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

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All foods sold in Europe must be safe for consumption. The purposes of the various requirements range from the approval of additives to the banning of harmful contaminants. Information labels on food packaging are also strongly controlled. What’s more, private requests are becoming equally important as mandatory requirements. Exporters need to monitor the market requirements frequently, because in 2020 alone there have been changes for nearly 60 different pesticide residues.

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 establishment of the European Food Safety Authority (EFSA). EFSA 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, and that includes exporters from developing countries. To achieve this, all food business operators need to implement the Hazard Analysis of Critical Control Points (HACCP) system in their daily operations.

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

Tariff barriers

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

For most processed fruit and vegetables, tariffs are calculated as a certain percentage of import value, also called ad valorem. For example, prunes imported from Argentina face 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 on the import of fig paste from Turkey). Also, applied tariffs can be a combination of ad valorem and specific. This is for example the case with the import of strawberry jams from China which have an ad valorem rate of 24.00% and an extra rate of €23.00 /100 kg.

Another tariff barrier are tariff quotas, however such quotas are rarely used for imported processed fruit and vegetables. One example is the import of olive oil from Tunisia, where zero tariffs are applied, but after the exported volume reaches 56,700 tonnes, a regular tariff of €124.50 per 100 kg applies. Please note that European importers must have an import license to benefit from reduced tariff rates under the tariff quotas.

Tip:

  • Use the Market Access Map to analyse potential competitive advantages based on applied tariffs for your country and other countries. You can learn how to use “compare” and other functions from instructional MacMap videos.

Phytosanitary inspection

The European Union inspects food products to protect citizens, animals and plants from diseases and pests. A common way of protection is inspection of food and the issuing of a phytosanitary certificate before export. Phytosanitary certificates are issued for plants or plant products which can be reproduced within Europe after imports, such as bulbs, tubers or food containing seeds. Phytosanitary certificates are not required for most processed fruit and vegetables with the exception of whole dried fruit, vegetables and in-shell nuts.

Official border control for food imported to 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. Those stricter conditions usually include a health certificate and an analytical test report for a certain percentage of the shipments from specified countries. Products from countries that have shown repeated non-compliance are put 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 is subject to official (physical) controls, since the first responsibility for their safety lies with the commercial operators such as importers. Importers will therefore conduct most of the checks required to assure a product is safe, and 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 and vegetables and edible nuts (as of October 2020)

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

Apart from 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.

During 2019, the RASFF reported 4,118 non-compliances found by official inspections, of which 1,499 were classified as border rejections. In the processed fruit and vegetables category, most problems were related to the import of edible nuts (mainly mycotoxins), followed by fruit and vegetable products (mainly pesticide residues). However, it is estimated that the number on non-compliances is much larger, since results of many controls conducted by private companies are not recorded by RASFF.

Tips:

  • Stay up to date with the Official Controls Regulation on the European Commission website. The list is updated regularly. Even if your country is not on the list, be aware of the most common contaminations for your product and implement all possible preventive measures.
  • Search in the RASFF database to see examples of withdrawals from the market and the reasons behind these withdrawals.
  • Subscribe for the EFSA newsletter (free of charge) to receive news about European food safety developments.
  • Implement an HACCP system into your daily practice. Even if HACCP is not an obligation in your country, you must comply with the European food safety regulations.

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 minimise 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 a number of 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, but some type of insects can develop inside the fruit and continue to grow during storage. In order to prevent contamination with insects, suppliers from developing countries should implement preventive measures such as fumigation and temperature treatments. When using fumigation, only apply officially approved fumigants. For example, methyl bromide as a fumigant is banned in the European Union.

Other types of contamination with foreign bodies include earth, stones, glass or metal parts (for example from agricultural machinery and tools). Usage of optical, metal and similar detectors is recommended to prevent this type of contamination. However, physical sorting and eye-hand control is always recommended, even if detectors are installed.

