July 23, 2018
Home < About Kona Coffee < Changes to Coffee Standards -Public Hearing- 9 Questions and Concerns for Farmers

Changes to Coffee Standards -Public Hearing- 9 Questions and Concerns for Farmers

Hearing Date and Time and Place
October 10, 2013- Thursday at 9 am
West Hawaii Civic Center, Com. Meeting Hale Bldg. G, 74-5044 Ane Keohokalole Highway

We need your Testimony.  
HDOA Requirements for Testimony: … submit comments orally or in writing. Written testimony may be submitted prior to the hearing via postal mail to the Quality Assurance Division c/o Department of Agriculture, 1428 S. King St., Honolulu, HI 96814, or via fax at (808) 832-0683, or via email at HDOA.QAD@hawaii.gov. Please include the word “testimony” and the subject matter.

To: KCFA Members

Earlier this month the Hawaii Department of Agriculture (HDOA) issued a notice of public hearing on extensive proposed amendments to the administrative rules relating to coffee standards. In addition to hearings at 4 other locations, there will be a hearing on Thursday, October 10, 2013, at 9:00 am in Building G of the West Hawaii Civic Center in Kailua-Kona.

Copies of the HDOA’s “Notice of Public Hearing” and of the “Proposed Amendments” are posted on the KCFA website.

These proposed amendments may have very significant impacts on many Kona coffee farmers. Please take the time to review the proposed amendments. It is important that every coffee farmers with concerns or questions about the proposed changes attend the hearing and participate.

Below for your review is a series of questions and observations. If you have additional questions or observations, please get those to info@konacoffeefarmers.org with the subject <HDOA Proposed Changes>

Again, please plan to attend and participate in the hearing.


1—Adverse Affect on “Home Roaster” Sales

The proposed revision to Section 1-143-3 eliminates the definition of “Wholesale Quantity” of green coffee from the rules.

It appears that this will eliminate the HDOA’s practice of many years of exempting sales of less than 10 pounds of green coffee from certification requirements.

This exemption for sales of less than “Wholesale Quantities” of green allowed many Kona coffee farms to build a thriving business of selling small packages of Kona green coffee to “home roasters” on the Mainland. The popularity of home roasting green has been growing rapidly. There are reports that for some Kona farms their sales of green coffee of 10 pounds or less amounts to more than half of their coffee sales.

If the less than “Wholesale Quantity” exemption is eliminated, direct sales to home roasters may become impractical. The new and burdensome regulations intended for large commercial sales would, for example, appear to require farmers to affix to even a one pound package of green a 2” x 4” tamper-proof tag, light in color, made of a material that resists tearing, with a blank area at least two inches by two inches.

Why is the HDOA acting to eliminate the less than Wholesale Quantity exemption? Why is the HDOA creating burdens for small-scale coffee businesses? Have there been problems with such sales? If so, what have the problems been—and how does this change address such problems?

2—Fees (Section 4-143-2 (k) and (l)

What is the basis for an increase in the charge for facsimile copies of an HDOA certificate from $1/page to $48/page? What was the basis for increasing the inspection fee from $31/hour to $48/hour?

For many years small-scale coffee farmers have suggested to the HDOA that a per pound inspection fee would provide fairness and equity for farmers—as compared with the much lower per pound fees paid by large corporate processing operations. If a “per pound” fee is properly set to cover HDOA costs, there would be no adverse economic impact on the HDOA. Such a “per pound” fee system would fairly distribute the costs of inspection services.

3—Deceptive Coffee Grade Descriptions

The “quality” of coffee is a subjective judgment as to the desirability of the taste of brewed coffee in the cup. Such a measure of quality does not necessarily have a relationship to the size or the appearance of green beans.

The current and the proposed “grade” classifications used by the HDOA give the false impression that the grade classifications are measures of quality (that is, Kona “Extra Fancy” tastes better than “Fancy” or “No. 1” or “Prime”). The grades, however, primarily indicate bean size, not the quality of the brewed coffee in the cup.

