee (pdf)
Food Standards Agency – Mycotoxins
Ochratoxin A in coffee. A critical review of contemporary scientific literature (pdf)
European Standard Contract for Coffee (pdf)
The Windsor Framework
