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Which requirements should grains and pulses comply with to be allowed on the European market?

Takes about 8 minutes to read

If you want to get grains and pulses on the European market, you must comply with strict requirements. Requirements that are especially important are those related to food safety, use of pesticides and contaminants. Complying with additional requirements (for example having GLOBALG.A.P.) or niche quality standards (for example having fair trade or organic certification) can help you distinguish your company from your competitors. 


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

When exporting grains and pulses to Europe, you must comply with the requirements listed below. Detailed information about European Union (EU) requirements can be found on the Export Helpdesk website. The obligatory requirements discussed in this section are as follows:

  • Food safety in general (incl. traceability)
  • Pesticides
  • Contaminants (incl. mycotoxins)
  • GMO
  • Food control
  • Labelling

Food safety: Traceability, hygiene and control

Food safety is a key issue in EU food legislation. The General Food Law is the legislative framework regulation for food safety in the EU. To guarantee food safety and to allow appropriate action in cases of unsafe food, food products must be traceable throughout the entire supply chain, and risks of contamination must be limited. One important aspect involved in controlling food-safety hazards is defining critical control points (HACCP) by implementing food-management principles. Another important aspect involves subjecting food products to official controls. Products that are not considered safe will be denied access to the EU. Products that are new in the European food market (e.g. those not widely consumed prior to 1997) are considered ‘novel foods’ and have specific legislation.

Tips:

  • Read more about Food Safety and Risk Management on the website of the Food and Agriculture Organization (FAO).
  • When introducing a novel product in the EU, consult with the EU food safety authorities to determine whether your product is actually considered a novel food. Novel food requires a special authorisation or notification.

Limited use of pesticides

The EU has set maximum residue levels (MRLs) for pesticides in and on food products. Strict compliance with MRLs and the prevention of microbial contamination are preconditions for entering the European market. Products containing illegal pesticides or excessive amounts of other residues will be withdrawn from the EU market. Note that the MRLs applied by buyers in several Members States are stricter than those specified in EU legislation.                                                                                                                                                                                                                                                                                      

Tips:

  • Use the MRL database to identify the MRLs that are relevant for your products. After selecting a product or pesticide used, the database returns the list of the MRLs associated with them.
  • Apply integrated pest management (IPM) to reduce the amount of pesticides. This agricultural pest-control strategy uses natural control practices. The fewer chemicals you use, the better your marketing position will be. The FAO website provides information about IPM.
  • Check with your buyers to determine whether they require additional requirements relating to MRLs and pesticide use. Expect your product and product samples to be subjected to thorough testing. The laboratory tests in Europe may be more extensive than those in your own country.

Contaminants

Contaminants are substances that have not been intentionally added to food, but which may be present as a result of the various stages during production, packaging, transport or holding. To avoid negative impact on the quality of food and risks to human health, the EU has set limits for several contaminants. These limits include heavy metals and mycotoxins, which are natural by-products of mould and very common on grains and pulses cultivated in humid climates.

Tips:

No GMOs

The European Union adopts a very cautious stance towards genetically modified organisms (GMOs). Only a few genetically modified grain varieties have been authorized for soybeans, rapeseed and maize, and they are used primarily in the animal feed sector. For human consumption, most food businesses choose not to sell GM food at all.

Tips:

  • Sell only non-GMO products if your product is destined for human consumption. In general, genetically modified crops are not accepted.
  • For additional information, consult the EU register on GMOs to determine which GMOs are allowed and the EU factsheet to review current legislation.

Control of food imported to the EU

To ensure food safety and avoid environmental damage, the EU has restricted the use of certain chemicals (MRLs) in several Regulations and Directives. Your products will be subjected to official controls, which are conducted in order to ensure that all food marketed in the EU is safe (i.e. in compliance with the requirements applicable to particular products). 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 EU can decide to conduct more intensive controls or impose emergency measures. Although controls can be carried out at all stages of import and marketing in the EU, most take place at the points of entry into the EU.

For importers of food products, the traceability of a product is compulsory. To this end, importers in the EU require exporters to show proof of origin and take traceability measures.

Tips:

  • Make sure that the accompanying documents (e.g. bill of lading) correspond exactly with the food products contained in the consignment, including the indicated volumes, number of pallets and boxes, and names of growers.
  • Consult the EU control measures to determine whether there are any increased levels of control for your specific product.
  • Read more about health control in the EU Export Helpdesk.

Labelling

Food placed on the EU market must conform to the following legislation with regard to food labelling:

  • Generic name and, if applicable, its treatment;
  • List of ingredients, including allergens;
  • Net quantity;
  • Date of minimum durability;
  • Special conditions for keeping or use;
  • Name and address of the manufacturer, packager or importer;
  • Place of origin;
  • Lot marking on pre-packaged foodstuffs.

Novel food and genetically modified foods require additional labelling (e.g. with regard to composition, nutritional value, intended use and materials that may have health implications and/or raise ethical concerns).

Tips:

  • Make sure that all mandatory information is mentioned, in addition to considering other useful information (e.g. logos of importers or certificates). Read more about food labelling in the EU Export Helpdesk.
  • When targeting several countries within the EU, labelling must be in the language of each country.
  • Avoid making health or nutrition claims that are not supported by European legislation. Check first with the EU Register of Nutrition and Health claims.

