Organically Grown Coffee

I’ve previously written about certified organic coffee and its potential impact on farmers.

I recently purchased an un-roasted, certified organic coffee to roast and sell. However, I am not able to market it as an Organic coffee because I am unable to satisfy the US Department of Agriculture (USDA) requirements to roast the coffee in a facility certified by them.

In this article, I explore what that means.

(I have an audio version of this article or you can just read on)

USDA requirements for Organic coffee

To sell coffee in the United States labeled as “organic,” a coffee roaster must comply with several requirements established by the United States Department of Agriculture (USDA) under the National Organic Program (NOP). These requirements include:

  1. Organic Certification: The coffee must be certified organic by a USDA-accredited certifying agent. This ensures that the coffee is grown and processed according to federal guidelines addressing factors such as soil quality, pest and weed control, and use of additives. (7 CFR Part205, § 205.100)

  2. Sourcing of Organic Beans: The coffee beans must be grown without the use of prohibited substances, like certain pesticides and fertilizers, for three years before the harvest used for organic coffee. (7 CFR Part205, § 205.400)

  3. Roasting Process: The roasting facility must also be certified for handling organic products. This ensures that there is no cross-contamination forbidden products. (7 CFR Part205, § 205.100)

  4. Record-Keeping: The roaster must keep detailed records that document the production, handling, and sales of the organic coffee. (7 CFR Part205, § 205.103)

  5. Labeling: Compliance with organic labeling requirements is mandatory. This includes using the USDA organic seal and proper representation of the organic content (e.g., “100% Organic”, “Organic”, or “Made with Organic Ingredients” depending on the specific content). (7 CFR Part205, Subpart D)

  6. Inspection and Compliance: Regular inspections are conducted to ensure ongoing compliance with organic standards. This includes reviews of the facilities and processes, as well as testing of soil and water. (7 CFR Part205, § 205.403)

  7. Prevention of Contamination: Measures must be in place to prevent contamination of organic beans with prohibited substances or commingling with non-organic products. (7 CFR Part205, § 205.272)

  8. Marketing and Sales: When marketing organic coffee, all claims must be truthful and not misleading regarding the organic status and practices. (7 CFR Part205, Subpart D)

Effects of roasting on a product’s organic integrity

The USDA requires the prevention of contamination of organic beans with prohibited substances or commingling with non-organic products. It is generally understood that in the roastery, this means a dedicated roasting machine for organic coffee. The underlying assumption is that beans rolling around inside a roasting machine or in the cooling tray can be contaminated with forbidden substances. USDA regulations forbid the following:

The use or reuse of any bag or container that has been in contact with any substance in such a manner as to compromise the organic integrity of any organically produced product or ingredient placed in those containers, unless such reusable bag or container has been thoroughly cleaned and poses no risk of contact of the organically produced product or ingredient with the substance used.

That generates a couple of questions:

  1. What is considered an appropriate method of cleaning a roaster? Does a “throw-away” roast of organic coffee suffice?
  2. What forbidden products actually survive the heat of roasting and thus pose a threat?

To explore the second question, I looked into arsenic, one of the forbidden substances.

Arsenic in coffee

The melting point for arsenic is 817°C (1,502.6°F). Its volatilization occurs around 300-600°C (572-1,112°F).(Xu et al., 2022)

Light-roasted beans are typically ejected from the machine at a bean temp around 177°C to 204°C (350°F to 400°F). This roast level would include the very light, Nordic-style of roasts.

Dark-roasted beans are typically ejected from the machine at a bean temp around 224°C to 232°C (about 435°F to 450°F) or higher. This roast level produces dark-brown to black coffee beans, often with a wet sheen of oil on the surface.

The environment or ambient temperatures of the roasting drum can exceed 700°C (1,292°F) by the end of even a light roast, depending on the design of the machine and the time-and-temperature profile applied by the operator.

Therefore the rate at which arsenic is removed from a coffee bean depends on the design of the machine and the roast profile used. Longer and darker roasts have a better chance of removing more arsenic than shorter and lighter roasts.

Arsenic is classified as a class or group 1 carcinogen by the International Agency of Research on Cancer.(Farooq et al., 2016)

It is found naturally in soils and water (fresh and salt water). Sources include volcanic emissions, rock weathering, and discharge from hot springs.(Farooq et al., 2016)

Arsenic is also used in pesticides and fertilizers—though more-so outside the US. In the US, use of arsenic in fertilizers and pesticides is restricted and limited to organic arsenic compounds in a limited number of approved uses.(EPA: Arsenic Compounds, 2021)

Plants take up arsenic through the soil and water, transport it throughout the plant via vascular tissue, and can store or compartmentalize it in organelles within the cells. (Farooq et al., 2016)

Therefore, if arsenic is present in coffee beans, it is present at the cellular level and not necessarily as a coating on the outside of the seed where it could be easily removed or transferred to another surface.

However, when we roast coffee, we impart physical changes that include fracturing of cell walls, increasing the size of micropores, and creating microfissures within the bean. The pressure within the bean increases and begins to force liquified lipids and other compounds to the surface of the bean.(Andrea Illy, 2005)

It is possible that the fracturing, fissuring, and internal pressure inside the beans and the volatilization of arsenic that results from the roasting process releases arsenic into the machine, contaminating the surfaces.

