What requirements must natural food additives comply with to be allowed on the European markets?

Regulatory requirements for natural food additives are becoming stricter in Europe. European buyers of natural food additives are increasingly demanding suppliers meet their additional buyer requirements. Moreover, there is an increasing demand for natural food additives for niche markets, such as organic. As an exporter of natural food additives that wants to successfully enter and trade in the European market, you must meet regulatory, additional buyer and niche market requirements.

1. What are mandatory requirements?

Safety of natural food additives

For the European Union (EU), ensuring the highest standards of food safety for its citizens is a key policy priority. As an exporter of natural food additives, you must demonstrate that your natural food additives are safe for use. You must therefore comply with the EU’s General Food Law, which ensures the safety of your natural food additives. Failure to comply results in your natural food additives not being allowed to enter the European market.

Under the General Food Law’s legislative framework, you must have a traceability system in place throughout your entire supply chain. This is because having a traceability system in place guarantees  the quality of your natural ingredients can be traced back from consumer to producer. The European Commission provides a  range of information on the traceability aspect of the EU General Food Law. For natural food additives from plant origin, the general guidelines apply. For the following two sectors, more detailed guidelines for traceability apply:

• Foods of animal origin: Commission Implementing Regulation (EU) No 931/2011.
• Sprouts and sprout seeds: Commission Implementing Regulation (EU) No 208/2013.

The EU legally requires you to immediately withdraw or recall any of your natural food additives that are no longer safe for use after they have reached and are on the European market. The EU also legally requires you to immediately notify them and the relevant national authorities of this so they can monitor the situation and take appropriate action to ensure food safety. Failing to do this could result in the end of your business relationships with European buyers and damage your reputation in the European food industry.

Contamination

For your natural food additives to enter and be traded in the European market, you must prove your natural food additives are not contaminated, or within levels set by the EU. This is because the EU legally requires you to do so. If you do not comply, your natural food additives will not be allowed to enter the European market.

The EU legally requires you to prove that your natural food additives are not contaminated by three elements, or within the levels set by them. The three elements are:

1. physical - this concerns plastic, metal and dirt residues;
2. chemical - this concerns pesticides;
3. biological - this concerns bacteria.

You must prove that your natural food additives are not contaminated by these three elements, or that they are within the prescribed levels set by the EU.

The EU has set Maximum Residue Levels (MRLs) for pesticides (EC Regulation 396/2005) and heavy metals (EC Regulation 1881/2006) for food products. You must ensure that your natural food additives do not contain pesticides or heavy metals above the levels set by the EU. If you do not comply, your natural food additives will not be allowed to enter the European market or withdrawn.

European buyers of natural food additives regularly test products they import, usually on a per batch basis, to determine whether or not they are contaminated, or within set levels. Indeed, in an interview conducted by Ecovia Intelligence on behalf of CBI a European buyer of natural food additives stated “we test a sample of every shipment”, and another said “we analyse for pesticides, for microbiology and for metals”. Alongside the EU’s legal requirements, this is another reason why your natural food additives must not be contaminated, or within set let levels.

Classification, Labelling and Packaging (CLP)

The EU’s Classification, Labelling and Packaging (CLP) Regulation (EC Regulation 1272/2008) identifies hazardous chemicals and informs users about their hazards through standard symbols and phrases. For your natural food additives to enter the European market, the EU legally requires you to meet its CLP Regulation. If you do not comply, your natural food additives will not be allowed to enter the European market.

Certain natural ingredients are hazardous; such is the case with certain essential oils that are classified as Class 3 Flammable Liquids and therefore require additional controls for transportation by air, land and sea. These include Tea Tree Oil, Citrus Oils (lemon, grapefruit, bergamot, orange) and Rosemary Oil.

You must guarantee safety during the import-export process. The EU legally requires special packaging to be used for hazardous ingredients during the transport and handling process in particular. Alongside this, the EU legally requires the corresponding warning labels to be applied on special packaging used.

As an exporter, you must determine whether your natural food additives are hazardous. Check the European Chemicals Agency (ECHA) database to determine if your natural ingredient is hazardous. If your natural ingredient is hazardous, use the appropriate special packaging and corresponding warning labels. You are legally required to use the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) labels for your food additives. This is to ensure those coming into contact with your natural ingredient throughout the supply chain are not put in danger or at risk of harm whilst handling it.

Guar gum, gum arabic, black pepper oleoresin, ginger oleoresin, carrageenan (a seaweed extract) and vanilla extract are examples of natural food additives that require appropriate special packaging and corresponding warning labels on their packaging.

Substances allowed in the European Union

Food additives are strictly regulated by the EU to ensure the safety of consumers with regards to foods containing food additives. The EU has placed increasing emphasis on this in recent years, a trend  expected to continue. EU Regulation 1333/2008 sets rules for the use of additives, such as colours and thickeners. Meanwhile, EU Regulation 1334/2008 sets rules for the use of flavourings, such as essential oils.

