What requirements should oilseeds comply with to be allowed on the European market?
Food safety, including mechanisms to prevent contamination, is a major concern in the oilseed sector and is an important focus in legislative and additional requirements. In terms of niche requirements, the growing importance of organic and (to a lesser extent) fair trade schemes follows the European trend towards ethical consumption.
Here you can find requirements you must meet when marketing your products in the European Union. The following legislative requirements apply to oilseeds:
- Food safety and health control
Food safety is a key issue in European food legislation. All food products in Europe must comply with the General Food Law, which lays down the general principles and requirements of food legislation and establishes the European Food Safety Authority. It also includes provisions on the traceability of food; the ability to track food products through the stages of production.
For exporters to Europe, your buyers (minimally) expect you to know and document your suppliers and the products used during your production process. You must also label final products for traceability in case a food safety problem would occur.
In short, it is important to ensure genuine traceability ‘from field to fork’. But the current actual legal requirement for primary processors or exporters is one step back and one step forward.
An important aspect of food safety is to identify hazards and defining critical control points by implementing quality management systems. Buyers increasingly require suppliers to have a HACCP system in place, but even if they do not, this system will build your buyer’s confidence in your ability to supply safe food products.
Food products should also be subjected to testing by approved bodies. Products that are not considered safe will be denied access to Europe.
Control of food imported to Europe
IIf companies from a specific country continuously fail to meet European legislation, products from this origin can only be imported under stricter conditions, such as having to be accompanied with a health certificate and analytical test report. Products from countries that have shown repeated non-compliance are put on a list included in the Annex of Regulation (EC) 669/2009. For example: in June 2016, groundnuts from Brazil and Sudan were subject to emergency measures due to the frequent detection of aflatoxin contamination.
- Read more about sanitary and phytosanitary requirements at the European Union Export Helpdeskand pay special attention to the following documents from the European Commission:
- Check if there are any increased levels of controls for your product and country. The list is updated regularly. Check the Regulation periodically for the most recent list.
Avoid contamination to ensure food safety
Contamination can occur during the various stages of growing, processing, packaging, transport or storage of oilseeds. It is one of the most common problems faced by oilseed exporters (for example, aflatoxin in groundnuts and salmonella in sesame seeds).. The different sources of contamination, and the respective legislation addressing them, are:
Aflatoxins: limits have been set for aflatoxins B1, B2, G1 and G2 for oilseeds used directly for human consumption. See section 2 of Annex of Regulation (EC) No 1881/2006.
- Dioxins and PCBs: limits are in place to protect human health (see section 5 in Annex of Regulation (EC) No 1881/2006).
- Pesticides: European legislation on Maximum Residue Levels (MRLs) of pesticides establishes maximum limits in products of animal and vegetable origin which are intended for human consumption. Products containing more pesticides than allowed will be withdrawn from the European market. Note that buyers in several Members States (including the United Kingdom, Germany, the Netherlands and Austria) use MRLs which are stricter than those laid down in European legislation.
- Microbiological: microorganisms, especially salmonella, are a significant risk for oilseeds. Food safety authorities can withdraw imported food products from the market or prevent them from entering Europe when microorganisms such as salmonella are found in the product. There are many ways to avoid microbiological contamination. Good sourcing practices and quality management systems are the best, but, if you encounter a problem, make sure that the way you address it is permitted by European law. Irradiation, for instance, is not allowed.
- Foreign matter: contamination by foreign matter such as insects (especially mites) or other sources is a threat for oilseeds when food safety procedures are not carefully followed. Glass (which cannot be detected), wood and metal are important concerns for buyers.
- Learn and comply with the maximum contamination levels allowed by European legislation. Read more about contaminants in the European Union Export Helpdesk and check the European Commission’s factsheet on food contaminants Managing food contaminants: how the EU ensures that our food is safe.
- On the website of the Rapid Alert System for Food and Feed (RASFF), you can browse through various border rejections and alerts for specific oilseeds under the category ‘nuts, nut products and seeds’. In this way, you can learn about common problems faced by suppliers during border controls and adopt appropriate measures to avoid them.
- Read more about contaminants in the European Union Export Helpdesk and check the European Commission’s factsheet on food contaminants Managing food contaminants: how the EU ensures that our food is safe.
