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

Exporting fresh fruit and vegetables to Europe requires you to keep high standards of food safety and quality. Responsible social and environmental conduct has also become a precondition to do business, and buyers often ask for certifications as a guarantee. However, there are also opportunities to distinguish yourself by applying additional or niche market standards.

1. What are mandatory requirements?

When exporting fresh fruit and vegetables to Europe, you have to comply with the requirements for food safety and product quality. For a full list of legal requirements, consult My Trade Assistant of Access2Markets of Access2Markets, where you can select your specific product code under Chapters 07 and 08.

Limited use of pesticides

According to The Rapid Alert System for Food and Feed (RASFF) Annual Report 2020, pesticide residues were the main reason for food safety notifications for fruits and vegetables in Europe.

To avoid health and environmental risks, the European Union (EU) 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 Products containing more pesticides than allowed will be withdrawn from the European market. MRLs can become stricter with new insights from Europe’s food safety authorities.

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 maintain the highest standards and generally demand 33% to 100% of the legal MRL. The German discounter Lidl is one of the strictest, with a limit of 33% of the EU legal standard for single active substances.

For importers, it is the easiest to work with the highest (Lidl) standard to maintain flexibility. Supermarkets tend to follow their competitors, and several of them may still tighten their requirements. Some of the supermarket chains impose financial penalties when a violation of their limit is detected.

Pesticide management takes a lot of responsibility on your part as a producer or exporter. More and more buyers ask for upfront information about your pesticide spray records, and shipments are checked before they are sent to the retailer. For future business, you must take into account that your responsibility as an exporter will play an important role as retail chains put more pressure on their suppliers.

Chlorpyrifos

One of the major problems in 2020 was residues of Chlorpyrifos. Chlorpyrifos and chlorpyrifos-methyl are insecticides used to control insect pests on a range of crops. The EU decided not to renew the approvals of chlorpyrifos and chlorpyrifos-methyl. Around October 2020, the new lowered MRL became applicable both to food produced in the EU and to imports.

Avoiding contaminants

Contaminants are substances which have not been intentionally added to food but which may be present as a result of the various stages of its production, packaging, transport or holding. Similar to the MRLs for pesticides, the European Union has set limits for several contaminants (see table 1). For fresh fruit and vegetables, your main concerns will be the contamination of lead, cadmium and nitrate (mainly for spinach, lettuce and rucola).

The rules for fruit and vegetables that are processed (for example, dried fruit or juices) may differ. As the regulation is also regularly updated, you must keep yourself up to date. New insights into or threats to food safety and contaminants can always lead to adjustments in the regulations.

Note that the maximum levels for fresh fruit and vegetables, in particular for cadmium, have become more specific after a revised regulation in August 2021 (see table 1).

Table 1: The current limits for lead and cadmium in fresh fruit and vegetables (January 2022)

Source: REGULATION (EC) No 1881/2006

Microbiological criteria for pre-cut fruit

When supplying pre-cut fruit and vegetables, you must take into account microbiological hazards such as Salmonella and E. coli. Salmonella must be absent throughout the shelf life of a freshly cut product. E.coli should be practically absent during the manufacturing process.

European Regulation (EC) No 2073/2005 will provide you with information about testing methods, sampling plans and measuring limits.

Plant health and phytosanitary regulations

Fruit and vegetables exported to the European Union must comply with European legislation on plant health. The European Union has laid down rules for the Trade in plants & plant products from non-EU countries to prevent the 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.

Most importantly, your home country needs to have a National Plant Protection Organization (NPPO), or official IPPC contact point. Such an authority must be able to declare a region pest-free or to perform checks on specific areas and product treatments. Otherwise, you will not be allowed to export to Europe.

Most fresh fruit and vegetables are subject to health inspections and require phytosanitary certificates prior to shipping.

• A phytosanitary certificate is needed for: Most fruit and vegetables. You can find these products and their Latin names in Annex XI, Part A and Part B of Regulation (EU) 2019/2072.
• No phytosanitary certificate is needed for: Pineapple, banana, coconut, durian and dates. See Annex XI, Part C of Regulation (EU) 2019/2072.
• Special requirements are needed for: A large number of fruit and vegetables originating outside the European community, such as leafy vegetables, potatoes, tomatoes, peppers, citrus fruit, stone fruit, berry fruit, apples, pears, mangoes, avocados, leaf celery and basil, among other things. Special requirements may include inspections, treatments or declarations that certain pests are absent. Root and tubercle vegetables require an official statement that the consignment or lot does not contain more than 1% by net weight of soil and growing medium. See Annex VII of Regulation (EU) 2019/2072.
• Special requirements for protected zones: are in place for certain products and regions, such as onions, carrots, potatoes, grapes (Cyprus) and citrus fruit (Malta). See Annex X of Regulation (EU) 2019/2072.
• Prohibited from entering the European Union: mainly applies for potatoes from certain origins. See Annex VI of Regulation (EU) 2019/2072.