Reducing the risk of microbiological contaminants

The main reasons for border rejections for imported processed fruit and vegetables are related to microbiological contamination. The most common types of microbiological contaminants in processed fruit and vegetables are salmonella, Escherichia Coli, listeria and viruses such as norovirus and Hepatitis A viruses. The European regulation on microbiological criteria for foodstuff sets limits for pathogenic micro-organisms, their toxins and metabolites. Table 2 lists the limits for most common pathogens.

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

Pathogen/Toxin

Limit

Salmonella

Absent

E.Coli

Absent

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 below pH ≤4.4); 100 cfu/g for other products

Yeast and Mold

10 cfu/g

Total Aerobic Colony Count

10 cfu/g for canned products

The World Health Organisation (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. Also, there are 100,000 cases of hepatitis A infection in the European region each year, causing 200 deaths. During 2019, the RASFF reported 399 notifications related to microbiological contaminants. Most issues reported on imported food are about Salmonella findings. Within the processed fruit and vegetables sector, salmonella mostly 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. Also, dirty hands and infected pickers and handlers can transmit bacteria or viruses to products. There were even cases in which the source of infection 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 and 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 microorganisms. Many of those tests can be performed quickly but some require time, such as the 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.

Tips:

  • Follow the most recent trends on food safety testing developments. More quick tests on site, and the increased automation and computerisation of food safety testing methods can help you a lot in your production process. Read the news on the webpage of European Food Safety authority (EFSA) to be updated on the latest food safety developments.
  • Follow the Codes of Hygienic Practice published by Codex Alimentarius to prevent microbiological contamination. Specific codes of Hygienic Practice are available for a wide range of processed fruit and vegetables, such as canned, frozen, dried products and edible nuts.
  • Read the guidelines for produce washing (pdf) and minimising the risk of microbial contamination of berries (pdf) on the webpage of European Association of Fruit and Vegetables Processors.
  • Transport fruit and vegetables from farmers to the processing facility in clean vehicles.
  • Regularly check the water you use for cleaning and processing fruit and vegetables. Infected water is one of the most common sources of microbiological contamination.

Mycotoxins control

Mycotoxins are toxic substances produced by fungi commonly known as moulds. These toxins are very stable and can survive severe processes such as 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 have been set for aflatoxins in most edible nuts and dried fruit. Ochratoxin A is a mycotoxin most commonly 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.

During 2019, the RASFF reported 409 notifications related to aflatoxins in imported edible nuts and dried fruit. More than 50% of those notifications are related to import of peanuts from Argentina (68 cases), the United States (48 cases), China (33 cases) and Egypt (33 cases). 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. In particular rotting apples and figs. For different types of fruit juices limits between 10 and 50 μg/kg apply. However, patulin is not a very common reason for border rejections, 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. New studies suggest that ochratoxin A may be genotoxic and carcinogenic. If new studies on toxicity of ochratoxin A validate these results, EFSA may reduce the current limits. However, more scientific data is necessary. The latest results show that the highest concentration is not found in processed fruit and vegetables but in plant extract formulas, flavourings, essences and chili pepper.

Control of mycotoxins is best achieved by good post-harvesting practices, such as 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.

Tips:

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 organisations and non-governmental organisations frequently conduct samples and tests, which often leads to public blaming and shaming of the industry if residues are found.

The European Union regularly publishes a list of approved pesticides that are authorised for use in the European Union. This list is frequently updated and there is a general tendency to lower pesticide limits. There were 60 changes to this list during 2020. The European Union Directive on Maximum Residue Levels of Pesticides (pdf) defines these MRLs and should therefore be checked frequently. Some important recent changes include the level of Chlorpyrifos, which is set to 0.01ppm from November 2020, and dimethoate and omethoate in cherries.

In 2020 the European Union implemented a set of policies and actions called the European Green Deal with the aim to make 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 of 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 and will be withdrawn from the European market, namely: beta-cyfluthrin, benalaxyl, bromoxynil, mancozeb, benfluralin, chlorpyrifos, chlorpyrifos-methyl and thiacloprid.