- Be familiar with FEDIOL’s Hygiene Guides, including set procedures dealing with salmonella and other sources of contamination.
- Many border rejections come from improper transport of oilseeds. For information on safe storage and transport, refer to the website of the Cargo Handbook.
- Investigate the pesticides and their maximum levels which are relevant for your products by using the European MRL database. You can search on the basis of your product or pesticide applied.
- Apply integrated pest management (IPM) to reduce the amount of pesticides in your product, if you are a producer. IPM is an agricultural pest control strategy that uses complementary strategies including growing practices and chemical management. Read more about MRLs in the European Union Export Helpdesk.
- If you are a non-producing exporter, carry out regular testing to manage pesticide residues and other sources of contamination.
General requirements on packaging and liability:
Full overview of requirements for oilseeds:
For a list of legislative requirements, consult the European Union Export Helpdesk where you can select your specific product code under chapter 12 (seeds).
Food Safety Certification as a guarantee
It is highly advisable for primary processors of oilseeds to comply with HACCP standards. For food processors, food hygiene based on HACCP methodology is a legislative requirement to enter the European market.
In addition to the minimum and mandatory food safety standards, European buyers increasingly demand compliance with even more comprehensive standards. Certifications of general quality and food safety management systems from recognised and trustworthy sources demonstrate the supplier’s commitment to high and consistent quality and safety.
This also applies to oilseed processing. In addition, these standards can give you a competitive advantage over other suppliers and, in some cases, add value to your product. Some buyers will pay more for product which is certified according to quality management systems, while others will not. But, in all cases, such certification will improve the chances of success in the European market.
Some buyers, including supermarkets and private-label packers, will require standards which go beyond HACCP such as:
- British Retail Consortium (BRC): contains more extensive rules on Good Manufacturing Practices (GMP) than HACCP, e.g. regarding organisation and communication.
- International Food Standard (IFS): corresponds to ISO 9001, but with a focus on food safety, HACCP, hygiene, the manufacturing process and business surroundings.
- ISO 22000: combines the HACCP plan with prerequisite programmes (PRPs). It specifies the requirements for a food safety management system along the food chain, up to the point of final consumption.
- FSSC22000: based on existing international standards ISO 22000 and ISO/TS 22002-1.
All the above mentioned management systems are recognised by the Global Food Safety Initiative (GFSI), which means that any of them should be accepted by several major retailers. However, in practice some buyers still have preferences for one specific management system.
In addition, the Sedex Members Ethical Trade Audit (SMETA) is an important tool to some of the main European/international companies. It is a means to find suppliers which comply with sustainability standards. You could use SMETA as a tool to streamline your information to multiple customers around four pillars: Labour Standards, Health & Safety, Environment and Business Ethics. As such, SMETA also addresses corporate responsibility aspects as described in the next section.
- Familiarise yourself with food safety management systems and select the most appropriate one for your market, as European market entry preparation most likely includes implementing a food safety management system.
- When you plan to target one or more markets, check which specific food safety management systems are most commonly requested. Choose for a management system that is approved by the Global Food Safety Initiative (GFSI) as it is an industry-driven global platform focused on food safety.
- Read more on the different Food Safety Management Systems on the ITC Standards Map website.
- An interesting information source covering food safety standards, which also publishes news items on this topic, is the website of HACCPEUROPA.
European buyers may expect you to comply with their supplier codes of conduct regarding social responsibility, which are often based on the International Labour Organisation (ILO) labour standards. This can be the importer’s own code of conduct or a code of conduct as a part of an initiative in which the importer is participating. The adoption of those standards is most common among large-scale importers, food manufacturers and retailers.
European buyers (especially large ones in Western and Northern Europe) are paying more and more attention to their corporate responsibilities regarding the social and environmental impact of their businesses. This has led numerous large supermarket chains and large industry players to develop sustainable sourcing policies.
This also affects suppliers directly. Common requirements are the signing of a suppliers’ code of conduct in which you declare that you do your business in a responsible way, meaning that you (and your suppliers) respect local environmental and labour laws, for example. These aspects are also investigated further in company audits carried out by your (potential) buyer.
- Most buyers are prepared to work with you toward compliance, provided you show interest and willingness. The first step is often a simple statement of intent or a policy on a particular aspect, for example a policy stating that you will not employ workers under the legal age in your country.