Phytosanitary certificates are provided by plant health authorities and must guarantee that a product is:

1. Properly inspected;
2. Free from pests - free from quarantine pests; within the requirements for regulated non-quarantine pests and practically free from other pests;
3. In line with phytosanitary requirements - laid down in Regulation (EU) 2019/2072

Countries, authorities and exporters that are not prepared for the strict pest control will have difficulties to export their fresh fruit and vegetables to Europe. As an exporter, you must stay up to date with the rules and work closely with the food safety authority in your country.

Table 2: Overview of EU regulations concerning protective measures against pests

Marketing standards

European legislation sets general and specific marketing standards for the minimum quality of fresh fruit and vegetables. A marketing standard determines the characteristics of “Extra Class”, Class I and Class II products, the minimum maturity, the different size codes, and the allowed tolerances in quality and size. Over the years, the marketing standards have been aligned with the UNECE standards for fresh fruit and vegetables. These standards provide guidance to businesses and generally change little.

The preferred sizes sometimes vary between the different European markets, but the quality is generally “Extra Class” or Class I. You might find a market for Class II products in some Eastern European countries, the processing industry or less formal segments.

There are specific marketing standards for the fresh fruit and vegetables listed below. You can find these in Annex I, Part B of EU Regulation No 543/2011:

• Apples
• Citrus fruit
• Kiwi fruit
• Lettuce, curly and broad-leaved endives
• Peaches and nectarines
• Pears
• Strawberries
• Sweet peppers
• Table grapes
• Tomatoes.

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

• the general marketing standards (GMS) in Annex I, Part A of EU Regulation No 543/2011; or
• the applicable UNECE standard (sometimes less strict than the EU standard).

Operators are free to choose whether to work with the EU (GMS) or UNECE standard. If your product is not covered by any specific European standard, you can also check for similar standards in the Codex Alimentarius. For visual examples and interpretation of marketing standards of several fruit and vegetables, you can refer to the OECD Fruit and Vegetables Scheme.

Conformity checks are carried out selectively by control bodies to ensure compliance with the marketing standards. These checks are based on a risk analysis and concentrate on traders most likely to have goods that do not comply with the standards. Controlled fruit and vegetables are accompanied with a certificate of conformity. An example of a certificate of conformity can be found in Annex III to EU Regulation No 543/2011. Non-EU countries may carry out their own conformity checks. Countries that are currently authorised to do their own conformity checks include Kenya, India, Israel, Morocco, Senegal, South Africa and Turkey.

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

Control of food imported in the European Union

To ensure food safety and avoid environmental damage, your products will be subjected to official controls. These controls are carried out to ensure that all foods marketed on the European market are safe and are in compliance with all applicable regulatory requirements.

Compulsory plant health checks are carried out on all plants and plant products coming from non-EU countries (see Annex XI, Part C of Regulation (EU) 2019/2072) for:

• Phytosanitary certificates and documents to ensure that the consignment meets EU requirements;
• Identity to ensure that the consignment corresponds to the certificate;
• Inspection to ensure that the consignment is free from harmful organisms.

EU countries collect a fee for the documentary, identity and plant health checks, to be paid by the importer or their customs representative. This fee is usually settled with the account of sales and final payment of the buyer.

In case of repeated non-compliance of specific products originating from particular countries, the European Union can decide to carry out more regular controls or 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, you must document the sources of your product, and be able to hand over proof of origin for all fruits and vegetables. Proof of origin is also necessary for importers to get beneficiary tariffs that are common for imports from developing countries with a Generalised Scheme of Preferences (GSP).

Figure 1: Label of oranges with traceability code

Source: European Commission - Factsheet Food Traceability

Labelling and packaging

Food placed on the EU market must meet the legislation on food labelling. Trade packages and cartons of fresh fruit or vegetables must mention the following particulars:

• Name and address of the packer or dispatcher;
• Name and variety of the produce (if the produce is not visible from the outside of the packaging);
• Country of origin;
• Class and size (referring to the marketing standards);
• Lot number for traceability or GGN if certified GLOBALG.A.P. (recommended);
• Official control mark to replace name and address of the packer (optional);
• Post-harvest treatment; for example, anti-moulding agents added in a post-harvest treatment of citrus fruits must be mentioned on the trade package;
• Organic certification, including name of inspection body and certification number (if applicable).