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

Control of chlorate and perchlorate

One of the most recent changes, is the level of chlorate. It is set to 0.05 mg/kg for most fruit and vegetables (including frozen), 0.3 for dates and figs, 0.7 to table olives and 0.1 to 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 by 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 negatively impact iodine uptake, especially among infants and children. Therefore, processed fruit and vegetable suppliers must control the use of water and detergents in their production facilities. This includes water used for washing, sorting, rehydration of dried fruit, glazing of frozen products, dilution of concentrated juices and purees, creation of berry compotes, and for salty, sour and sweet solutions in canned products.

Tips:

  • Use the European Union pesticides database to find the MRLs that are relevant for your products. Select your product or the pesticide you use, and the database shows the list of the MRLs associated with it.
  • To be prepared for potential new changes in the MRLs, read the Ongoing Reviews of MRLs in the European Union.
  • A good way to reduce pesticide amounts is to apply Integrated Pest Management (IPM). IPM is an agricultural pest control strategy that uses natural control practices in addition to chemical spraying. For more information about Integrated Pest Management see the FAO website.
  • Work closely with farmers to have full control of the use of pesticides in your raw materials. Engage with plant protection experts who can regularly guide and advise farmers on the sustainable use of pesticides. For example, with a subscription to a professional weather services, or with the use of agricultural weather stations, it is possible to forecast the appearance of potential pests and plant illnesses and to limit the use of pesticides.
  • Check with your buyers if they have additional requirements on MRLs and pesticide use.

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 such as farming, industry or car exhausts, 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, a high lead or cadmium presence can be found in frozen fruit and vegetables, but also in 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 tinplate. However, since tin cans now generally have a different coating on the inside, there are not many recent alerts of tin found in canned products.

During 2020, the European Commission launched a review process for the maximum allowed levels of lead and cadmium. New limits for some products may be set in 2021. The most significant changes are expected to apply to infant food such as baby purees and drinks.

Tips:

  • Work closely with the growers of the products you are sourcing. Make sure they invest in good agricultural practices; this will give you control of the supply chain. 
  • Check the sampling and analysis guidelines on the European Commission page for food contaminants.

Other contaminants that must be controlled in processed fruit and vegetables

There are several other contaminants which are commonly controlled via physical and laboratory tests. Those include:

Irradiation

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

For some products, such as wild-collected dried mushrooms or wild fruit, this control is even more frequent. 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 food, such as dried preparations for soups, breakfast cereal products, snacks and potato products. In 2018, the European Union published new maximum levels for glycidyl esters (pdf) in foods for special medical purposes and/or intended for infants and young children.

Polycyclic aromatic hydrocarbons

A specific problem related to production of banana chips is the occurrence of benzo(a)pyrene and polycyclic aromatic hydrocarbons (PAH). Those toxic organic compounds may be formed during the frying of banana slices in coconut oil. The European contaminants regulation set an amendment for the maximum levels of polycyclic aromatic hydrocarbons (pdf) specifically for banana chips since 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) are set to 4 mg/kg for MOH and they only apply to the German market.

Acrylamide

Acrylamide is a contaminant which 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.

Data collected and published in October 2020 will lead to new regulation stipulating a maximum level of acrylamide in foods. It is expected that the new regulation will be published soon and set a maximum level for acrylamide in baby foods, more specifically in baby biscuits and cereal-based baby foods.

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 the final consumer. Raw apricot kernels contain the naturally occurring substance amygdalin – a cyanogenic glycoside which 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 ML of 20 mg/kg that is set 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 are ragwort (Jacobaea vulgaris), Datura stramonium, Black nightshade (Solanum nigrum) and Potato berries. In order to prevent this contamination, it is recommended that you follow the principles of integrated pest management (IPM), such as 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.

Tips:

Product composition requests

Buyers and European authorities can reject products if they have undeclared, unauthorised or excessive levels of food improvement ingredients. There is specific legislation for additives (like preservatives, colours, thickeners), flavourings and enzymes that list what E numbers and substances are allowed. If you want 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 authorised are listed in Annex II of the Food Additives Regulation. The authorised use of additives is listed according to the category of food to which they may be added. Other annexes of 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 considered to be a food additive.