As an exporter of natural food additives, you must ensure your ingredients are allowed for use in the EU. This is because European customs authorities do not allow food products into the European market if they contain unauthorised additives, flavouring or substances not allowed in the EU.

The substances allowed in foods in the EU as well as the rules concerning these substances are subject to changes and updates. You must regularly monitor changes to ensure your natural food additives are allowed to enter the European market. For example, check if your natural food additives have been removed from the relevant EU rules.

Food extracts for colouring of additive-free foods

There has been growing demand for additive-free foods in recent years, a trend  expected to continue. Food extracts with colouring properties are not classified as food additives by European legislation, and are thus suitable for use in additive-free foods.

If you are a company with food extracts that have colouring properties, you must be aware of this legal difference. Furthermore, this could allow you to benefit from European demand for additive-free foods.

Convention on Biological Diversity/Access and Benefit-Sharing

The Nagoya Protocol of the Convention on Biological Diversity (CBD) aims to ensure that the benefits of genetic resources and long-established knowledge are shared equitably. It does so through its Access and Benefit-Sharing (ABS) scheme, which is particularly important for wild-collected ingredients.

The EU has adopted international treaties and protocols on using plant resources into European law. The Nagoya Protocol of the Convention on Biological Diversity (CBD) is an important protocol translated into European Law. It is likely part of your national laws too.

You must comply with the Nagoya Protocol if your country is a signatory to the protocol. Failure to comply will result in your natural food additives not being allowed to enter the European market.

2. What additional requirements and certifications do buyers ask for in the European natural food additives sector?

European buyers of natural food additives have additional requirements beyond the mandatory requirements set by the EU. Not meeting these additional requirements will make it much more difficult for you to successfully enter and trade on the European market, which is becoming increasingly competitive. Table 1 shows the most important certifications requested by European buyers of natural food additives.

Table 1: Most important certifications requested European buyers of natural food additives

Certification name	Type	Cost for companies	Most used in European end-market(s)	Further information on getting certification
ISO 22000:2018 FSSC 22000	Food safety	Certification costs are dependent on factors such as your company’s business activities and location.	Germany France Italy The UK	See the ISO 2200:2018 food safety management systems webpage on the ISO website for further information on getting certification. See the certification bodies section on the FSSC website for further information about getting certification.
ISO 9001: 2015	Quality management	Certification cost is dependent on factors such as your company profile, sectors, annual turnover, number of sites and staff.	Germany France Italy The UK	See the ISO 9001:2015 quality management systems webpage on the ISO website for further information about getting certification.
EU Organic	Organic	Certification costs are dependent on factors such as your company profile, business activity, number of sites, who you work with, and country / region.	Germany France Italy The UK	See the organic agriculture Europe quotation section on the Ecocert website for further information about getting certification.
FairWild	Social aspects (wild harvested)	Certification costs are dependent on factors such as location, size and complexity of operations.	Germany France Italy The UK	See the approved control bodies and accreditation section on the FairWild website for further information about getting certification.
Fairtrade International	Social aspects	Certification and license costs are dependent on factors such as product standard, product, quality, form, product characteristics, country / region and producer scope.	Germany France Italy The UK	See the get certified and get licensed section on the Fairtrade website for further information about getting certification.
Fair For Life	Social aspects	Certification costs are dependent on factors such as the size and complexity of supply chain, type of certification sought, location of operation and producers and whether you have other certification.	Germany France Italy The UK	See the become certified section on the Fair For Life website for further information about getting certification.

Source: Ecovia Intelligence

Certification

Food safety is important to European buyers of natural food additives. As a result, buyers regularly demand extra certification proving the added safety and quality of the natural food additives they buy.

Indeed, when asked what the most important requirements were for new suppliers in developing countries, one European buyer revealed “we like them to be certified”, as “our customers require certificates… so we have to have them from the supplier”. Additionally, when asked about the importance of certification, another buyer stated that it is “necessary, yes” with yet another stating “certifications are particularly important”.

European buyers demand certification of a food safety management system based on the European Union’s Hazard Analysis Critical Control Points (HACCP) system outlined in EU Regulation 852/2004 on hygiene of food stuffs.

To trade with European buyers, you should meet their demands for extra certification as that will give you an advantage  establishing yourself successfully in the European market. It could also be the basis for developing long-lasting trading relationships with buyers.

The most common certifications demanded by European buyers are:

• International Organization for Standardization (ISO) 22000 food safety management system certification and ISO 9001:2015 quality management systems certification;
• Food Safety Certification (FSSC 22000) which is based on ISO 2200 and is specifically aimed towards food manufacturers; and

• British Retail Consortium Global Standard for Food Safety (BRCGS) certification which provides technical standards for food safety.

Figure 1: Examples of certification

Source: Various

Documentation

European buyers of natural food additives expect exporters to provide them with well-structured and organised product and company documentation. This is because it shows you comply with regulations, as well as their buyer requirements. 

