What requirements must processed fruit and vegetables comply with to be allowed on the European market?

When exporting products to the European market, producers and exporters must comply with all mandatory standards set by public institutions to ensure product quality, environmental protection and consumer health. Requirements range from the approval of additives to the prohibition of harmful contaminants. Information labels on food packaging are also strongly controlled.

While all the legally binding requirements are clearly listed onthe EU Trade Helpdesk, private requests from individual European buyers are becoming equally important. Exporters from developing countries are therefore advised to regularly check which voluntary standards have become a prerequisite.

1. What are mandatory requirements?

Apart from customs procedures, almost all mandatory requirements related to importing processed fruit and vegetables (and food in general) are related to food safety. The General Food Law is the legislative framework regulation for food safety in Europe. The General Food Law specified the establishment of the European Food Safety Authority (EFSA). This legislation is responsible for the development of specific food safety legislation and the creation of a framework for official food controls.

This law is based on the ‘Farm to Fork’ approach. This means that all food must be traceable throughout the entire supply chain, including exporters from developing countries. To achieve this, all food business operators must implement the Hazard Analysis of Critical Control Points (HACCP) system in their daily operations.

Several aspects of the most important food safety requirements are described below.

Tariff barriers

Tariffs are one of the main trade barriers influencing a country’s competitiveness when exporting to Europe. They are customs duties, which are usually paid by the importer. The level of applied tariffs depends on the trade agreements between the European Union and the supplying country. For most processed fruit and vegetables imported from developing countries, the tariff rate is zero. To benefit from these low tariffs, however, most fruit and vegetables must be fully obtained in the supplier country before processing, although there are a few exemptions.

For most processed fruit and vegetables, tariffs are calculated as a certain percentage of import value, also referred to as ad valorem. For example, prunes imported from Argentina are subject to an ad valorem tariff of 9.6%. In some cases, tariffs are calculated on a specific basis (for example, a tariff of €1.38/100 kg is applied to the import of fig paste from Turkey). Applied tariffs can also be a combination of ad valorem and specific rates. For example, this is the case for the import of strawberry jams from China, which are subject to an ad valorem rate of 24% and an additional rate of €23/100 kg.

Another form of tariff barriers are tariff quotas, which impose limits on the amount of goods that can be imported at a reduced or zero rate of custom duty. Such quotas are rarely used for imported processed fruits and vegetables. One example is the import of olive oil from Tunisia, where zero tariffs are applied. Export volumes exceeding 56,700 tonnes are subject to a regular tariff of €124.50/100 kg. Please note that European importers must have an import license to benefit from reduced tariff rates under the tariff quotas.

Phytosanitary inspection

The European Union inspects food products to protect citizens, animals and plants from diseases and pests. One common means of protection is the inspection of food and the issuing of a phytosanitary certificate before export. Phytosanitary certificates are issued for plants or plant products that can be reproduced within Europe after import (e.g. bulbs, tubers or food containing seeds). Phytosanitary certificates are not required for most processed fruit and vegetables, except for whole dried fruit, vegetables, and in-shell nuts.

Official border control for food imported into the European Union

You should be aware that repeated non-compliance with the European food legislation by a particular country may lead to stricter import conditions or even suspension of imports from that country. These stricter conditions usually include a requirement for a health certificate and an analytical test report for a certain percentage of the shipments from specific countries. Products from countries that have shown repeated non-compliance are placed on a list included in the Regulation on the increased level of official controls on imports.

Nevertheless, only a small number of the products imported and marketed in Europe are subject to official (physical) controls, as the primary responsibility for their safety lies with commercial operators (e.g. importers). Importers will therefore conduct most of the checks required to ensure that products are safe, and they may also demand certification and other proof of quality and safety. The frequency of controls for certain processed fruit and vegetables included in the latest issue of the EU border control regulation is presented in Table 1.

Table 1: Official controls for processed fruit, vegetables and edible nuts  (for reference only; consult EUR-Lex for the most current information related to the frequency of identity and physical checks)

Product	Country of origin	Hazard	Frequency of official controls (%)
Apricot kernels	Turkey	Cyanide	50
Brazil nuts in shell	Brazil	Aflatoxins	50
Dried apricots	Uzbekistan	Sulphites	50
Dried figs and dried fig paste	Turkey	Aflatoxins	20
Dried goji berries	China	Pesticide residues	10
Dried grapes	Turkey	Ochratoxin A	10
Dried mandarins	Turkey	Pesticide residues	5
Dried oranges	Turkey	Pesticide residues	10
Frozen beans	Cambodia	Pesticide residues	50
Frozen chillies	Vietnam	Pesticide residues	50
Frozen okra	India, Vietnam	Pesticide residues	10
Frozen or dried curry leaves	India	Pesticide residues	50
Frozen paprika	Egypt, Uganda, Pakistan	Pesticide residues	20
Frozen paprika	Thailand, Turkey, India	Pesticide residues	10
Groundnuts	Bolivia, Madagascar, Sudan, Senegal, Ghana, Gambia	Aflatoxins	50
Groundnuts	China, Egypt	Aflatoxins	20
Groundnuts	United States, Brazil, India	Aflatoxins	10
Groundnuts	Argentina	Aflatoxins	5
Hazelnuts	Georgia	Aflatoxins	50
Hazelnuts and hazelnuts paste	Azerbaijan	Aflatoxins	20
Hazelnuts and hazelnuts paste	Turkey	Aflatoxins	5
Hazelnut oil	Azerbaijan	Aflatoxins	20
Hazelnut oil	Azerbaijan	Aflatoxins	5
Palm oil	Ghana	Sudan dyes	50
Peanut butter	Bolivia, Madagascar, Senegal, Ghana, Gambia, Sudan	Aflatoxins	50
Peanut butter	China	Aflatoxins	20
Peanut butter	United States, Brazil, India	Aflatoxins	10
Peanut butter	Argentina	Aflatoxins	5
Pickled and preserved turnips	Lebanon	Rhodamine B	50
Pickled and preserved turnips	Syria	Rhodamine B	50
Pistachios	United States	Aflatoxins	10
Pistachios and pistachio paste	Iran, Turkey	Aflatoxins	50
Watermelon seeds	Sierra Leone, Nigeria	Aflatoxins	50