But this generates more questions, such as; at what levels is arsenic released from the beans; at what rate is it then transferred from the surfaces of the machine to beans; and at what rate is arsenic transferred from roasted and ground beans into water during the brewing/extraction phase?

Arsenic and iron

Something I haven’t looked deeply into; certain arsenic molecules and certain iron molecules tend to chemically bond with each other well.(NIH: Arsenic in Drinking Water, 2009) Many of the components of a roaster, especially the drum, contain iron.

The affinity of arsenic (As) with iron (oxyhydr)oxides is known, at least, since 1835, when Robert Bunsen used iron hydroxides to revert As poisonings.

(Souza & Ciminelli, 2023)

Understanding arsenic’s affinity for iron oxide and the levels and nature of iron oxides in a given roaster may help answer the question of how to clean a roaster. If arsenic is adsorbed and fixed in a roaster in this way, I doubt a “throw-away” roast alone would sufficiently clean the roaster. Souza and Ciminelli also state in their article that using iron to fix arsenic does not get arsenic levels in contaminated water down to safe levels.(Souza & Ciminelli, 2023)

Implications for farmers

One of the great points recently made when I was having this conversation with another coffee professional is; what is the implication for smallholders who can’t necessarily afford the time or the expertise to produce organically? Also, how does the money flow and who really benefits from organic certification?

I think my case represents an interesting one. I purchased a certified organic intermediate product (the un-roasted coffee) solely because of its origin, its sensorial attributes, and its cost, in that order. I wanted a coffee from Oaxaca, Mexico that I could present as a balanced, clean, chocolate-forward coffee at a cost from which I could make a profit.

I don’t add an organic premium to my price because I can’t legally market it as certified organic—even though I paid a premium when I bought a certified organic green coffee. The premium I paid went to the distributor who sold me the coffee. Presumably, that distributor paid a premium to the co-op when they bought it.

Ultimately, in my case, the certified organic status was not what sold the intermediate product. It was the origin, quality, and cost.

See also: Ethical Consumption

Is the quality a result of being organically grown? I’m sure it has an effect—even if that effect is only in the fact that it was thoughtfully produced following a strict and regimented process.

Because I am not selling the Mexico Oaxaca coffee as an organic coffee, I potentially become the ‘last stop’ for any benefits to the producers that may result from it being marketed as certified organic. People looking for an organic coffee won’t likely find what I’m selling and those who do may choose not to buy it because I’ve broken its organic intengrity. But how impactful is that when I’ve already bought the intermediate product? Any money as a result of me buying it has already flowed through the system. Of course, more demand for my version would likely generate more purchases of the intermediate product by me, so that is certainly one benefit.

Because it is so difficult to calculate the net premium for producers, maybe it’s better to think of the premium as a way to subsidize producers’ efforts to improve living conditions and help improve use of natural resources.

See also: Organic Coffee

Implications for the end-user

The way I have positioned my offering of a coffee that was organically grown is this; the buyer is buying a coffee that was grown without the addition of forbidden products. Their purchase could be considered an indirect reward to those farmers who put in the extra time, money, and effort to produce a certified organic product.

Have I contaminated the product by roasting it in a machine that also roasts non-certified organic products? Probably. But the level of contamination is not known and its effects on health are not known. How much arsenic is naturally present in a certified organic coffee? That isn’t tested as part of the certification process. The certification process does not test the levels of any contaminant.

If the buyer’s goal is to financially support and incentivize farmers to farm organically, then how the coffee is ultimately roasted has no impact on that goal. Loosening the roasting requirements and therefore making it easier to roast and sell certified organic coffee may actually increase sales.

If the buyer’s goal is to consume coffee that contains less or none of the forbidden substances, then the roasting process likely impacts that goal. Maintaining organic integrity in this case is important and regulation of the roasting process is likely beneficial.


  1. Xu, F., Chu, M., Hao, C., Zhou, L., Sun, X., & Gu, Z. (2022). Volatilization characteristics and relationship of arsenic and sulfur during coal pyrolysis. Fuel, 315, 123223.
  2. Farooq, M. A., Islam, F., Ali, B., Najeeb, U., Mao, B., Gill, R. A., Yan, G., Siddique, K. H. M., & Zhou, W. (2016). Arsenic toxicity in plants: Cellular and molecular mechanisms of its transport and metabolism. Environmental and Experimental Botany, 132, 42–52.
  3. Andrea Illy, R. V. (Ed.). (2005). Espresso Coffee: The Science of Quality. Academic Press; 2nd edition.
  4. Souza, T. G. F., & Ciminelli, V. S. T. (2023). Arsenic removal and fixation by iron (oxyhydr)oxides: what is new? Current Opinion in Environmental Science & Health.

Michael C. Wright

Michael is a licensed Q Grader, licensed Q Processor Pro, an Authorized SCA Trainer (AST), and most recently, a graduate with a degree in horticulture and a concentration in horticultural business management. He has over ten years experience in the coffee industry operating on both the supply and demand sides of the value chain.