For years professional cuppers—and HDOA inspectors–who taste coffee for a living have observed that there is no detectable quality difference between coffee from the same farm brewed from “Extra Fancy” and “Prime”. They have also observed that the defect element of the Hawaii coffee grade system—at least for Prime and above—has no discernable effect on taste quality. If the Hawaii coffee grades primarily indicate size of beans, then the names of the grades should describe size (for example, “Large Size Beans”, “Medium Size Beans”, “Small Size Beans”)—and not imply quality differences in brewed coffee.

Even though “Kona Prime” continues to offer the same taste for brewed coffee that made Kona coffee world famous, continued use of the current grade names falsely implies that the quality of Kona coffee has declined because CBB damage reduces the amount of Kona meeting the “higher” grades like “Extra Fancy” and “Fancy”. This is a point clearly illustrated by the Greenwell Farms Inc.’s. CBB White Paper of July 2013 (posted at www.konacoffeefarmers.org). GFI’s green bean market has been adversely affected by the perception of buyers that GFI’s inability in 2012/2013 to deliver “Extra Fancy” or “Fancy” grades indicates a decline in “quality” of Kona coffee—when, in fact, the traditional quality taste of brewed Kona coffee is readily available from Kona “Prime” which GFI had available in abundance.

The HDOA should take steps to eliminate the false impressions generated by the names of its grade classifications.

4—Pinholes Caused By CBB

In section 4-143-6(i) the proposed amendments add new defect score for beans affected by pinholes caused by CBB. Does the HDOA have data indicating that such pinholes adversely affect the taste of brewed coffee in the cup? If so, what does that data indicate?

5—Non-Sale Transport of Coffee Within the Region

The application of Section 4-143-12 appears to place a significant record keeping burden on Kona farmers for transport of cherry, parchment, and green in instances where no sale is involved. For example, many Kona farmers make many trips each year transporting cherry, parchment, and green to and from mills where the coffee is processed and then returned to the farm with no sale of the coffee involved. What is the purpose of requiring the making and storage of detailed records of this transport for 6 years? Shouldn’t the transport of coffee within the region when no sale occurs be exempted from this requirement?

6—HDOA Affidavit of Origin Form

The proposed changes to Section 1-143-1(a) add new language describing a “geographic region statement” to be provided by the HDOA that may be used to document the origin of coffee. Is this form the same as the form emailed to KCFA by the HDOA in September 2012, entitled “Affidavit of Hawaii–Grown Coffee Origin—Form C-6 (8/12)”? If so, will the HDOA sanction the use of this form by Hawaii coffee farmers to represent “origin” to foreign buyers?

7—Entry of Public or Private Premises or Vehicles

Section 4-143-8 purports to provide authority for HDOA inspectors to enter any public or private premises and any vehicle of transport—with no reference to a warrant or probable cause. Has this provision been approved by the Hawaii Attorney General’s office as meeting constitutional standards?

8—Certification of Origin Only

Over the years the HDOA has offered a cost-effective option used by many small-scale coffee farmers for “certification of origin only”—with no express grade determination or cupping and a statement of Kona origin with the indication that the coffee meets grade standards of Prime or better. Does the proposed elimination of current Sections 4-143-2(f) and (g) indicate that the HDOA will no longer make this service available to small-scale Kona coffee farmers? If so, what are the reasons for not continuing this service?

9—Increase in Defects Limits for Prime

In addition to changes of defect limits for other grades, Section 4-143-6(e) increases the defect limit for the “Prime” grade from 15% to 20%.  Does the HDOA have data indicating that this increase does not affect the quality of the taste of brewed coffee in the cup?  If so, what is the data?  Has the HDOA made any determination whether the quality of the taste of brewed “Extra Fancy” Kona coffee would be diminished by a similar 20% defects limit?




