Regulation (EU) 2022/47 authorizes the placing on the internal market of dried pulp of coffee berries (species Coffea arabica L. and/or Coffea canephora Pierre ex A. Froehner) for infusions and beverages, as a traditional food from third countries, under Reg. EU 2015/2283 on novel foods. (1)
Dried pulp of coffee berries, traditional foods from third countries
Société de Produits Nestlé SA and Luigi Lavazza SpA have notified the Commission of their intention to release into the EU dried pulp of coffee (or cascara) berries of the species Coffea arabica L. e Coffea canephora Pierre ex A. Froehner and its infusion, as ingredients for infusions and flavored drinks intended for the general population.
The data submitted by the applicants show that the use of dried berry pulp of the mentioned species and its infusion is historically proven in Yemen, Ethiopia and Bolivia, consistent with the requirements of Reg. EU 2015/2283 (art. 14). Member states did not submit reasoned objections within 4 months after notifications were received (Art. 15).
EFSA reports and conditions of employment
EFSA has published two technical reports, concluding that the available data on composition and historical use do not raise safety concerns. The new food is referred to as ‘coffee berry pulp’ and/or ‘cascara (coffee berry pulp)‘ and/or ‘coffee berry pulpinfusion’ and/or ‘dry coffee berry pulp infusion.
There are three permissible conditions of use:
– Coffee berries of the species Coffea arabica L. and/or Coffea canephora Pierre ex A.Froehner for the preparation of infusions,
– ‘coffee, coffee and chicory extracts, soluble coffee, tea, herbal and fruit infusions, coffee substitutes, coffee blends and soluble hot drink blends (and their flavored counterparts).’
– Ready-to-drink flavored and unflavored soft drinks.
Instructions for use and warnings
Instructions for use. ‘Typical brew preparations are prepared with up to 6 g of coffee berry pulp per 100 ml of hot water (> 75°). For coffee berry pulp placed on the market as such for the preparation of infusions, consumer information shall be provided on the preparation‘.
Warnings. The wording ‘High caffeine content. Not recommended for children or women during pregnancy or lactation‘, followed by the caffeine content in mg/100 ml, is prescribed in the same visual field as the designation, if the caffeine content in the product (beverage as is or obtained by reconstitution, according to the instructions provided) is >150 mg/l.
Caffeine, inconsistency with reg. EU 1169/11
A serious inconsistency between this regulation and the Food Information Regulation is noted with regard to the warning ‘high caffeine content‘. Which does not apply to beverages ‘made with abasis of coffee, tea or coffee or tea extract whose name includes the term “coffee” or “tea”‘(EU Reg. 1169/11, Annex III, point 4).
The discrimination of the novel food against other beverages based on coffee and its extracts lacks any scientific justification. And when it even stems from carelessness, it expresses an excess of power of the European Commission that needs to be corrected as soon as possible.
Coffee berry pulp, the campesino tradition in Bolivia
Bolivia expresses less than 1 percent of the world’s coffee production, albeit of high quality. In the early 19th century, production was so low that landowners forbade rural workers, the Yanaconas, to drink coffee. They thus began making a drink from the only part of the berries available to them, the dried pulp.
Sultana, the ‘poor man’s tea,’ was made by infusing the dried pulp-after roasting it in clay pots to intensify its color-with cinnamon, sugar and cloves. A delicacy that farmers from the Yungas, the region where coffee production is concentrated in Bolivia, brought to La Paz where it became famous and is now also used in cooking and baking. (2)
Sultana, agroecology and circular economy
Agroecology still coexists, in Bolivia, with coffee production, which is in fact grown within agroforestry systems with trees, orchards (e.g., citrus, bananas) and other local species. Space is optimized with simplicity by diversifying cultivation into different layers of plants that realize ecosystem services and balances. Greater biodiversity of animals and insects, less impact of pests. (3) A treasure to be preserved and promoted.
In turn, the circular economy is emblematic of Sultana’s production, where a pulp-rich in tannins, phenolic compounds, caffeine, and various amino acids-which would otherwise be lost in the side streams of co-products is enhanced. In fact, the coffee industry uses only 5 percent of the harvested fruit, and waste disposal on plantations has negative impacts on plants and biodiversity, among other things. (4)
Interim conclusions, the value of organic
The possibility of introducing this novel food into the European Union sets the stage for the development of innovative infusions and functional drinks of definite interest. Further studies are recommended to ascertain and demonstrate the benefits associated with the intake of phenolic compounds and other bioactive substances.
The value of organic is essential, precisely to preserve and incentivize the development of integrated agroforestry systems where the use of the bulk of the harvested material allows for increased profitability for campesinos, in addition to the nutraceutical value of the products. (5) Without neglecting, in each case, the strict limits of pesticide residues. (6)
Dario Dongo, with the collaboration of Isis Consuelo Sanlucar Chirinos
Notes
(1) Reg. EU 2022/47 authorizing the placing on the market of dried berry pulp of the species Coffea arabica L. and/or Coffea canephora Pierre ex A. Froehner and its infusion as a traditional food from a third country under Regulation (EU) 2015/2283. https://bit.ly/3FSmET6
(2) María Julia Jiménez, Yara Carolina Fernandez Valdez, Johanna Jacobi, Chahan Yeretzian (2021). Sultana: bonnes pratiques et autres curiosités. Slow Food Bolivia. https://doi.org/10.21256/zhaw-21770
(3) Mil y una formas de consumir la sultana. Slow Food Bolivia. 11.9.19, https://www.slowfood.com/es/mil-y-una-formas-de-consumir-la-sultana/
(4) César Oswaldo González Sosa (2020). Tisana a base de cereza del café: analysis de mercado, desarrollo y evaluación sensorial del producto terminado. Universidad Autónoma de Puebla, México. https://repositorioinstitucional.buap.mx/handle/20.500.12371/14846
(5) Dario Dongo, Andrea Adelmo Della Penna. Biological foods and the immune system, scientific evidence. GIFT (Great Italian Food Trade). 11.4.20, https://www.greatitalianfoodtrade.it/salute/alimenti-biologici-e-sistema-immunitario-evidenze-scientifiche
(6) The levels of pesticides allowed in the subject foods are those set by reg. EC 396/2005 under item 0639000, relating to ‘herbal infusions from other parts of the plant‘
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