In addition to border controls, official food controls include regular inspections that can be carried out at all stages, from import to retail sales. In case of non-compliance with the European food legislation, individual cases are reported through the Rapid Alert System for Food and Feeds (RASFF), which is freely accessible to the general public.

In 2021, of the 4,607 RASFF notifications transmitted, 4,102 concerned food, 236 concerned feed and 269 concerned food contact material. Products were blocked at European borders in 1,457 cases (31.6% of all non-compliance cases). In the category of processed fruit and vegetables, most problems were related to the import of edible nuts (mainly mycotoxins), followed by fruit and vegetable products (mainly pesticide residues). The number of cases of non-compliance is estimated to be much larger, however, as the results of many controls conducted by private companies are not recorded by RASFF.

Control of contaminants

Food contaminants are unwanted and harmful substances in food that can cause consumer illness. These substances may be present in food as a result of the various stages of its production, packaging, transport or holding, or they may come from the external environment. The European Union has taken strict and extensive measures to minimize contaminants in food. The European Commission Regulation sets maximum levels for certain contaminants in food products. This regulation is frequently updated and, apart from the limits set for general foodstuffs, there are several specific contaminant limits for specific products.

The most common requirements regarding contaminants in processed fruit and vegetables are related to microbiological contaminants, mycotoxins and pesticide residues.

Contamination by foreign bodies

Insects form an important contamination issue for dried fruit imported to the European market. Insects may be found dead in the packaging, and some type of insects can develop inside the fruit and continue to grow during storage. To prevent contamination with insects, suppliers from developing countries should implement preventive measures (e.g. fumigation and temperature treatments). If you use fumigation, you should use only officially approved fumigants. For example, the use of methyl bromide as a fumigant is banned in the European Union.

Other types of contamination with foreign bodies include soil, stones, glass and metal parts (e.g. from agricultural machinery and tools). The use of optical, metal and similar detectors is recommended to prevent this type of contamination. Physical sorting and visual-manual inspection are always recommended, however, even if detectors have been installed.

Reducing the risk of microbiological contaminants

The main reasons for border rejections of imported processed fruit and vegetables relate to microbiological contamination. The most common types of microbiological contaminants in processed fruit and vegetables are Salmonella, Escherichia coli, Listeria and viruses (e.g. norovirus and hepatitis A viruses). The European regulation on microbiological criteria for foodstuff sets limits for pathogenic micro-organisms, their toxins and metabolites. The limits for most common pathogens are listed in Table 2.

Table 2: Limits for certain pathogens in processed fruit and vegetables

Pathogen/Toxin	Limit
Salmonella	Absent
E. coli	Absent; 100 cfu/g in ready-to-eat, pre-cut fruits and vegetables and unpasteurized fruit and vegetable juices
Listeria monocytogenes	Absent in infant food and in foods that cannot support the growth of L. monocytogenes (for example frozen fruit and vegetables and pickled products with a pH value ≤4.4); 100 cfu/g for other products
Yeast and mould	10 cfu/g
Total aerobic colony count	10 cfu/g for canned products

Source: Commission Regulation (EC) No 2073/2005

The World Health Organization (WHO) estimates that norovirus is the most common cause of foodborne illness in Europe, with close to 15 million cases each year, causing more than 400 deaths. In addition, there are 100,000 cases of hepatitis A infection in the European region each year, causing 200 deaths (863 notifications in 2021). Pathogenic micro-organisms remain a very important hazard category for food products, although the total number of notifications has been decreasing slightly in recent years. Most issues reported on imported food concern Salmonella findings (641 notifications). Within the processed fruit and vegetables sector, most Salmonella contaminations occurred in edible nuts

In the fruit and vegetable processing sector, the source of microbiological contamination can be dirty water used for irrigation or for cleaning and processing operations. Bacteria and viruses can also be transmitted to products by dirty hands and infected pickers and handlers. In some cases, the source of contamination was a fruit-transporting vehicle that had also been used for transporting animals. As such, it is important for suppliers from developing countries to teach their employees to implement good hygienic practices and to use clean, disinfected vehicles and packaging for transport.

The standard procedure before exporting processed fruit and vegetables to Europe includes laboratory testing for the presence of pathogenic micro-organisms. Although many of those tests can be performed quickly, some require time (e.g. tests for hepatitis A or norovirus). Be sure to use only accredited laboratories when performing microbiological tests. Testing for norovirus, hepatitis A, parasites and toxins may only be available at national or international reference laboratories.

Mycotoxin controls

Mycotoxins are toxic substances produced by fungi commonly known as moulds. These toxins are very stable and can survive severe processes (e.g. heat treatment). The most common mycotoxin contaminations in the processed fruit and vegetables sector are aflatoxins, ochratoxin A and patulin.