Full overview of requirements for your grains and pulses

For a full list of requirements, please consult the EU Export Helpdesk. Specific product codes can be selected under Chapters 07.13 (Pulses), 10 (Cereal grains) and 12 (Seeds

General requirements on packaging and liability

Note that non-product-specific legislation on packaging and liability also applies to all goods marketed in the EU.

2 . What additional requirements do buyers often have?

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

Marketing standards

Each product has its own characteristics which are often documented as a marketing standard. The Codex Alimentarius provides standards for several grains and pulses, such as couscous, sorghum, rice and certain pulses. These standards cover characteristics such as moisture, purity, grain quality and appearance. Not all products are covered. However, this does not mean that buyers of such products operate without a standard.

Tip:

  • Ask your (potential) buyer for technical data sheets. This will give you an indication of the product characteristics you have to supply.

Certification as guarantee

Given that food safety is a top priority in all EU food sectors, most buyers are likely to request additional guarantees in the form of certifications. For European food businesses it is a legal requirement to have a food safety management system based on the principles of HAZARD ANALYSIS AND CRITICAL CONTROL POINT (HACCP). Many EU buyers (e.g. traders, food processors, retailers) require the same from their foreign suppliers.

Food safety management systems and certifications that are recognized by the Global Food Safety Initiative (GFSI) are widely accepted throughout Europe. The following are the most significant certifications:

GLOBALG.A.P. – a pre-farm-gate standard covering the process from farm input to non-processed product

FSSC 22000 / ISO 22000 – International standard for food safety management. FSSC 22000 is based on ISO 22000 and targeted specifically at food manufacturers. These certifications include HACCP.

BRC Global Standard for Food Safety provides technical standards for food safety, consumer products, packaging, storing and distribution. It is a widely accepted standard in Europe.

IFS – Safety standard for food processors and packers

GMP+ – International standard for feed safety and responsibility throughout the supply chain for animal feed

Tips:

  • Check the FAO Guidelines for the implementation of HACCP.
  • Read more on the different Food Safety Management Systems and hygiene standards in the Standards Map, or consult the Global Food Safety Initiative (GFSI). The Standards Map contains a benchmark for relevant additional standards.
  • Become familiar with A.P., as your preparation for EU market entry is likely to include GLOBALG.A.P. certification, especially when targeting supermarkets as the end market.
  • Different market channels and EU regions may have different preferences for particular food safety management systems. Check with your buyers to determine which systems they prefer.

Social and environmental practices

Buyers in the EU are increasingly paying attention to their corporate responsibilities with regard to the social and environmental impact of their businesses. This has led a number of supermarket chains and large industrial players to develop their own Corporate Social Responsibility (CSR) and sourcing policies. In addition, many smaller buyers have incorporated social and sustainable practices into their business policies. This has implications for suppliers as well. Common requirements include signing a code of conduct for suppliers, in which you declare that you conduct your business in a responsible manner (e.g. you and your suppliers respect local environmental and labour laws and avoid corruption). Social compliance is supported by several important initiatives, including the following:

Business Social Compliance Initiative (BSCI)

The BSCI is a leading business-driven initiative for companies committed to improving working conditions in the global supply chain by adopting a common code of conduct. It is particularly prominent in Western mainland Europe. The initiative of BSCI is in the hands of European companies that share a common code of conduct, improving working conditions of supplying factories and farms.

Ethical Trading Initiative (ETI).

Originating in the UK, the ETI is an alliance of companies, trade unions and NGOs promoting respect for workers’ rights around the globe.

Global Social Compliance Programme (GSCP)

The GSCP is a business-driven programme for the continuous improvement of working and environmental conditions in global supply chains.

Tips:

  • Check the current performance of your company (e.g. by completing a self-assessment on the BSCI website). This will help you focus on specific improvement points.
  • The implementation of new certification systems can be very time-consuming. Plan ahead and focus on the ones that are most relevant to your product and target market.

3 . What are the requirements for niche markets?

In addition to the official and common requirements, specific requirements apply to niche markets (e.g. for organic grains and pulses or fair trade products). These requirements can be particularly important for specific consumer groups or in the health-food segment.

Organic, a growing niche market

Consumers in the EU increasingly prefer food products that are produced and processed using natural and sustainable methods. Organic certification is often used for food products associated with health benefits. For example, the European market for quinoa has been developed entirely by organic trading companies.

In order to market organic products in the EU, you must use organic production methods, which are specified in EU legislation. You must have used these production methods for at least two years before you can market grains and pulses as organic. In addition, you (or your EU importer) must apply for import authorization from an EU organic control body. After being audited by an accredited certifier, you may affix the EU organic logo on your products, along with the logo of the standard holder. Examples include the Soil Association (especially relevant in the UK), Bio-Siegel (Germany), Agriculture Biologique (France) or BioSuisse (Switzerland). Although there are slight differences between these standards, they all comply with EU legislation concerning organic production and labelling.

Tips:

Fair trade and environmental certification

Fair trade and sustainable certification is a niche requirement that can distinguish your product from the mass and attract the more conscious consumers. These certification labels are consumer-focussed and best applicable to products from smallholder farms. Well-known labels include Fair for Life, Rainforest Alliance and Fairtrade. Fairtrade International (FLO) introduced a new fair trade standard for cereals in 2016.

Tips:

  • Consult the Standards Map database for a list of labels, along with their similarities and differences. Enter your product, country and destination country to find certification schemes that fit your product.
  • Find a specialized European buyer who is familiar with sustainable or fair trade products.