Figure 2: Example of printed packaging for export

Source: OECD (2020), Mangoes, International Standards for Fruit and Vegetables, OECD Publishing, Paris.

When fruit or vegetables are processed or directly packed for consumption, you must include appropriate labelling for consumers:

• Common name of the product;
• Full name of the country of origin;
• Name and address of the producer, packer, importer, brand owner or seller (retailer) in the EU who places the product on the market, and the wording “Packed for:”, if applicable;
• Net content in weight;
• Minimum durability – a best-before date (on all processed fruit and vegetables, such as freshly cut);
• Producer identification or lot number;
• List of ingredients (if applicable), including additives and post-harvest treatment;
• Allergenic declaration (if applicable);
• Declaration of nutritional value (when mixed with other foodstuffs);
• Packed in protective atmosphere, if applicable;
• Additional information about quality class, size, variety or commercial type and post-harvest treatment on the product labelling or in close proximity (on the shelf) for products with specific marketing standards.

Figure 3: Example of freshly cut fruit

Source: ICI Business
Figure 4: Example of pre-packaged avocados

Source: ICI Business

The European Union (EU) requires that the text on the label must be written in one of the official languages of an EU Member State and be understandable for the consumer.

Packaging marketed within Europe must comply with the general requirements and specific provisions. These aim at protecting the environment and preventing any risk to the health of consumers. The packaging must protect the product against contamination, leakage and dehydration. Also pay attention to your buyer’s preference for presentation, such as individual wrapping or sortation (for example, one side up). Products and packaging should be uniform.

In the future, you can expect stricter regulations on the use of plastic in packaging. The new EU Directive 2019/904 on the reduction of the impact of certain plastic products on the environment already intends to limit the use of single-use plastics by transferring the cost of waste and responsibility to the producer. With the European strategy for plastics, more and more buyers will demand alternative and environmentally friendly packaging.

2. What additional requirements do buyers often have?

European buyers often have specific requirements, depending on their sales channels and product segments. Common buyer requirements include GLOBALG.A.P. certification, and compliance with social and environmental standards.

Table 3: Most important certifications requested by fresh fruit and vegetables buyers

Source: Autentika Global, modified by ICI Business

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 certification. All buyers in the supply chain, such as traders, food processors and retailers, require the implementation of a food safety management system based on hazard analysis and critical control points (HACCP).

GLOBALG.A.P.

The most commonly requested certification scheme, essential for exporting fresh produce to Europe, is GLOBALG.A.P. This pre-farmgate standard covers the whole agricultural production process from before the plant is in the ground to the unprocessed product. GLOBALG.A.P. focuses on food safety as well as the environment, labour conditions and product quality. It has become a minimum standard for most European supermarkets.

Food safety management systems

In addition to GLOBALG.A.P., other food safety management systems can be required as well; for example, for the handling or processing of fresh fruit and vegetables. Almost all buyers on the north-western European market (including the UK) will require you to comply with the BRC Global Standards, which are widely applied as a standard for hygiene and food safety. In Germany, the IFS food standard is very common.

Alternative food safety management certification includes the Safe Quality Food (SQF) programme and FSSC 22000, an industry-developed standard developed by the International Organization for Standardization (ISO).

All the mentioned management systems are recognised 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, but in general, you can only do business when certifications and standards are in place. Living up to these standards will only become stricter and more widespread in the future.

Social and environmental compliance

There is growing attention to the social and environmental conditions in the producing areas. Most European buyers have a code of conduct, with which they will expect you to comply. Although product quality is the top priority, social compliance becomes more and more important.

Initiatives in and attention to corporate social responsibility (CSR) vary across the various parts of Europe. In the eastern part of Europe, fewer buyers require strict social compliance, while there are multinational buyers in Western Europe which have their own compliance programme. Examples include Unilever’s Sustainable Agriculture Code and Tesco’s Nurture accreditation. In some cases, the increasing attention to social and environmental conditions requires specific actions; for example, in water management in arid areas and in achieving ‘living wages’ in poor supply countries.

As an exporter you need to implement standards, especially when dealing with buyers that are linked to retail chains. The most common social standards include SMETA and GLOBALG.A.P. GRASP. These are accessible for most exporters. Rainforest Alliance is also gaining importance in supporting climate-smart agriculture and help reduce climate impacts. Fairtrade labels are not on the top of the list of buyers because of their complex requirements and high costs. Fair Trade is most often used for the largest product categories such as bananas. In the near future, you can expect new standards and buyer requirements to be introduced.

