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What requirements should fresh fruit or vegetables comply with to be allowed on the European market?

Takes 9 minutes to read

Europe is very demanding about food safety, which is why dealing with fresh agricultural products is subject to various legal and other buyer requirements. But there are also opportunities to distinguish yourself by applying additional or niche market quality standards. This document provides an overview of the most common requirements and standards, as well as the specific requirements that apply to niche markets such as organic or fair trade fruit and vegetables.


1 . With which legal and non-legal requirements must my product comply?

When exporting fresh fruit and vegetables to Europe you have to comply with the following requirements. For a full list of requirements, please consult the EU Trade Helpdesk where you can select your specific product code under chapters 07 and 08.

Limited use of pesticides

To avoid health and environmental damage, the European Union has set maximum residue levels (MRLs) for pesticides in and on food products. Products containing more pesticides than allowed will be withdrawn from the European market.

Note that buyers in several Member States such as the United Kingdom, Germany, The Netherlands and Austria, use MRLs which are stricter than the MRLs laid down in European legislation. Supermarket chains are the strictest and demand 33 to 70% of the legal MRL.

More and more buyers ask for upfront information about your pesticide spray programmes and records. Shipments are checked before it is sent to the retailer. Pesticide management takes a lot of responsibility from your part as a producer or exporter.

Tips:

  • Use the EU Pesticide Database to find out the MRLs that are relevant for your products. You can select your product or a pesticide and the database shows the list of associated MRLs.
  • Apply integrated pest management (IPM) to reduce the amount of pesticides. IPM is an agricultural pest control strategy, which is also part of a GlobalGAP certification. It uses natural control practices such as the application of pests’ natural enemies. The fewer chemicals you use, the better your marketing position will be for export to Europe.
  • Always check if your buyers have additional requirements on MRLs and pesticide use.

Control of food imported to the EU

To ensure food safety and avoid environmental damage, the European Union has restricted the use of certain chemicals (MRLs) in several Regulations and Directives. Therefore, your products will be subjected to official controls. These controls are carried out to ensure that all foods marketed in the European market are safe and in compliance with all applicable regulatory requirements.

There are three types of checks:

a) Documentary checks
b) Identity checks
c) Physical checks

In the event of repeated non-compliance of specific products originating from particular countries, the European Union can decide to carry out controls at an increased level or to lay down emergency measures. Controls can be carried out at all stages of import and marketing in Europe. However, most checks are done at the points of entry.

For importers of fresh fruit and vegetables, the traceability of products is compulsory. To fulfil this obligation, European importers will require you to provide proof of the origin of all fruits and vegetables with a Bill of Lading, phytosanitary certificate, packing list and custom documentation.

Tips:

  • Familiarise yourself with the procedures. Failure to follow the right procedures could cause decrease and delay of orders, increase costs, and result in actions by European enforcement authorities.
  • Make sure that the accompanying documents (such as bill of lading) correspond exactly with the food products contained in the consignment, including indicated volumes, classes and sizes, number of pallets and boxes and the names of growers.
  • Check the documents needed for customs clearance in the European Union.

Marketing standards

European legislation sets general and specific marketing standards for the minimum quality and the minimum maturity of all fresh fruit and vegetables.

There are specific marketing standards (MS) for the fresh fruit and vegetables listed below. These products must be accompanied with a certificate of conformity with each consignment. These certificates can be issued by the European control bodies and in some cases in the country of origin. A sample certificate of conformity can be found on page 115 in Annex III to EU Regulation No 543/2011.

  • apples
  • citrus fruit
  • kiwi fruit
  • lettuce
  • peaches
  • nectarines
  • pears
  • strawberries
  • sweet peppers
  • table grapes
  • tomatoes

Fresh products that are not covered by a specific marketing standard have to comply with:

Operators are free to choose which to use.

Imports of products intended for processing are not subject to compliance with the EU marketing standards. However, these must be clearly marked by the pack with the words "intended for processing" or other equivalent wording.