Aflatoxins are the most common mycotoxins found in edible nuts, especially in groundnuts, pistachios and hazelnuts. They are also frequently found in dried figs. Limits for aflatoxins have been set for most edible nuts and dried fruit. Ochratoxin A is a mycotoxin mostly found in dried fruits, especially grapes, but also in grape juice. Ochratoxin A is not easy to prevent, as its appearance is connected to climatic conditions.

In 2021, the RASFF reported 399 notifications relating to aflatoxins, particularly in nuts (273). The maximum level of aflatoxins for nuts and dried fruit intended for direct human consumption must be below 2 μg/kg for aflatoxin B1 and below 4 μg/kg for the total aflatoxins content (B1, B2, G1 and G2).

Patulin is especially associated with a range of mouldy fruits and vegetables, particularly rotting apples and figs. Limits between 10 and 50 μg/kg apply to different types of fruit juices. Patulin is not a very common reason for border rejections, however, probably because the industry itself is monitoring it sufficiently.

During 2019 and 2020, EFSA launched a public consultation on the draft scientific opinion about the public health risks of the presence of ochratoxin in food. In its scientific opinion (PDF), EFSA concluded that the presence of ochratoxin A (OTA) in food indicates a possible health concern for certain consumer groups. To ensure a high level of human health protection, the draft Regulation establishes maximum levels for ochratoxin A in certain foods (e.g. dried fruit other than dried vine fruit).

Control of mycotoxins is best achieved through good post-harvesting practices (e.g. timely harvest or proper drying after harvest). Appropriate moisture and temperature conditions during storage and transport and the timely detection and removal of contaminated material from the food supply chain are also important control measures. For example, colour sorting is often used to remove mouldy nuts from bulk shipments.

Limited use of pesticides

The European Union has set maximum residue levels (MRLs) for pesticides in and on food products. If your product contains residues of illegal pesticides or higher amounts of pesticide residues than allowed, it can be withdrawn from the European market. The general public is very concerned about pesticide residues. Both government organizations and non-governmental organizations frequently conduct samples and tests, and this often leads to public blaming and shaming of the industry when residues are found.

The European Union regularly publishes a list of approved pesticides that are authorized for use in the European Union. This list is frequently updated, and there is a general tendency to lower pesticide limits. The European Union Directive on Maximum Residue Levels of Pesticides (PDF) defines these MRLs, and should therefore be checked frequently.

In 2020, the European Union implemented a set of policies and actions called the European Green Deal, with the aim of making the European economy more sustainable and climate neutral by 2050. The action plan also includes a 50% reduction in the use of pesticides and an increase in the share of agricultural land used for organic farming to 25% by 2030. This means that many pesticides will be banned, and residue levels will decrease gradually over the next years.

During 2020 and 2021, several pesticides were withdrawn from the European market: beta-cyfluthrin, benalaxyl, bromoxynil, mancozeb, benfluralin, chlorpyrifos, chlorpyrifos-methyl and thiacloprid.

Note that, in organic products, the use of most pesticides is not allowed. In practice, however, very low levels of residues are permitted in these products. This is only the case if you can prove that these residues are not the result of cross contamination or from illegal use. The applicable limit is often 10 to 100 times lower than the limit for conventional products, however, which generally stands at 0.01 ppm.

Control of chlorate and perchlorate

One of the most recent changes is the level of chlorate. This level has been set at 0.05 mg/kg for most fruit and vegetables (including frozen), 0.3 mg/kg for dates and figs, 0.7 mg/kg for table olives and 0.1 mg/kg for edible nuts. Legislation on chlorate levels entered into force in June 2020. Chlorate is no longer approved as a pesticide, but it can come in contact with food through the use of chlorinated water during processing. Another source may be the use of chlorinated detergents used for cleaning of facilities and processing equipment.

In its scientific opinion on the presence of chlorate in food, EFSA found that current chlorate levels in drinking water and in foods were too high and could have a negative impact on iodine uptake, especially for infants and children. Suppliers of processed fruit and vegetables must therefore control the use of water and detergents in their production facilities. This includes water used for washing, sorting, rehydrating dried fruit, glazing frozen products, diluting concentrated juices and purees and creating berry compotes, as well as for salty, sour and sweet solutions in canned products.

Limited amounts of heavy metals and metalloids

Heavy metals can occur as residues in food because of their presence in the environment, as a result of human activities (e.g. farming, industry or car exhaust) or from contamination during food processing and storage. The European Union regulation on food contaminants sets restrictions for lead (fruit, fruit juices, various kinds of vegetables), cadmium (fruit and vegetables), mercury (food supplements) and tin (canned food and beverages).

In the processed fruit and vegetables sector, high levels of lead or cadmium can be found in frozen fruit and vegetables, as well as in the colours used on glass packaging materials. Higher concentrations of tin used to be found in canned fruit and vegetables as a result of dissolution of the tin coating or tin plating. Given that most tin cans now have a different coating on the inside, few recent alerts have concerned tin found in canned products.

The new limits for lead and cadmium came into force as of 30 and 31 August 2021, respectively.

Other contaminants that must be controlled in processed fruit and vegetables

Several other contaminants are commonly controlled through physical and laboratory tests. They include:

Irradiation

Irradiation is a way to combat microbiological contamination, but its use is limited by European Union legislation for processed fruit and vegetables, as well as for edible nuts. European radiation protection legislation and radioactive contamination legislation define maximum permitted levels of radioactive contamination in food. European buyers commonly request irradiation tests for many food products.