Vitamins and minerals can be added to fruit juices and fruit nectars. Maximum levels have not been established yet, but the European Commission is working on a proposal for those.

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 because of the undeclared or excessive use of preservatives.

Product authenticity

Intentionally placing wrongly declared products on the European market is considered as a criminal activity. The main reason to mislead consumers is to gain profit. Still, many food criminals are not aware that placing undeclared ingredients can present 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.

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

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

Sometimes selling products to Europe which are not in line with the European requirements is not intentional, but it occurs due to lack of processing technology, lack of processing controls or simply through human error. Therefore, it is important that suppliers from developing countries regularly implement training and awareness programmes for their employees. Also, it is important to be keep up-to-date with the developments and changes in European food safety legislation.

Tips:

  • Read more about additives for processed fruit and vegetables in the Food Additives Regulation under section four.
  • Use the European Commission’s Food Additives Database to check which food additives are allowed in Europe.
  • Find a list of vitamins and minerals and their forms, which can be added to foods in Europe.
  • E numbers indicate approval by the European Union. To obtain an E number, the additive must have been fully evaluated for safety by the competent food safety authorities in the European Union. For an overview of E numbers, refer to the specifications for food additives in the annex of the Food Additive Regulation.
  • Prepare in advance for the potential changes of food additives limits by checking the re-evaluation of food additives on the website of European Commission. 

Safe packaging and informative labelling

Export packaging must be in line with the European legislation on weighting, be safe for consumer health and for the environment. Packaging made of wood or vegetable materials may be subjected 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 with the indicated quantity (in weight or volume) on the label. Importers will check packaging size and weight to ensure that pre-packed products are within the limits of tolerable errors (pdf).

Specific health controls apply for consumer packaging materials that come in contact with food (like cans, jars, or 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 deteriorate the taste and odour.

An interesting substance to be aware of is Bisphenol A (BPA). BPA is known for its use in plastic bottles but is also sometimes used in inner coatings of jar lids. The use of BPA is currently still allowed, but its use is under review. EFSA has announced that the official opinion on the BPA usage in food contact materials will be published soon.

The European Union has announced the introduction of new legislation concerning plastic packaging. From 2021 onwards, some types of single-use plastic will be banned and the use of other types will be 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 plastic throw-away bottles.

By 2030, all bottles in the European Union must be made from at least 30% recycled materials. Also, by 2024 all beverage bottles below 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 that are found in nature, as bottle caps represent 10% of plastic litter found on European beaches, for example.

From January 1st 2021, the European Union started to apply a tax on non-recycled plastic packaging waste, at a rate of €0.80 per kilogramme. 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, the labelling rules ensure citizens get comprehensive information about the content and composition of food products. Labelling helps consumers make an informed choice while buying their foodstuffs.

Regulation on the provision of food information to consumers defines obligations such as:

  • Nutritional information: energy value and the quantities of fat, saturates, carbohydrates, protein, sugars and salt per 100 g. It is possible to place additional nutritional information on retail products on a voluntary basis, such as content of fibre, vitamins or minerals.
  • Presentation of allergens (like soy, nuts or 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. The way to do this is to indicate “Algeria” as the origin, but the packer can also write “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 written with a minimum font size of 1.2 mm.

Some of the obligations (such as the minimum font size) relate to consumer-packed products only. However, as a supplier of bulk products, you will be asked to provide relevant information on allergens and composition.

It is possible to place additional nutrition information on the retail products on a voluntary basis, such as fibre fibre, vitamin or mineral content, for example. In order to better inform consumers about healthier food choices, several nutritional labelling voluntary schemes were developed in Europe. The most famous and widely consumer-accepted nutritional labelling scheme is nutri-score, but there are other schemes such as Nutriform battery (Italy), Front of Pack Nutritional Labelling (also known as ‘traffic light’, the United Kingdom) or Keyhole (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 a harmonised mandatory front of pack nutrition labelling at EU level to help consumers make better choices for healthier food. 