Tips:

  • Check which standards are applicable to your product and make sure your products and the necessary documentation are in order. By filling in your export details at the EU Trade Helpdesk (product codes in chapter 7 or 8) you can find the contact details of the official authorities by following the link on marketing standards.
  • Check out the Codex Alimentarius published by the Food and Agriculture Organization (FAO) with marketing standards for fresh fruits and vegetables.

Labelling and packaging

Food placed on the EU market must meet the legislation on food labelling.

Cartons of fresh fruit or vegetables must mention the following particulars:

  • The name and the address of the packer or the dispatchers
  • The name of the produce (if the produce is not visible from the outside of the packaging)
  • The country of origin
  • The class and size (referring to the marketing standards)
  • Lot number for traceability or GG number if certified GlobalGAP (recommended)
  • Official control mark to replace name and address of the packer (optional).

For consumer and pre-packed fresh products you must add the name and the address of a seller established within the European Union with the mention ‘Packed for:’ or an equivalent mention.

Note that there is also non product specific legislation on packaging and liability that apply to all goods marketed in the EU.

Tips:

  • Make sure that all mandatory information is mentioned, but also think of other useful information such as logos of importers or certificates.
  • For pre-packed fruit and vegetables for consumers, read the full regulation concerning labelling for foodstuffs at the EU Export Helpdesk.

Plant Health

Fruit and vegetables exported to the European Union must comply with European legislation on plant health. The European Union has laid down phytosanitary requirements to prevent introduction and spread of organisms harmful to plants and plant products in Europe. These requirements are managed by the competent food safety authorities in the importing and exporting countries.

Tips:

  • Verify with the National Plant Protection Organisation or food safety authority in your country if and under which conditions you can export fresh fruit and vegetables to Europe. These authorities normally work with international standards, but always check with your buyer as well.
  • Read more about plant health at the EU Trade Helpdesk. A model phytosanitary certificate can be found through Annex VII (p.170) of the Plant Health Directive.

Contaminants

Contaminants are substances that have not been intentionally added to food, but may be present as a result of the various stages of its production, packaging, transport or holding. To avoid negative impact on the quality of food and risks to human health, the European Union has set limits for several contaminants. Especially the limits for nitrate (in spinach and lettuce) and metals (cadmium, lead, mercury and inorganic tin) are relevant for fresh fruit and vegetables.

Tips:

2 . Which additional requirements are buyers likely to impose?

European buyers often have specific requirements, depending upon their sales channels and product segments. Common buyer requirements include the following:

Certification as guarantee

As food safety is a top priority in all European food sectors, you can expect most buyers to request extra guarantees from you in the form of a certification. Many buyers (for example traders, food processors, retailers) require the implementation of a food safety management system based on Hazard Analysis and Critical Control Point (HACCP).

The most commonly requested food safety certification scheme, essential for exporting fresh produce to Europe, is GLOBALG.A.P. This is a pre-farm-gate standard that covers the whole agricultural production process, from before the plant is in the ground to the non-processed product (processing not covered). GLOBALG.A.P. has become a minimum standard for most European supermarkets.

In addition to GLOBALG.A.P., other food safety management systems can be required as well. Almost all buyers on the North-Western European market will require you to comply with the British Retail Consortium (BRC) global standards, which are widely applied as a standard for hygiene and safety. On the European mainland, buyers sometimes require you to comply with the IFS food standard, Safe Quality Food (SQF) programme, FSSC22000 or other industry-developed standards.

All the mentioned management systems are recognized by the Global Food Safety Initiative (GFSI), which means that they are generally accepted by the major retailers. Compliance with certification schemes varies between countries, trade channels and market situations. Buyers can be more lenient during supply shortages.

Tips:

  • Read more on the different Food Safety Management Systems and hygiene standards at the Standards Map or consult the Global Food Safety Initiative (GFSI). It contains a benchmark for relevant additional standards.

  • Become familiar with GLOBALG.A.P. as your EU market entry preparation is likely to include GLOBALG.A.P. certification.

  • Check with your buyer about their preferred food safety management system and certification as these are often buyer specific.