These controls are even more frequent for certain products (e.g. wild-collected dried mushrooms or wild fruit). Wild‑collected fruits and mushrooms may absorb radiation if they are collected in areas of previous nuclear accidents.

Glycidyl esters

Glycerol-based products are contaminants found in vegetable oils and in smaller quantities in some processed foods (e.g. dried preparations for soups, breakfast cereal products, snacks and potato products). Since 2018, glycidyl esters in oils and fats, infant formula, follow-on formula and foods for special medical purposes for infants and young children have been regulated in Regulation (EC) 1881/2006.

Polycyclic aromatic hydrocarbons

A specific problem related to production of banana chips is the occurrence of benzo(a)pyrene and polycyclic aromatic hydrocarbons (PAH). These toxic organic compounds may be formed during the frying of banana slices in coconut oil. The European contaminants regulation added an amendment to the maximum levels of polycyclic aromatic hydrocarbons (PDF) specifically for banana chips in 2015.

In 2020, the food control authorities in Germany made a recommendation on ‘benchmark levels’ for contents of mineral oil hydrocarbons (MOH). These benchmark levels (non-legislative) have been set to 4 mg/kg for MOH, and they apply only to the German market.

Acrylamide

Acrylamide is a contaminant that may be formed in foods during cooking, frying, baking or roasting at temperatures of 120 °C or higher. In November 2019, the European Commission published its recommendation on the monitoring of the presence of acrylamide in certain foods, including roasted nuts, dried fruits and table olives.

SAFE Food Advocacy Europe is campaigning for safer binding levels for acrylamide in foods that are consumed largely by young consumers, as well as for clear and definite maximum contamination levels to be set throughout the EU.

Specific plant toxins

Some toxins may be naturally present in fruit or vegetable parts, or in weeds that can contaminate products in the field. The most important plant toxins for processed fruit and vegetables include tropane, pyrrolizidine alkaloids and cyanide.

The presence of tropane alkaloids is controlled for unprocessed whole, ground, milled, cracked or chopped apricot kernels placed on the market for end consumers. Raw apricot kernels contain the naturally occurring substance amygdalin: a cyanogenic glycoside that results in the release of cyanide during digestion of the kernels in the human gut. Raw, unprocessed apricot kernels, both bitter and sweet varieties, should not be sold for human consumption unless cyanide levels are compliant with the maximum level of 20 mg/kg that is laid down in legislation (PDF).

Contaminants such as tropane and pyrrolizidine alkaloids can be transmitted to fruit and vegetables from certain weeds. Common examples of toxic weeds include ragwort (Jacobaea vulgaris), Datura stramonium, black nightshade (Solanum nigrum) and potato berries. To prevent this contamination, it is recommended to follow the principles of integrated pest management (IPM), including safe planting distance from potential risk areas and the physical removal of weeds while they are in the early development stage.

Nitrates

Nitrate levels are controlled in frozen spinach.

Product composition requests

Buyers and European authorities can reject products if these contain undeclared, unauthorized or excessive levels of food improvement ingredients. There is specific legislation for additives (e.g. preservatives, colours, thickeners), flavourings and enzymes that specify which E numbers and substances are allowed. If you would like to add vitamins into your product, you will have to know which vitamins (see Annex I), sources, formulations and mineral substances are allowed (see Annex II).

Additives that are authorized are listed in Annex II of the Food Additives Regulation. The authorized use of additives is listed according to the category of food to which they may be added. Other annexes to the regulation list food enzymes, flavourings and colorants. Note that pectin derived from apple, citrus fruits or quinces (which is used in the production of jams and marmalades) is not regarded as a food additive.

Vitamins and minerals can be added to fruit juices and fruit nectars. Although no maximum levels have as yet been established, the European Commission is working on a proposal to this end.

Product-specific legislation regarding composition applies to fruit juices and fruit jams, jellies, marmalade and sweetened chestnut purée. The directives indicate which raw materials and additives may be used. In the processed fruit and vegetables sector, problems commonly occur due to the undeclared or excessive use of preservatives.

Product authenticity

Intentionally placing improperly declared products on the European market is regarded as a criminal activity. The main reason to mislead consumers is to gain profit. Nevertheless, many food criminals are not aware that placing undeclared ingredients can pose a serious risk to human health. Some substances can cause allergic reactions, and some are toxic. Many laboratories around Europe have increased testing to discover this type of fraud in food.

Examples of authenticity problems with processed fruit and vegetables include the following:

• Undeclared preservatives used (e.g. sulphites in dried fruit and coconut products or benzoic acid in some pickled products).
• Undeclared use of food colouring (e.g. use of Sunset Yellow colouring in dried candied fruit or fruit purees, or Tartrazine colouring in condiments, spreads, pickled products and soft drinks).
• Declaring a false variety of products (e.g. substituting ‘Alphonso mango’ puree with cheaper varieties such as ‘Totapuri’).
• Wrongly declared ratios in fruit mixes; for example, increasing the share of cheaper berries (e.g. strawberries) and decreasing the share of expensive berries (e.g. raspberries or blueberries).
• Adding water to frozen products – although water glazing is commonly used in some types of frozen products (e.g. fish), it must not be used in frozen fruit and vegetables.
• Adding water to concentrated juices or purees is regarded as fraud, even if added water would not decrease a declared Brix value.
• Lower levels of certain types of fruit than declared in retail products; examples include declaring the product as blueberry nectar with a content of blueberry/bilberry juice lower than 40%, which is not allowed.
• Incorrect quality declaration (e.g. selling virgin or lampante olive oil as extra virgin).