The European nutrition and health claims are important for exporters from developing countries aiming to sell labelled retail products directly to the final consumers. It does not apply to business-to-business communication. European labelling legislation forbids misleading consumers (Chapter 2, Article 3). Claims that any food is preventing, treating or curing a human disease cannot be made on labels in the European Union. So, it is better to avoid health or nutritional claims that are not substantiated by scientific evidence.

Tips:

  • Visit the Access2Markets for more information on food labelling. For practical guidance on food labelling for pre-packed products, check the official guidance document (pdf) published by European Commission on the control of compliance of nutrient values declared on a label.
  • Note that the presence of allergens is becoming more and more important. The chance of cross-contamination (for example when a product is processed in a factory that also processes peanuts) is sometimes even considered to be possible at farm level.
  • Read the official answers from the European Commission on the most frequently asked questions regarding Food Labelling regulation published in 2018.
  • For product-specific packaging requirements, read product-related studies about promising export products.
  • Be aware of the new plastic packaging rules in Europe and make sure to adapt to new packaging materials in time.

Novel foods must be authorised before entering the European market

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

As of 1 January 2018, the new Regulation (EU) 2015/2283 on novel foods is applicable. 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. Still, the process of placing novel foods on the European market is difficult and expensive for many suppliers.

The new regulation simplifies the authorisation 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.

In the processed fruit and vegetables sector, novel foods frequently appear, especially in the subsector of “superfruit” or “superfood” ingredients. Authorised novel food includes products traditionally eaten in non-European Union countries such as noni and baobab juice, maca powder, aswaganda or food produced using the latest technological innovations such as high-pressure fruit juice (which is an example of a food derived from new production processes).

Tip:

  • To check if your product or ingredient is authorised as a novel food check the Novel Food Catalogue. Note that the list is non-exhaustive and serves as orientation on whether a product will need authorisation under the Novel Food Regulation. Also, check the Union list of novel foods. This list shows novel foods that do not need notification.

2. What additional requirements do buyers often have?

European buyers will also require additional food safety certification in the form of specific certification performed by an independent control body. Some of the buyers will have their own control lists and number of different quality requests. Aside from 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 different factors depending on the product type. For example, for frozen and dried fruit and vegetables and for edible nuts, mainly the allowed percentage of defective produce and fruit size are used to define quality categories. For homogenous products such as juices, purees or fruit spreads, there are many quality criteria including colour, flavour, chemical composition and brix level (sugar content in water solution).

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

Frozen fruit and vegetables quality: mostly defined by Codex Alimentarius standards. Currently, Codex standards apply for for 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 to determine the quality for frozen products. For example, the brix level in frozen fruits is important for the processing industry, while retailers value the uniform shape and colour of individually frozen products.

The 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 and size and more uniform shape.

Dried fruit and nuts quality: commonly defined by United Nations Economic Commission for Europe (UNECE) standards. UNECE standards apply for many nuts including almonds, brazil nuts, cashews, coconuts, hazelnuts, macadamias, pine nuts, pistachios and walnuts. UNECE standards for dried products include apricots, bananas, grapes, mangoes, melons, papayas, pears, pineapples, prunes and tomatoes. Codex Alimentarius also has standards for dried apricots, raisins, pistachios, dates, desiccated coconuts, peanuts and dried mushrooms.

Fruit and vegetable juice quality: 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 such as authorised ingredients, labelling rules and minimum brix levels 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.

Jams, jellies and marmalades quality: 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. There are many other product characteristics not included in the European legislation that do define quality, such as consistency (homogenised, with fruit pieces, with seeds or ‘seedless’), fruit brix level, colour, taste and type of sweetener used. There are also Codex Alimentarius standards for jams that define quality categories such as “extra jam” and “high fruit jam”.

