Cascara and Regulation (EU) 2022/47.
Dried coffee cherry pulp and its infusion are authorised for sale in the European Union. Commission Implementing Regulation (EU) 2022/47 added them to the Union list of novel foods as a traditional food from a third country, and it entered into force on the twentieth day after publication in Official Journal L 9 of 14 January 2022.
Authorisation is not the end of the work. The regulation fixes what the product may be called, what it must contain, and what the label must say. This page sets out each of those, quotes the numbers, and says plainly where a fact is still open. It is the page we send to food-safety officers before they ask.
- Implementing Regulation (EU) 2022/47The authorisation, the conditions of use and the specification.
- Regulation (EU) No 1169/2011, Annex IIIThe caffeine statement for beverages above 150 mg/l.
- Implementing Regulation (EU) 2017/2470The Union list itself, which 2022/47 amends.
Everything below is quoted from these. Where we have not been able to verify a point against the primary text, this page says so in the same sentence.
Four permitted names, and “tea” is not one of them.
The regulation states that the designation of the novel food on the labelling of foodstuffs containing it shall be one of the following. A menu or a packet that calls it coffee cherry tea is not using an authorised designation.
- 01coffee cherry pulp
- 02cascara (coffee cherry pulp)
- 03coffee cherry pulp infusion
- 04coffee cherry pulp dried infusion
The Union list entry is headed “Coffea arabica L. and/or Coffea canephora Pierre ex A.Froehner dried cherry pulp and its infusion (Traditional food from a third country)”. Rimbaud ships Coffea arabica only.
High caffeine content. Not recommended for children or pregnant or breast-feeding women
Required when the product as sold, or after reconstitution, contains more than 150 mg/l of caffeine. It goes in the same field of vision as the name of the food, followed by the caffeine content expressed in mg per 100 ml.
At the regulation's own preparation ratio — up to 6 g per 100 ml of water above 75 °C — a cascara infusion is over that threshold. Plan on carrying the statement rather than on avoiding it.
Regulation (EU) 2022/47 carries this requirement in its own labelling clause, and Annex III of Regulation (EU) No 1169/2011 carries the general rule for beverages. Read them together.
NAME OF THE FOOD cascara (coffee cherry pulp) IN THE SAME FIELD OF VISION AS THE NAME High caffeine content. Not recommended for children or pregnant or breast-feeding women (___ mg per 100 ml <-- FILL THIS IN FROM THE ACCREDITED CERTIFICATE) DESCRIPTION Dried unroasted coffee cherry pulp of Coffea arabica L. Origin: Ethiopia, East Hararghe. Authorised in the European Union as a traditional food from a third country by Commission Implementing Regulation (EU) 2022/47. PREPARATION (required for pulp sold as such) Use up to 6 g per 100 ml of water above 75 °C. Leave a few minutes, then pour through a strainer. STORAGE Store dry, below 20 °C, out of direct light. LOT: RIM-25/26-EH-04. Packed by Rimbaud, Harar, Ethiopia.
The caffeine content is left blank on purpose. It is the one figure that is lot-specific and measured, and this lot's accredited panel is still at the laboratory. We would rather hand you a blank than a number we invented.
These are the figures in Table 2 of the Union list entry. A lot either meets them or it may not be sold in the European Union. Rimbaud publishes a lot-specific result against each one before you pay.
| Water | < 18% | We hold under 10.5% |
|---|---|---|
| Water activity (aw) | ≤ 0.65 | Measured off the beds |
| Ash | < 10.4% DM | Per lot |
| Protein | < 15% DM | Per lot |
| Fat | < 5% DM | Per lot |
| Carbohydrates | < 85% DM | Per lot |
DM: dry matter. CFU: colony forming units.
| Aerobic plate count | < 10⁴ CFU/g |
|---|---|
| Total yeasts and moulds | < 100 CFU/g |
| Enterobacteriaceae | < 50 CFU/g |
| Salmonella | Absence in 25 g |
| Bacillus cereus | < 100 CFU/g |
| Ochratoxin A | < 5.0 µg/kg |
|---|---|
| Aflatoxin B1 | < 2.0 µg/kg |
| Aflatoxins B1, B2, G1, G2 (sum) | < 4.0 µg/kg |
| Cadmium | < 0.05 mg/kg |
| Lead | < 1.0 mg/kg |
| Copper | ≤ 50 mg/kg |
| Mercury | ≤ 0.02 mg/kg |
| Arsenic | ≤ 0.2 mg/kg |
| Benzo(a)pyrene | < 10.0 µg/kg |
| Benzo(a)pyrene, benz(a)anthracene, benzo(b)fluoranthene, chrysene (sum) | < 50.0 µg/kg |
Pesticide residues must comply with Regulation (EC) No 396/2005 at code 0639000, “herbal infusions from any other parts of the plant”.
The specification allows water below 18%. We take husk off the beds under 10.5%, because 18% husk in a jute sack in a Red Sea container is how a lot arrives with mould and a smoke-taint cup. The lower figure is a quality decision, not a legal one.
The tariff code, and the honest state of it.
Dried coffee cherry husk is normally declared under Combined Nomenclature code 0901 90 10, “coffee husks and skins”, inside heading 0901. That is the classification we declare and the one our buyers' brokers have used.
It is not beyond argument. A product worked into a preparation can fall to heading 2106, and a customs officer who reads “coffee husks and skins” narrowly may look at 1212 instead. If your compliance depends on the code, ask your authority for a binding tariff information ruling on the actual goods. We will supply whatever documents that needs.
Commercial invoice and packing list
Lot code, net weight, delivered price.
Origin declaration
Species, country, region, harvest and station.
Certificate of analysis
The lot's lab panel against the table above.
Phytosanitary certificate
Issued by Ethiopia's plant protection authority where the consignment requires one. Whether dried, non-viable pulp is caught by Annex XI of Regulation (EU) 2019/2072 is a point we confirm per destination rather than assert here — ask us and we will send what the authority told us in writing.
Entry document
Your border control post issues it under Regulation (EU) 2017/625. Your broker or importer of record files it, not us.
Rimbaud ships delivered, so freight and export documents are ours. Duty and any import VAT at your border remain yours to settle.
Six things. A Rimbaud dossier carries the specification, the origin declaration and the label kit for every lot, plus each laboratory result as it is reported — rows still at the laboratory are printed as pending, never filled in. Your HACCP plan will want all of it filed against the lot code, not against the supplier.
01
The specification
The Table 2 entry above, and your supplier's declaration that the lot meets it.
02
A lot-specific certificate of analysis
Moisture, water activity, ochratoxin A, aflatoxins, heavy metals, PAHs and the five microbiological criteria.
03
The caffeine figure
In mg per 100 ml of the infusion as you serve it, because your label has to carry it.
04
Origin and identity
Species, country, harvest and lot code, traceable to the drying station.
05
Import documents
Commercial invoice, packing list, CN code, phytosanitary certificate where the consignment requires one, and the entry document your border control post issues.
06
Your own label proof
A photograph or artwork file showing the name and the caffeine statement in the same field of vision.
Nothing on this page is behind a form. Forward it.
If your officer has a question this page does not answer, send it to docs@rimbaud.coffee. Ahmed answers with the certificate attached, usually the same day.