In some cases, selling products to Europe that are not in line with the European requirements is not intentional, but occurs due to lack of processing technology, lack of processing controls or simply through human error. Suppliers from developing countries should therefore regularly implement training and awareness programmes for their employees. In addition, it is important to stay abreast of developments and changes in European food safety legislation.

Safe packaging and informative labelling

Export packaging must be in line with the European legislation on weighting, in addition to being safe for consumer health and for the environment. Packaging made of wood or vegetable materials may be subject to phytosanitary controls. The labelling of packed products must contain various items of information relevant to the consumer.

Safe, well-measured and eco-friendly packaging requests

The content of the packaging must correspond to the quantity (either weight or volume) indicated on the label. Importers will check the size and weight of packaging to ensure that pre-packed products are within the limits of tolerable errors (PDF).

Specific health controls apply to consumer packaging materials that come in contact with food (e.g. cans, jars, bottles). Food contact materials may not transfer their constituents to food in quantities that could endanger human health, change the composition of the food in an unacceptable way or cause deterioration in taste or odour.

One interesting substance to be aware of is bisphenol A (BPA). Known for its use in plastic bottles, BPA is also occasionally used for inner coatings of jar lids. The use of BPA is currently still allowed, but this is under review. Following a re-evaluation of the risks of BPA in food, EFSA has proposed a substantial reduction in the tolerated daily intake. Its draft scientific opinion was open for public consultation until 22 February 2022.

The European Union has announced the introduction of new legislation concerning plastic packaging. From 2021 onwards, some types of single-use plastic have been banned, and the use of other types has been restricted. Items on the banned list include oxo-degradable plastic and expanded polystyrene take-away food and drink containers. From 2029, member states are obliged to collect 90% of their disposable plastic bottles.

By 2030, all bottles in the European Union must be made from at least 30% recycled materials. In addition, by 2024, all beverage bottles less than 3 litres must be closed using only tethered caps. Tethered caps are caps that remain attached to the bottle once it is opened. The aim of this rule is to reduce the number of caps found in nature (bottle caps represent 10% of all plastic litter found on European beaches).

From 1 January 2021, the European Union has applied a tax on non-recycled plastic packaging waste, at a rate of €0.80/kg. This tax goes into the EU budget and is used to support member states during the coronavirus pandemic.

Labelling requirements for retail food products

In the European Union, labelling rules ensure that citizens receive comprehensive information about the content and composition of food products. Labelling helps consumers make informed choices when buying foodstuffs.

Regulation on the provision of food information to consumers defines various obligations, including the following:

• Nutritional information: energy value and quantities of fat, saturates, carbohydrates, protein, sugars and salt per 100 g. Additional nutritional information (e.g. fibre content, vitamins, minerals) may be included on retail products on a voluntary basis.
• Identification of allergens (e.g. soy, nuts, gluten) in the list of ingredients.
• Indication of origin (since April 2020). For example, if Algerian dates are packed in Germany, the packaging must indicate the origin. This can be done by indicating ‘Algeria’ as the origin, by noting ‘non-EU’ or by declaring ‘dates do not originate from Germany’. It is in your interest to negotiate with the buyer to clearly state your country as the origin, although you usually do not have control over this.
• Mandatory information must be printed in a minimum font size of 1.2 mm.

Some of the obligations (e.g. minimum font size) relate only to consumer-packed products. Suppliers of bulk products are also asked to provide relevant information on allergens and composition.

Additional nutritional information (e.g. fibre content, vitamins, minerals) may be included on retail products on a voluntary basis. Several voluntary nutritional labelling schemes have been developed in Europe to provide consumers with better information about healthier food choices. The best-known and most widely accepted by consumers is Nutri-Score. Other schemes include Nutrinform (Italy), Front of Pack Nutritional Labelling (also known as ‘traffic light’, United Kingdom) and Keyhole (Denmark, Lithuania and Sweden).

In May 2020, the European Commission published a report on additional forms of expressing nutrition declaration (PDF). According to this report, the European Commission will prepare a legislative proposal to introduce mandatory harmonized front-of-pack nutrition labelling at the EU level to help consumers make better choices for healthier food.

The European nutrition and health claims are important to exporters from developing countries aiming to sell labelled retail products directly to end consumers. They do not apply to business-to-business communication. European labelling legislation (Chapter 2, Article 3) prohibits misleading consumers. Claims that any food can prevent, treat or cure human disease cannot be included on labels in the European Union. It is therefore better to avoid making any health or nutritional claims that are not substantiated by scientific evidence.

Novel foods must be authorised before entering the European market

The term ‘novel food’ refers to all foods that were not consumed to a significant degree in the European Union before May 1997. Novel food can be newly developed, innovative food, food produced using new technologies and production processes, or food that is or has been traditionally eaten outside of the European Union. Novel food must be approved, safe for consumption and properly labelled.

The new Regulation (EU) 2015/2283 on novel foods has applied since 1 January 2018. This new legislation improves conditions so that food businesses can more easily bring new and innovative foods to the European market, while maintaining a high level of food safety for European consumers. For many suppliers, however, the process of placing novel foods on the European market is still difficult and expensive.

The new regulation simplifies the authorization process for the notification of traditional foods from third countries, by requiring evidence of safe use in at least one country outside of the European Union for a period of 25 years. A notification is sent to the European Commission and then forwarded to all member states and EFSA. Within four months of receiving the valid notification, a member state or EFSA may submit safety objections to the traditional food in question.