For example, when asked in an interview whether documentation is important, one European buyer of natural food additives answered “100 percent yes”. Another buyer stated “when you are looking for a new supplier, yes of course it [documentation] is important”. As such, you should consider providing European buyers with documentation. It is something they have come to expect and will likely increase your chances of entering the European market. Additionally, it adds credibility to your business as it makes it look organised and well prepared.

European buyers of natural food additives usually want exporters to provide them with Safety Data Sheets (SDS), Technical Data Sheets (TDS) and Certificates of Analysis (CoA). Be prepared to invest time and resources into preparing the documentation that buyers require. Additionally, be prepared to complete questionnaires about your compliance with EU regulations, because European buyers often require this. Table 2 shows what is contained in SDS, TDS and CoAs to help you prepare these three important pieces of documentation.

Table 2: What is contained in SDS, TDS and CoA

Safety Data Sheet (SDS)	Technical Data Sheet (TDS)	Certificate of Analysis (CoA) which matches
Product description	Product description	Data mentioned in the TDS
Product classification	Product classification	Pre-shipment samples approved by buyer
Hazard identification	Quality analysis	Contractual agreements with buyer
Information on safety measures	Information on applications
	Certificates

Source: Ecovia Intelligence

EU regulations have become stricter in recent years and quality standards are also increasing, leading to more pressure on European buyers. Consider acquiring a SDS, a TDS and a CoA for your natural food additives and have them ready for European buyers. Additionally, inform European buyers if you already have the proper documentation when approaching them.

Samples

European buyers usually demand samples after reviewing documentation concerning the natural food additives they are considering buying. This is to determine whether  your natural food additives comply with EU legislation and meet their own specifications. For example, one buyer of gum arabic stated in an interview “every time, each consignment they would like to offer we need a sample beforehand for every batch”. European buyers will test and analyse samples at laboratories.

As an exporter of natural food additives, ensure  samples you send to European buyers show you at your best. Always meet the requirements a buyer has set for any samples you send them. This typically concerns:

1. sample type – for example conventional or organic;
2. quantity – for example 400 grams of organic guar gum; and
3. packaging – for example kraft paper bag and/or steel container.

3. What are the requirements and certifications for natural food additives niche markets?

Certification of organic production

There is growing consumer demand for certified organic products in the European market, a trend  expected to continue. However, quality and contamination are two big issues for European buyers. As a result, European buyers are increasingly demanding certified organic food ingredients to meet growing consumer demand, but also because they are a sign of good quality.

For example, when European buyers of stevia were asked if there is demand for organic stevia several answered “yes”, with one buyer commenting “we only have organic stevia”. Meanwhile, when European buyers of vanilla extract were asked if there is demand for organic vanilla several answered “yes”, with one commenting “yes, of course there is demand for organic vanilla”. Additionally, another buyer commented “most people are demanding organic vanilla”. As such, you should consider acquiring organic certification.

Certified organic additives are produced and processed using natural techniques. This includes crop rotation, the biological protection of crops and the use of green manure and compost. You must comply with EU regulations to trade your natural food additives as organic on the European market. You can find information on organic certification on the EU organics website.

For any organic ingredient to be traded on the European market, the EU requires it to have a Certification of Inspection (COI). Moreover, European buyers themselves also often request a COI. As such, ensure you have a COI for your natural food additives.

From January 2021, new EU regulation (EU) 2018/848 will come into effect in Europe. Additionally, there are new official control regulations to help determine whether products imported to Europe meet European rules.  You must comply with this new regulation if you produce organic natural ingredients.    

Having your food additives certified as organic shows European buyers  you are a reliable trading partner and that your food additives are of high quality. You can use the certification of your food additives as a selling point when approaching European buyers.

Figure 3: EU organic certification logo

Source: Source: ec.europa.eu

Environmental and social sustainability

There is growing consumer demand for environmentally and socially-produced products in the European market, and that trend is expected to continue. There is growing demand from European buyers for sustainably-produced natural food additives. As an exporter, getting certification that proves you meet environmental and/or social standards is a way of meeting this demand.

Certification proving your natural food additives have been produced according to certain environmental standards can be obtained from the:

• UNCTAD BioTrade Initiative BioTrade Principles and Criteria which provide a framework for the conservation and the sustainable use of biodiversity in business and trade;
• FairWild Standard which focuses on sustainable collection, social responsibility and fairtrade principles for wild-collected plants.

To prove you meet social standards consider obtaining:

• Fairtrade International standards which require producers and traders to meet a range of economic, environmental and social criteria;
• Fair for Life Standard which concerns certification programmes for fair trade, responsible supply chains and Corporate Social Responsibility.

Europe has seen increasing consumer demand for ethical products in recent years. That is true for foods in particular, as this segment showed the highest growth in sustainable product sales. This trend is expected to continue.

Figure 4: Examples of environmental and social standards

Source: Various

This study has been carried out on behalf of CBI by Ecovia Intelligence.

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