- Be aware that many of the environmental and social sustainability issues take place at farm level (which may not be a part of your company). To test to what extent your farmers are sustainable you could ask them to fill in the Farmer Self Assessment by the Sustainable Agriculture Initiative.
- Keep up-to-date on developments in sustainability by reading news items from sector associations (e.g. European Vegetable Oil and Protein meal Industry) and magazines (e.g. Public Ledger and visit specialised trade fairs, conferences and meetings.
- Implementing a management system such as ISO 14000 (environmental aspects), OHSAS 18001 (occupational health and safety) or SA 8000 (social conditions) is a way to address sustainability and possibly gain a competitive advantage. Investigate and inquire with your (potential) buyer whether such certificates (and which ones) are appreciated - it may be more straightforward than you expect.
Environmental and social certification for the mainstream market
In recent years, the sustainable sourcing of commodities such as soy (and palm, within the vegetable oil industry) has become a particularly important issue for buyers. Severe problems related to deforestation and other environmental and social effects have taken the news and affected public opinion.
In the case of soy, extensive publicity and concerns about sustainability of production and trade have led to the Roundtable on Responsible Soy (RTRS), which has led to related product standards and has been endorsed by large-scale mainstream players such as AHOLD, Jumbo, Arla Foods and ADM.
Additional requirements, such as environmental requirements and social (labour) requirements, are becoming increasingly important on the oilseed market.
Organic certification is a non-legislative requirement for oilseeds, but in order for you to market your product as ‘organic’ on the European market, you must comply with the European Regulation for organic production and labelling – which is in itself a legal requirement.
Organic-certified products attain a price premium which varies from product to product. The market for organic oilseeds accounts for a small share of the total market in Europe, estimated at 4% (not statistically verified), but it is growing at a fast pace.
Organic products must be grown using organic production methods which are laid down in legislation. Growers and processing facilities must be audited by an accredited certifier before putting the European Union’s organic logo on the products, as well as the logo of the standard holder (e.g. Soil Association in the United Kingdom, Naturland in Germany).
One of the factors you have to pay special attention to is whether your organic certification is recognised by European legislation. Therefore, you should search for a certifier whose standards are recognised by the European Union. The European Commission’s Agriculture and Rural Development website provides a thorough explanation of import regulations and other related issues.
New organic legislation will be implemented in Europe mid-2017. The objective is to simplify the old organic legislation.
- Investigate the possibilities for organic certification, including the opportunities and costs involved in the process. Some supply chains may find certification easier than others if pesticides are not part of day-to-day agriculture.
- For information on organic certification in Europe, visit the website of Organic Farming in the European Union, which also contains guidelines concerning imports of organic products. Also consult the International Federation of Organic Agriculture Movements website for information on certification standards.
- Check the Soil Association standard for Food and drink to familiarise yourself with the requirements of organic production.
- eck the websites of organic importers such as Tradin, DO-IT and Rapunzel.
Fair trade products are produced with an extra focus on the social conditions in the producing areas. The market for fair trade-certified oilseeds in Europe is very small, and is concentrated around a few players on the European market.
Fairtrade International is the leading standard-setting and certification organisation for Fairtrade. Products which carry the Fairtrade label indicate that producers are paid a Fairtrade Minimum Price. FLO has a minimum price for various oilseeds and oleaginous fruits.
Other fair trade standards available on the European market are Fair Trade Ecocert and Fair for Life. Fair Trade Ecocert provides for guaranteed minimum prices, producer support and good agricultural practices; this standard requires an organic certification. Fair for Life has a similar proposition, and is a standard for companies which demonstrate decent working conditions and commit to fair sourcing and responsibilities towards their primary producers. Organic certification is not compulsory for Fair for Life holders.
- Before engaging in a Fair Trade certification programme, be sure to check (in consultation with your potential buyer) that this label has sufficient demand in your target market and whether it will be cost-beneficial for your product. You can only realistically engage in a Fair Trade process in partnership with a Fair Trade buyer.
- Check the Fair Trade Standards for small oilseed and oleaginous fruit producer organisations.
- Consult the Standards Map database for more information on Fair Trade and other voluntary standards relevant for oilseeds.