Novel foods frequently appear in the processed fruit and vegetables sector, especially in the sub-sector of ‘super fruit’ or ‘super food’ ingredients. Authorized novel food includes products traditionally eaten in non-European Union countries (e.g. noni and baobab juice, maca powder, aswaganda) or food produced using the latest technological innovations, such as high-pressure fruit juice (an example of a food derived from new production processes).

2. What additional requirements do buyers often have?

European buyers also require additional food safety certification in the form of specific certification performed by an independent control body. Some buyers will have their own control lists and a number of different quality requests. In addition to food safety and product quality requests, there is an increasing demand for proof of sustainable and ethical business practices.

Product quality requirements

The quality of processed fruit and vegetables is determined by a variety of factors, depending on the type of product. For example, the quality categories for frozen and dried fruit and vegetables and for edible nuts are defined largely by fruit size and the allowable percentage of defective produce. For homogeneous products (e.g. juices, purees, fruit spreads), there are many quality criteria, including colour, flavour, chemical composition and Brix value (sugar content in water solution).

Most quality criteria are defined by industry standards, and not by official European legislation. This is because some criteria (e.g. taste or flavour) are subjective and thus difficult to measure. The most common quality standards for specific products include the following:

Quality of frozen fruit and vegetables: Defined mostly by Codex Alimentarius standards. Codex standards currently apply to many frozen products, including peas, strawberries, raspberries, peaches, bilberries, blueberries, broccoli, cauliflower, spinach, Brussels sprouts and green beans. The industry has set several additional criteria for determining the quality of frozen products. For example, the Brix value of frozen fruits is important for the processing industry, while retailers are more likely to value uniformity of shape and colour for individually frozen products.

Quality also is determined by the type and variety of frozen products. For example, frozen wild bilberries (Vaccinium myrtillus) are more valued by processors due to their higher anthocyanin levels and stronger colour and flavour, while packers and retailers prefer cultivated blueberries (Vaccinium corymbosum) due to their larger size and more uniform shape.

Quality of dried fruit and nuts: Commonly defined by the standards of the United Nations Economic Commission for Europe (UNECE). These standards apply to many nuts, including almonds, Brazil nuts, cashews, coconuts, hazelnuts, macadamia nuts, pine nuts, pistachio nuts and walnuts. The UNECE standards for dried products include apricots, bananas, grapes, mangoes, melons, papayas, pears, pineapples, prunes and tomatoes. The Codex Alimentarius also includes standards for dried apricots, raisins, pistachios, dates, desiccated coconuts, peanuts and dried mushrooms.

Quality of fruit and vegetable juices: In Europe, this is based on the EU Fruit Juice Directive and on Industry Codes set by the European Fruit Juice Association. The European Fruit Juice Directive defines several quality aspects, including authorized ingredients, labelling rules and minimum Brix values for reconstituted fruit juices and purees. There is also a Codex Alimentarius standard for fruit juices and nectars, which can be used to define parameters for coconut water, which is not included in the European fruit juice directive.

Quality of jams, jellies and marmalades: In Europe, this is based on the European regulation for fruit jams, jellies and marmalades, and sweetened chestnut purée. This regulation basically defines a minimum content of fruit pulp and/or purée in finished products. European legislation does not include many other product characteristics, like consistency (homogenized, with fruit pieces, with seeds or ‘seedless’), Brix value, colour, taste or type of sweetener used. There are also Codex Alimentarius standards for jams that define quality categories (e.g. ‘extra jam’ and ‘high fruit jam’).

Quality of canned fruit and vegetables: Usually defined by several Codex Alimentarius standards. The Codex has currently published standards for processed tomatoes, apple sauce, canned pineapples, canned raspberries, canned strawberries, fruit cocktails, tropical fruit salad, chestnuts and chestnut purée, mango chutney, canned bamboo shoots, canned stone fruits, pickled fruit and vegetables, certain canned vegetables, coconut milk and cream. With regard to quality, Codex has also published Guideline Procedures for the Visual Inspection of Lots of Canned Foods for Unacceptable Defects.

Food Safety Certification as a basis for entering the European market

Although food safety certification is not obligatory under European legislation, it has become a must for almost all European food importers. Most established European importers will not work with you if you cannot provide proof of some type of food safety certification as the basis for cooperation.

The majority of European buyers will ask for Global Food Safety Initiative (GFSI) certification. The following are the most popular programmes for processors and traders of fruit and vegetables:

• International Featured Standards (IFS)
• British Retail Consortium Global Standards (BRCGS)
• Food Safety System Certification (FSSC 22000)

Please note that this list is not exhaustive and food certification systems are constantly under development. The majority of food safety certification programmes are similar to the ISO 22000 standard.

Although different food safety certification systems are based on similar principles, some buyers may prefer one specific management system. For example, British buyers often require BRC, while IFS is more common for German retailers. It is also important to note that food safety certification is only a basis for starting to export to Europe. Serious buyers will usually visit/audit your production facilities within the first few years of cooperation.

In the fruit juice industry, the most recent development is SGF certification, which is aimed at increasing safety, quality and fair competition in the fruit juice sector through industrial self-regulation. This scheme certifies fruit processing companies, packers and bottlers, traders and brokers for fruit juices, along with transport companies and cold stores in almost 60 countries.

For concentrated juices and purée producers, an important part of the SGF certification system is known as the IRMA (International Raw Material Assurance). In an ideal situation, the fruit juice industry should have the whole supply chain under control, farmers should hold GlobalGap certification, fruit processors should hold IRMA certification, and juice bottlers should be certified by the IQCS (International Quality Control System for juices and nectars). In addition to fruit processors, IRMA certification also applies to traders/brokers, transport companies, producers of semi-finished products and storage facilities.