Canned fruit and vegetables quality: usually defined by several Codex Alimentarius standards. At the moment, Codex has published standards for processed tomatoes, apple sauce, canned pineapples, canned raspberries, canned strawberries, fruit cocktails, tropical fruit salad, chestnuts and chestnut puree, mango chutney, canned bamboo shoots, canned stone fruits, pickled fruit and vegetables, certain canned vegetables, coconut milk and cream. With regards to quality, Codex 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 some type of food safety certification proof as the basis for cooperation.

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

Please note that this list is not exhaustive and food certification systems are constantly developing. The majority of food safety certification programmes are similar to 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. Also note that food safety certification is only a basis to start exporting to Europe. Serious buyers will usually visit/audit your production facilities within one or a few years.

In the fruit juice industry, the most recent development is SGF certification, which aims to achieve more safety, quality and fair competition in the fruit juice sector through industrial self-regulation. SGF certifies fruit processing companies, packers and bottlers, traders and brokers for fruit juices, as well as transport companies and cold stores in almost 60 countries worldwide.

For concentrated juices and purees producers, an important part of the SGF certification system is called IRMA (International Raw Material Assurance). In an ideal situation, the fruit juice industry has the whole supply chain under control, farmers should be GlobalGap certified, fruit processors should be IRMA certified, while juice bottlers should be certified by IQCS (International Quality Control System for juices and nectars). Apart from fruit processors, IRMA certification is also applicable for 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. So buyers in Europe frequently ask for laboratory tests. It is common practice in Europe that deliveries are accompanied with documentation from accredited laboratories that is not older than six months.

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

Tips:

  • Get food safety certification. However, check with the importers and experts if the food safety certification company you consult is appreciated by European Union buyers. Examples of independent internationally accredited certification companies include SGS, CIS, TÜV and Bureau Veritas.
  • Stick to the rules! New laboratory testing methods can easily discover non-permitted additions (such as sugars, water or other fruit) into your products. It takes a long time and a lot of money to build a good reputation in European markets, but this can be lost very quickly if you are caught tampering with your products or delivering sub-standard products. You can find several examples of food fraud in our mango puree study.
  • Consider becoming a member of SGF if you are supplying raw materials for the European juice industry.

Retail chains and other private sector requests

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

One of the recent trends is to ask for laboratory tests proving that specific pesticide residues are present in significantly lower quantities than legally required. Those requirements are still not harmonised even within the network 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 in other countries Lidl moved this limit to 30%.

The British retailer Tesco developed the specific certification scheme called “Tesco Nurture”. This certification scheme is used for producers of fresh fruit and vegetables but also for producers of edible nuts. Suppliers of this retail chain already needed GlobalG.A.P. certification and in addition, they now also need to be certified against the Tesco Nurture programme through an additional Nurture Module in the GlobalG.A.P. scheme.

Another initiative called “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 but as yet, they are not widely recognised by all market segments.

Some ingredient users, such as the baby food industry, will ask for organic certification or for controlled use of pesticides. Sometimes ingredient users will ask suppliers to follow strictly prescribed plant protection plans and only use pesticides from specifically developed lists.

Sustainability and corporate social responsibility (CSR) requests

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

In order to improve sustainable production and sourcing of nuts, a group of mainly European companies and organisations formed the Sustainable Nuts Initiative in 2015. The major objective of this initiative is to improve the circumstances in nut-producing countries and work towards sustainable supply chains. A similar initiative is a Sustainability Initiative Fruit and Vegetables (SIFAV). The aim of SIFAV is to reach 100% sustainable imports of fruits and vegetables from Africa, Asia and South America by 2020.

Also, leaders in the fruit juice industry formed The Sustainable Juice Covenant (SJC) with the global aim of making sourcing, production and trade of fruit and vegetable-derived juices, purees and their concentrates 100% sustainable 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 implemented a set of policies called the European Green Deal, with the aim of making the European economy more sustainable and climate neutral by 2050. Policies also include specific measures which may impact supply from developing countries. They also include a 50% reduction of 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. There are new certification schemes based on CO2 emissions including MyClimate or Carbon Footprint Certification. One certification scheme supporting several sustainability aspects is Planet Proof. Planet Proof includes several themes such as energy and climate, crop protection, biodiversity and landscape, soil fertility, clean water, packaging and waste.