Buyer initiatives which affect you as a supplier in terms of social compliance include:

• The IDH Sustainable Trade Initiative, which has a Sustainability Initiative [for] Fruit and Vegetables (SIFAV), a pan-European covenant with over 30 partners, including retailers, brands, traders and civil-society organisations. The 2025 strategy focuses on reducing the environmental footprint across the supply chain, improving working conditions, wages and incomes, and strengthening due diligence reporting and transparency.
• Amfori BSCI (Business Social Compliance Initiative) in north-western Europe, which includes a Code of Conduct for all its participants, and amfori BEPI for environmental performance;
• Sedex, a non-profit membership organisation to evaluate and manage your performance on labour rights, health and safety, the environment and business ethics;
• The Ethical Trading Initiative (ETI) in the UK.

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

• SMETA (Sedex Members Ethical Trade Audit), a social audit;
• GLOBALG.A.P., including add-ons such as GRASP for social compliance and SPRING for sustainable irrigation and groundwater use;
• Rainforest Alliance, a certification that supports climate-smart agriculture and help reduce climate impacts;
• ISO 26000, a standard for social responsibility and ISO 14001 for Environmental management.
• Corporate Carbon Footprint of TÜV Rheinland.

The Green Deal

In the coming years, the European Green Deal will influence how resources are used and greenhouse gas emissions are reduced. The new EU policies on sustainability will prepare Europe in becoming the first climate-neutral continent by 2050.

The Farm to Fork Strategy is at the heart of the European Green Deal, aiming to make food systems fair, healthy and environmentally friendly. It will ensure sustainable food production and address, for example, packaging and food waste. EU trade agreements with several countries already include rules on trade and sustainable development. For suppliers of fresh fruit and vegetables, it is important to look ahead of the increasing standards and try to be ahead of the developments.

Soft skills and company performance are also important

Complying with the food safety requirements, quality standards and certifications is a precondition to market fresh products in Europe, but it is still not a guarantee for success. Buyers look for trust and reliability and large retailers want to be unburdened. This means that your soft skills and performance are just as important as your product and certifications. Some of the most important things in the fresh trade are a timely delivery, proactive communication and commitment to agreements.

However, good conduct works both ways, so be aware of buyers that have a poor reputation or only show a short-term interest. In this fast-moving and perishable market, sudden decisions are taken, such as “dumping” your products at very low prices when the quality starts to deteriorate or when the demand slows down. European buyers are not eager to accept their loss and rather settle by claiming a quality issue. It is crucial that you can deal professionally with claims, whether they are justified or not.

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 fruit and vegetables.

Organic, a growing niche market

More and more consumers in Europe prefer organic fruit and vegetables because of their natural and sustainable production methods and their connection to a healthy diet. In countries such as Italy, Ireland, France, Germany and Sweden, organic fruit and vegetables represent around a fifth of the total organic demand.

To market organic products in Europe, you have to use organic production methods according to European legislation. Since January 2022, the new organic regulation (EU) 2018/848 has come into force, laying down the rules on organic production and labelling of organic products. A number of delegated and implementing regulations foresees in the legislation for trade in organic products. Inspection of organic products has become strict to prevent fraud. As a third-country producer, you will have to comply with the same set of rules as those producing in the European Union.

Before certifying your product as organic, you must have used these production methods for at least 2 years throughout a conversion period. Maintaining the required soil fertility and water retention, avoiding cross-contamination, and using organic inputs and reproductive materials can be a challenge for farmers in countries with tropical climates or with limited access to organic reproductive material and inputs.

To get certified as an organic farmer or exporter, you must be registered and certified through a recognised control body or accredited certifier. This control body is responsible for verifying that you comply with the organic rules through an annual inspection and a set of checks. After being audited by an accredited certifier, you can use the EU organic logo on your products, along with the logo of the standard holder.

European countries may prefer a national organic standard, which is in line with the EU certification but often exceeding its requirements. National standards can be an addition when supplying specific markets, for example Naturland in Germany, KRAV in Sweden, BioSuisse in Switzerland.

Figure 5: The official Organic label for organic products in Europe

Source: European Commission

All organic products imported into the EU must have the appropriate electronic certificate of inspection (e-COI). These certificates are managed through the Trade Control and Expert System (TRACES). If you do not have an electronic certificate of inspection, your products will not be released from their port of arrival in the European Union.

Fairtrade and environmental labels

Fairtrade and environmental product labels (visible to consumers) are niche requirements that can distinguish your product from the masses and attract the more conscious consumers. These certification labels are consumer-focused and are the most applicable to products from smallholder farms and main fruit and vegetable categories. Typical fruit varieties that can be found with these labels are bananas, pineapples and coconut, for example. Well-known labels include:

• Fair for Life;
• Fairtrade;
• Rainforest Alliance.

This study was carried out on behalf of CBI by ICI Business.

Please review our market information disclaimer.]