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Newsletter Articles

What kind of coffee do you drink?

27 Jul 2022 Europe

 The answer to this question is neither “black” nor “with sugar”. The question refers to whether we know if the coffee we consume contains a coffee substitute or additives that are not properly declared, if at all. This issue was recognised long ago, and now it finally got a regulatory framework. 

On 31 May 2022, the Rulebook on Quality of Raw Coffee, Coffee Products, Coffee Substitutes and Related Products (Official Gazette of RS no. 159/2020) (“the Rulebook”) started to apply. It was adopted in December 2020 and entered into force on 7 January 2021. However, the application of the Rulebook was delayed so that the manufacturers would have enough time to adjust their operations with the newly established requirements.

Scope of the Rulebook

The Rulebook specifies requirements regarding the quality of raw coffee, coffee products, coffee substitutes and related products. In other words, the Rulebook prescribes conditions referring to the content of the respective products, as well as names under which they are placed in the market and content of declarations of such products.

Integral parts of the Rulebook are the List of Standards Establishing the Methods for Sampling and Examining Product Quality (Appendix 1) and Technological Procedures Applied in Product Manufacturing and Processing (Appendix 2).


According to the Rulebook, before the production commences, an entity operating in food business shall pass a manufacturer’s specification,under the law regulating food safety, which shall notably contain elements prescribed by the Rulebook. In relation thereto, the Rulebook stipulates that the products declared, i.e., labelled before the Rulebook started to apply, which do not comply with the requirements set out thereby, may be marketed until their expiry date.

Raw coffee

As regards the raw coffee, according to the Rulebook, it is a product of dried seed (coffee bean) of plant from Coffea species, obtained by appropriate technological process from coffee fruit, by removal of mesocarp, endocarp and partially or entirely of parchment (silver skin). It is further categorised according to botanical types and marketed under the following titles: 1) raw coffee; 2) raw coffee blend; 3) raw decaffeinated coffee; 4) raw decaffeinated coffee blend; 5) raw coffee with a share of defect; or 6) raw coffee blend with shares of defect.

Coffee products

Pursuant to the Rulebook, coffee products shall mean: 1) roasted coffee; 2) coffee extracts; and 3) beverage from cold-extracted coffee. The Rulebook further defines each of the stated products and prescribes the names under which they shall be marketed, as well as requirements regarding their content and declaration.

Coffee substitutes

The Rulebook stipulates that a coffee substitute is a product obtained by roasting fruits and edible parts of plant rich in starch, sugars, and inulin. Within the stated group of Products, the Rulebook further distinguishes: 1) roasted coffee substitute; 2) coffee substitute extracts; and 3) chicory extract.

Related products

As for the related products, the Rulebook defines them as coffee products (such as roasted coffee, coffee extracts and beverage from cold-extracted coffee) that may be added sugar, powdered milk and other milk products, vegetable fats, aromas, additives, spices, spice extracts and other additives, as well as products obtained by mixing roasted coffee and coffee extracts that may be added the abovesaid additives.

Related products may also be added edible parts of plants, except for certain roasted edible parts of plants (indicated in Article 21 of the Rulebook) and their extracts.

Related products are marketed under the name containing names of coffee products, i.e., blends of coffee products, with indication of additives.

Reasons for passing the Rulebook

The main reason for adoption of the Rulebook is certainly alignment with the regulations of European Union, i.e., Council Directive 77/436/EEC, but also prevention of unfair business practices towards consumers, which would mislead them regarding the nature and content of products they consume.


Ivana Ružičić
Managing Partner 


Lara Maksimović
Senior Associate