Quality specifications

Quality is integrated in food safety requirements and marketing standards. At the same time, buyers use their own specific quality specifications. The importance of quality is not to be underestimated. There are many claims from buyers on quality of fresh fruit and vegetables because they are perishable products. In this fast moving and perishable market ‘sudden’ decisions are taken, such as ‘dumping’ your products at very low prices when quality starts to deteriorate.

The standards that are most widely used by EU importers and traders are those developed by the United Nations Economic Commission for Europe (UNECE) and the Codex Alimentarius Commission (CAC). Note that these standards remain subject to legally required marketing standards.

Tips:

  • Agree with your buyer on important topics:
    - Delivery and payment terms
    - Specifications
    -The certification scheme(s) that will be used
  • Be on top of quality! If you are not sure, do not send your products, but rather look for (local) alternatives. If you decide to ship your products anyway, be transparent about the quality and discuss this on beforehand with your buyer.

3 . What are the requirements for niche markets?

In addition to the official and common requirements, specific requirements apply to niche markets such as organic or fair trade fruit and vegetables.

Social and environmental compliance

There is growing attention for the social and environmental conditions in the producing areas. Most European buyers have a code of conduct which they will expect you to adhere to. For most fresh fruit and vegetables social compliance is important, although product quality is top priority.

Initiatives and attention relating to Corporate Social Responsibility (CSR) vary across the various parts of Europe. In the Eastern part of Europe, fewer buyers require social compliance, while in Western Europe some multinationals even have their own codes of conduct. Examples include Unilever’s Sustainable Agriculture Code and Tesco’s nurture accreditation.

Buyer initiatives which have an impact on you as a supplier in terms of social compliance include:

Examples of social or sustainable labels for fresh fruit and vegetables are:

Fair Trade labels are not on the top of the list of buyers because of the complex requirements and high costs. GRASP, which is part of GlobalGap, is more accessible and gaining in importance.

Tips:

  • Consult the ITC Standards Map for the different labels and to learn about differences between fair-trade labels.
  • Check your company’s current performances. For example by doing a self-assessment on the BSCI website (search for “self assessment”).
  • Check with your buyer which social protocol they request. If you choose to certify your production with fair trade label, find a specialised European buyer who is familiar with these products.

Organic, a growing niche market

An increasing number of European consumers prefer food products that are produced and processed using natural methods. Organic fruit and vegetables have a higher cost of production, but are also better valued on the European market.

To market organic products in the European Union, you have to use organic production methods, which are laid down in EU legislation.

Furthermore, you have to use these production methods for at least two years before you can market the fruits and vegetables as organic.

You (or your importer) must apply for an import authorization from EU organic control bodies. After being audited by an accredited certifier, you may put the EU organic logo on your products, as well as the logo of the standard holder, for example Soil Association (especially relevant in the UK), Naturland (Germany) or BioSuisse (Switzerland). Each standard is slightly different, but they all comply with the EU legislation on organic production and labelling.

Tips:

  • Assess the organic market potential for your specific product. Inform yourself well, because implementing organic production and becoming certified can be expensive and time-consuming.
  • Find importers that specialise in organics through trade fairs such as Biofach or Fruit Logistica and company directories such as the International directory of organic food wholesale & supply companies (Organic-bio) and the International Trade Centre (ITC). Organic importers often play an active role in advisory and guidance of producers.
  • Read more about organic farming on an informative website of the European Commission on organic farming.

New legislation for organic

The European Commission made a proposal for a new organic legislation in 2014, but it is not clear into what extend it has been actually implemented. Part of the objective is to simplify the old organic legislation and improve electronic certification systems. This would also benefit the consumer confidence in organics through better traceability, reduced fraud, less administrative burden and availability of statistics on organic import.

In general, organic regulation and testing are expected to become stricter. Traces of unauthorized substances can result in a direct withdrawal of an organic certification. According to IFOAM EU this will be a concern for exporters and producers from “developing countries with completely different meteorological, environmental and structural conditions comply with the rules made for European conditions”.

There is also some criticism from the Organic Research Centre. They argue that the details and consequences of the harmonization of the legislation are not worked out sufficiently.

Tip:

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