Tips:

  • Do a self-assessment through the producer starter kit on the amfori BSCI website (pdf).
  • Ask your farmers to fill in the Farmer Self-Assessment by the Sustainable Agriculture Initiative to check how sustainable their production is.
  • Consider implementing management systems such as ISO 14001 (environmental aspects), OHSAS 18001 (occupational health and safety), ISO 26000 (a comprehensive system including all social responsibility aspects) or SA 8000 (labour and working conditions). Those systems are good ways to address sustainability and possibly gain a competitive advantage. Research with your buyer whether this is appreciated.
  • Read more about specific sustainability initiatives in our trends study and our product specific studies.

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 be grown using organic production methods according to the European legislation. Growing and processing facilities must be audited by an accredited certifier before you may put the European Union’s organic logo on your products, as well as the logo of the standard holder– Soil Association in the United Kingdom and Naturland in Germany, for example.

Be aware that the New EU regulation on organic production is expected to enter into force in 2022. The new rules will allow for mixed farming and combining conventional and organic production, provided that the two are sufficiently separated.

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

The procedure for the certification roughly follows these five steps:

  • Step 1 – Follow organic production rules - A common practice is to engage agronomists who are experts in organic production in order to implement the best practices and to get guidance that will prepare producers and exporters for the 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 interests.
  • 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 recognised control bodies which are approved by European Union regulation (EC) No 1235/2008. A 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 the reality and identifies any issues. After evaluation of the report a control body decides if a certificate can be issued or some non-conformities must be corrected first.
  • Step 4 – Certification - Once the control body confirms that the organic management plan is consistent with the 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. Together with a logo a certifier code number must be indicated. Be aware that an organic certificate is valid for one year from the date it was issued.
  • Step 5 – Submitting the certification of inspection - Every shipment of organic products must be accompanied by the certification of inspection from the selected certifier only electronically through the central platform called TRACES). European importers must also submit an application form for the import of organic products from developing country exporters. For this application form, the company information, the name of the certifier, and the date of the last inspection need to be provided. The importer also needs to submit a confirmation from a third party, stating that the certifier fulfils the requirements of ISO standard 65 / EN 45011.

Tips:

  • Consider investing in organic production and make a cost-benefit analysis. Organic production will often make your products more expensive, but you may be able to compensate this with higher sales prices. Demand for certified organic processed fruit and vegetables is increasing.
  • Try to combine organic certification with other sustainable initiatives to increase your competitiveness on the European market.
  • Check the guidelines for imports of organic products into the European Union (pdf) to familiarise yourself with the requirements for European traders.
  • Consult the Sustainability Map database for organic labels and standards.

Social and ethical requests

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

Responsible business and fair treatment of all people in the supply chain are always welcomed. However, a report on due diligence published by the European Commission in 2021 confirmed that 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. Because of that, the EU announced mandatory legislation on due diligence which should ensure respect for human rights and the environment throughout the whole 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. The rights of victims or stakeholders in third countries would also be better protected.

Tips:

  • Consult the ITC Sustainability Map for a full overview of certification schemes.
  • Check the Fair Trade Standards relevant for your production, processing and trade.
  • Respect human rights throughout the whole supply chain. Avoid making deals with companies that are not treating farmers and employees in a fair and sustainable way.

Ethnic certification

The Islamic dietary laws (Halal) and the Jewish dietary laws (Kosher) propose specific restrictions in diets. If you want to focus on Jewish or Islamic ethnic niche markets, you should consider the implementation of Halal or Kosher certification schemes.

Tip:

  • If you are focusing on the European Jewish or Islamic market, make yourself familiar with relevant certification procedures. You can find answers at many Halal or Kosher certification organisations.

This study has been carried out on behalf of CBI by Autentika Global.

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