Laboratory control

In practice, food safety certification is less important than the physical approval of the products. For this reason, buyers in Europe frequently ask for laboratory tests. In Europe, it is common practice for deliveries to be accompanied by documentation from accredited laboratories that is not older than six months.

The credibility of laboratories that perform the testing is important to European buyers. This could be a potential issue for some exporters from developing countries, as laboratories must be able to perform all required tests. In some developing countries, laboratories are able to perform only a limited number of tests and analysis samples must be sent to other countries for some. It is common for European buyers to ask for tests for more than 500 different pesticide residues.

Retail chains and other private sector requests

Although most European retailers support the certification schemes listed above, many will have additional requirements. Many supermarket chains contractually oblige suppliers to meet comprehensive quality assurance requirements, including unannounced inspections at processing facilities.

One recent trend involves asking for laboratory tests proving that specific pesticide residues are present in significantly lower quantities than legally required. These requirements have yet to be harmonized, even within networks of the same retailer. For example, in some countries, the German retailer Lidl requires that the sum of several residues must be at least 50% below the EU limits, while shifting this limit to 30% in other countries.

The British retailer Tesco developed the specific certification scheme known as ‘Tesco Nurture’. This certification scheme is used for producers of fresh fruit and vegetables, as well as for producers of edible nuts. Suppliers of this retail chain have already been required to hold GlobalG.A.P. certification, and they must now also be certified for the Tesco Nurture programme through an additional Nurture Module in the GlobalG.A.P. scheme.

Another initiative, known as ‘free from pesticide residues’, allows for the controlled use of phytochemicals combined with biological control and natural stimulation. Under these schemes, residue-free means that any active ingredient is measured at under 0.01 ppm when analysed under European regulations on maximum residue levels. At the moment, several of these initiatives are run by private certification companies across Europe. To date, however, they are not widely recognized by all market segments.

Some ingredient users (e.g. the baby food industry) ask for organic certification or for controlled use of pesticides. In some cases, ingredient users ask suppliers to follow strictly prescribed plant protection plans and to use only pesticides from specifically developed lists.

Sustainability and corporate social responsibility (CSR) requests

Social, environmental and ethical activities are becoming very important in the European processed fruit and vegetables industry. These activities are implemented and monitored from the farm and production level to the processing (factory) level and up to delivery to the end consumer. Companies have different requirements regarding social responsibility. Some companies require adherence to their own codes of conduct or to international standards, such as the Supplier Ethical Data Exchange (SEDEX), the Ethical Trading Initiative (ETI), the Business Social Compliance Initiative code of conduct (BSCI), BCorp or Fair for Life.

To improve sustainability in the production and sourcing of nuts, a group of mainly European companies and organizations formulated the Sustainable Nuts Initiative in 2015. The major objective of this initiative is to improve circumstances in nut-producing countries and to work towards supply-chain sustainability. A similar initiative is the Sustainability Initiative Fruit and Vegetables (SIFAV). In 2021, SIFAV launched its new 2025 strategy, with a clear focus on reducing the environmental footprint across the supply chain, improving working conditions, wages and incomes, and strengthening due diligence, reporting and transparency.

In addition, leaders in the fruit juice industry have established the Sustainable Juice Covenant (SJC) with the global aim of achieving 100% sustainability in the sourcing, production and trade of fruit and vegetable-derived juices, purees and their concentrates by 2030. The European Fruit Juice Association (AIJN) established the Juice CSR Platform to support, guide and inspire juice stakeholders to integrate corporate social responsibility throughout the supply chain.

Sustainability has become one of the most important topics on the official European agenda. The European Union has implemented a set of policies known as the European Green Deal, with the aim of increasing the sustainability of the European economy and making it climate neutral by 2050. These policies also include specific measures that could affect supply from developing countries. They further include a 50% reduction in the use of more hazardous pesticides and increasing the share of agricultural land used for organic farming to 25% by 2030.

Sustainability is also an important part of the new certification schemes. Several existing certifications focusing on environmental and social aspects are described in the sections below. Some new certification schemes are based on CO2 emissions, including MyClimate or Carbon Footprint Certification. One certification scheme that supports several aspects of sustainability is Planet Proof. Planet Proof covers several themes, including energy and climate; crop protection, biodiversity and landscape; as well as soil fertility, clean water, packaging and waste.