  1. sent to KCFA by a KCFA Member…

    These new rules have to be seen in context with HB280, 2012
    Makes the offense of false labeling as to the geographic origin of Hawaii-grown coffee a class C felony. Authorizes the department of agriculture to adopt administrative rules relating to the inspection and documentation of the geographic origin of Hawaii-grown green coffee beans. Removes the requirement that all Hawaii-grown green coffee beans shall be inspected and certified by the Department of Agriculture unless otherwise specified by rules of the Department. Requires that no Hawaii-grown coffee beans shall be shipped outside the area of their geographic origin unless they have been marked with or contain documentation of geographic origin approved by the department of agriculture. (HB280 CD1)”

    (e) The requirements of this section shall apply to both intra-state and export sales and distribution of Hawai’i grown green coffee.
    The deletion of ‘green’ applies all administrative rules to roasted and natural coffee as well.

    §4-143-2 Inspection and Fees.
    Are the collected fees going to a special coffee fund or the general fund? If it is a special fund, who audits it? What gets paid from it?

    (b) Inspection for certification of green coffee or natural coffee for origin
    Origin certification has to be reinstated as an affordable alternative for small growers.

    Except for (1) Green coffee packed in less than wholesale quantities and labeled for retail sale…
    Has to be reinstated to the status quo of up to 10 LBS per shipment

    (c) should therefore be reinstated as well.

    §4-143-3 Definitions
    “Damage” means any defect (insert: detectable by the naked eye and not by any optical magnification device as it is industry standard) which materially…

    §4-143-6 Standards for grades of green coffee.
    Ka’u coffee should have the same standards as Kona coffee enjoys under the “Ka’u and not the Hawaiian Island name (Ka’u Extra Fancy, Ka’u Fancy, etc).

    (Replace eliminated section with: The mandated calibration dates for the official moisture meter shall be posted in the inspection office.

    Former (j) A bean that is affected by no more than two pinholes detectable by the naked eye and not by any optical magnification…

    A bean that is affected by greater than two pinholes detectable by the naked eye and not by any optical magnification…

    Former (k) Size classifications for green coffee shall be as follows:
    For Type I green coffee;
    The lowering of sizing is detrimental to the known quality of Kona coffee by green brokers and roasters. The CBB problem has nothing to do with sizes of beans.

    [§4-143-7 Minimum export requirement.
    Reinstate this paragraph as it hinders the sale of OFFGRADE coffee as Hawaiian coffee or even Kona coffee.

    [4-143-10 Coffee Quality Certification Program

    This program has to be redefined but not eliminated! It was originally thought out to prevent delays for large contract shipments and to give autonomy to well-run mills. The refusal of the current inspector to accommodate shippers the day before or after when their assigned certification day falls on a holiday, makes this very necessary (memo of Sept 2010). The workload could be significantly reduced for the inspection office without loss of service to the mills or shippers.

    The new CQCP can work similar to public notaries. A few trained and qualified part time certifiers should be able to be called upon for inspection & certification services by mills and shippers. The part time certifiers would have a log book, seal, moisture meter, and be able to use available roasting facilities for cupping purposes. Being a Q-Taster or being a trained coffee inspector could be asked as requirements. The fees should be higher than the official inspection fees and could be split btw the HDOA and the part time certifier.

    HB 280 was supported by many in the coffee industry as the turnaround times for mandatory certification by the Captain Cook inspection office was getting too cumbersome because of understaffing. Sales were lost especially around the yearend holidays. A more dynamic certification protocol with trained and supervised, independent, part time certifiers would rectify this situation immediately and the mandatory certification for wholesale quantities of green and natural Hawaiian coffees can be reinstated.

  2. It might be useful to ask some broader, principle-based questions at the outset, such as:
    – “What are the specific objectives of DOA that drive the proposed amendments?
    – “Did addressing those objectives consider the differential financial, logistical and other practical impacts on small, family-scale farms and farmers?
    – “Does DOA have a new policy of regulating a two-acre coffee farm the same as a 200 acre coffee farm? If so, have the reasons and proof of necessity, in the form of facts and statistics, been set forth in writing that farming professionals are allowed to see and review in public?
    – “Would DOA please add these new regulatory objectives, policies and summary facts of justification to the first paragraph of the Rules so that all farmers and farm suppliers can understand why you have proposed to do this to the Kona farming community?

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