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

Name of certification	Type	Cost for companies	Most used in European end markets	Further information on obtaining certification
BRCGS Global Food Safety Standard	Food Safety	A typical 2-day BRCGS Certification Audit costs between USD 5,300 and USD 7,500, excluding travel expenses	UK, France, the Netherlands, Denmark, Belgium, Spain, Italy, Poland, Sweden	To find a consultant or certification body, visit the partner sections of the BRCGS website
FSSC 22000	Food Safety Management Systems	Costs vary depending on the size and complexity of your business	Sweden, the Netherlands, Denmark, France, Italy	To find a consultant or certification body, visit the partner sections of the FSSC website
IFS International Featured Standards	Food Safety	Costs vary depending on the size and complexity of your business	One of the most popular certification standards in Europe. Italy, Germany, Spain, Denmark, Belgium, France, Poland, the Netherlands	To find a consultant or certification body, visit the partner sections of the IFS website
SGF	Juice Safety	Voluntary Control System; Membership starts at €5,000 for companies with revenues below €6.25 million and one production plant. An additional €4,500 is charged for each additional production plant	Germany, Spain, Greece, France	To find a consultant or certification body, visit the partner sections of the SGF website
GlobalG.A.P	Crops for Processing Safety Standard	The costs vary depending on farm size. Consult the fee tables.	Portugal, Italy, Greece, Spain, the Netherlands	To find a consultant or certification body, visit the partner sections of the GlobalG.A.P website
SMETA (Sedex Members Ethical Trade Audit)	Social auditing standard	The costs start at USD 700 per factory	All of the EU	To find a consultant or certification body, visit the partner sections of the Sedex website
BSCI	Working conditions audit	amfori membership fees start at €3,310 for companies with revenues below €20 million. Consult the fee tables.	All of the EU	For more information, consult the Audit Integrity Program
Fair for Life	Social responsibility certification	Certification costs vary depending on the size and complexity of the operation/supply chain, the location.	Germany, Spain, France, the UK	Consult the Fair for Life website for more information on the certification
Fairtrade	Sustainability certification	Use the FLOCERT calculator to see what Fairtrade certification is likely to cost you	All of the EU	Consult the Fairtrade website for more information on certification
Rainforest Alliance	Sustainability certification	There are four cost components: supply chain audit fees, sustainability differential, sustainability investment, and a volume-based royalty. Consult the website for more information on pricing.	All of the EU	To find a consultant or certification body, visit the partner sections of the Rainforest Alliance website

Source: Compiled by M-Brain

3. What are the requirements for niche markets?

Increasing demand for certified organic products

To market processed fruit and vegetables and edible nuts as organic in Europe, they must have been grown using organic production methods according to the European legislation. Growing and processing facilities must be audited by an accredited certifier before you can use the European Union’s organic logo on your products, as well as the logo of the standard holder (for example, the Soil Association in the United Kingdom or Naturland in Germany).

In March 2021, the EU Commission launched an organic action plan for the EU. This plan aims to achieve the European Green Deal target of increasing the share of agricultural land used for organic farming to 25% by 2030. Be aware that the new EU regulation on organic production is expected to enter into force in 2022. New legislation relating to the organics sector was introduced on 1 January 2022. This legislation seeks to respond to the challenges posed by the rapid expansion of organic farming by providing a more effective legal framework for the industry.

Under the new EU regulation, inspection of organic production and organic products will be stricter, in order to prevent fraud. For example, you will need to prove that you have implemented all precautionary measures to avoid cross contamination (for example, placing a barrier between your fields and those of any neighbours who spray their orchards). If traces of pesticides are found in your products and you fail to prove that you have implemented all the required measures, you will be decertified automatically.

The procedure for the certification roughly follows these five steps:

• Step 1 – Follow organic production rules: One common practice is to engage agronomists who are experts in organic production in order to implement the best practices and to obtain guidance that will prepare producers and exporters for organic certification. When engaging consultants, be aware that the same company cannot provide both consulting and certification services, as this is considered a conflict of interest.
• Step 2 – Apply for certification: When companies decide that their production and processing are ready for organic certification, they can select and negotiate a certification fee with any of the EU recognized control bodies that have been approved by European Union regulation (EC) No 1235/2008. One frequent practice for small farmers is group certification, as that may save costs.
• Step 3 – Inspection: During the inspection phase, an inspector verifies whether the organic management plan is consistent with reality and identifies any issues. After evaluating the report, a control body decides whether a certificate can be issued or whether any non-conformities must be corrected first.
• Step 4 – Certification: Once the control body confirms that the organic management plan is consistent with reality, an organic certificate is issued. 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. The logo must be accompanied by a certifier code number. Be aware that an organic certificate is valid for one year from the date it was issued.
• Step 5 – Submission of the inspection certificate: Every shipment of organic products must be accompanied by an inspection certificate from the selected certifier, which must be submitted electronically through the central platform known as TRACES. European importers must also submit an application form for the import of organic products from exporters from developing countries. This application form must include the company information, the name of the certifier and the date of the most recent inspection. The importer must also submit confirmation from a third party, stating that the certifier meets the requirements of ISO standard 65 / EN 45011.

Social and ethical requests

The two most commonly used sustainability certification schemes are Fairtrade and Rainforest Alliance. Fairtrade international has developed a specific set of standards for processed fruit and vegetables and edible nuts for small-scale producer organizations. These standards define protective measures for farmers and workers in processing facilities. The standards also define terms of payment, Fairtrade Minimum and Premium Price for conventional and organic products from several countries and regions.

Responsible business practices and the fair treatment of all people in the supply chain are always welcomed. As confirmed by a report on due diligence published by the European Commission in 2021, however, voluntary measures have not been effective in encouraging companies to identify, account for and mitigate negative human rights and environmental impacts in their supply chains. For this reason, the EU announced mandatory legislation on due diligence, which is intended to ensure respect for human rights and the environment throughout the entire supply chain.

According to the draft legislation, the rules should apply to all companies operating in the European market, including non-European suppliers. Companies must act in line with due-diligence obligations and take measures to prevent harm to human rights, the environment or good governance. Companies must pay a penalty if they cause harm unless they can prove that they have acted in line with due-diligence obligations. This would also improve protection for the rights of victims or stakeholders in third countries.

Ethnic certification

Islamic dietary laws (halal) and the Jewish dietary laws (kosher) impose specific restrictions in the diets of those following them. If you would like to focus on Jewish or Islamic ethnic niche markets, you should consider implementing the halal or kosher certification schemes.

This study was conducted on behalf of CBI by Autentika Global and updated by M-Brain.

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