What requirements must herbs and spices meet to be allowed on the European market?

You have to meet a number of requirements to enter the European market. Buyers likely have additional requirements, and they may ask for certificates. Requirements for herbs and spices in Europe are usually about consumer health and safety, but environmental and social sustainability are also becoming more important. If you want to prepare for new legislation and requirements, you need to monitor the market on a regular basis.

1. What are mandatory requirements for spices and herbs?

Most mandatory requirements for importing herbs and spices (and food in general) are related to food safety. The European Commission Department for Health and Food Safety is responsible for the European Union’s policy and for monitoring the implementation of related laws.

Official food controls

Food imported into the European Union (EU) is subject to official food controls. These controls include regular inspections that can be carried out at import (at the border) or later on, once the food is in the EU, such as at the importer’s premises. The control is meant to check whether the products meet the legal requirements.

An important element of this legislation is that “all food businesses outside Europe, after primary production, must put in place, implement and maintain a procedure based on HACCP principles”. This does not need to be guaranteed with certificates or official controls. However, it shows that an HACCP plan is a key element in the quality management systems of companies aiming to become successful suppliers to the European market. 

Non-compliance with European food legislation is reported via the Rapid Alert System for Food and Feed (RASFF). In 2024, 277 issues with spices and herbs were reported in the RASFF. This was slightly higher than the 275 issues reported in 2023. The most common issue was exceeding the Maximum Residue Limits (MRLs) for pesticides. The second most common issue was plant toxins, followed by salmonella as the predominant microbiological contamination.  

Source: GloballyCool (April 2025)

The main developments visible from Figure 1 can be explained as follows: 

• The rise in issues relating to pesticide residue is due mainly to problems with shipments of cumin from India and black pepper from Vietnam. Cumin from India has been subject to stricter conditions since 2023, with an increased testing frequency. This led to a high number of interceptions, which increased the frequency to 30% in January 2025.
• The rise in issues relating to plant toxins is due to issues with oregano from Türkiye  and cumin from Türkiye and India. These three product-origins are also subject to increased testing frequencies. 

Non-compliance leads to stricter conditions

If imports of a certain product from a specific country repeatedly show non-compliance with European food legislation, the frequency of official controls at the border will increase. These products are listed in Annex 1 of the regulations on the temporary increase of official controls and emergency measures. One example is spice mixes from Pakistan, which are frequently checked due to their increased risk of aflatoxins (aflatoxins come from mould and therefore are part of the mycotoxins group in Figure 1). 

Table 1 lists all the herbs and spices that are subject to temporary increases in official controls at entry to the European Union, including the relevant hazards and origins. The last column, ‘notes’ gives more information on specific measures, as they tend to change over time due to changes in risk perceptions. For example, the spice mixes from Pakistan experienced a decrease in the frequency of controls (from 50% to 30%), due to improved test results and an associated reduction in food-safety risks.

Table 1: Herbs and spices subject to temporary increases in official controls in the EU (frequency of identity and physical checks, in %), since 08/01/2025

Source: GloballyCool (April 2025), based on EUR-Lex

Another table in EU Regulation 2019/1793 lists products that have special import conditions because of contamination risks. Annex 2 gives special import conditions for food consignments that: 

• consist of products that come from multiple origin countries, or
• contain two or more ingredients from Table 2 (below), and the ingredients make up more than 20% of the total product. 

For these consignments, a frequency of identity and physical checks as a percentage is applied to make sure that contamination hazards remain under control. In other words, for the products in Annex 2 (Table 2 below), the import conditions are stricter than for the products of Annex 1. 

Table 2: Spices and herbs subject to special conditions for import to the EU (frequency of identity and physical checks, in %)

Source: GloballyCool (April 2025), based on EUR-Lex

Recent changes in frequencies include the following: 

• The testing frequency for nutmeg from Indonesia was previously 30%, but it increased to 50% in July 2024.
• The testing frequency for pepper (CN 0904) and spices in CN 0910 (ginger, saffron, turmeric) from Ethiopia was previously 50% for testing on Aflatoxins, but it decreased to 30% in July 2024.
• The pesticide-testing frequency for nutmeg, mace and cardamom from India was previously 20%, but it increased to 30% in July 2024.
• Cumin from Turkey was included in this regime from January 2025, with a testing frequency of 30% for Pyrrolizidine Alkaloids.

Control of pesticide residues

Regulation (EC) No 396/2005 sets maximum residue levels (MRLs) of pesticides in or on plant-origin food and feed. The MRL is the highest amount of pesticide residue legally permitted in or on food products when pesticides are used. Products exceeding these levels are taken off the European market. In 2024, 47% of all issues reported in the RASFF related to excessive pesticide levels or traces of illegal pesticides. 

In 2024, the most frequently reported pesticide issues were:

1. Chlorpyrifos                       40 issues (30%)
2. Pesticide cocktails          35 issues (27%)
3. Ethylene oxide (EtO)     16 issues (12%)
4. Others                                  40 issues (30%)

A cocktail is a mix of two or more pesticides, often including Chlorpyrifos and others, such as Anthraquinone, Carbendazim, Chlorfenapyr, Chlorothalonil, Clothianidin, Thiamethoxam, Tolfenpyrad, Triazophos or Cyromazine.

The EU regularly updates its list of approved pesticides (Annex 1). In 2022, the European Commission adopted proposals to reduce the use and risk of chemical pesticides by 50% by 2030 (SUR). However, this Sustainable Use of Pesticides Regulation (SUR) plan was withdrawn in February 2024, after being rejected by the European Parliament in November 2023. At the moment of writing (March 2025), the European Commission was still developing a more balanced approach and updated regulation. 

Synthetic pesticides not allowed in organic production

The use of synthetic pesticides is not allowed in organic production. Very low residue levels (often 0.01 parts per million) may be tolerated, but only if there is proof that the presence of the pesticide is due to cross-contamination, rather than to illegal pesticide use.

Control of contaminants

Food contaminants are substances that have not been intentionally added to food. They may be present in herbs and spices as a result of production, packaging, transport, holding or environmental contamination. Contaminants can pose a health risk to consumers. To minimise these risks, the EU has set maximum levels for certain contaminants in food and ingredients.

Bacterial contaminants

The EU regulation on microbiological criteria for foodstuffs lays down the microbiological criteria for certain micro-organisms and the rules that food business operators need to comply with. It does not set specific limits for herbs and spices.

The most common type of bacterial contaminant in spices and herbs is salmonella. Salmonella must be completely absent in spices and herbs. It is usually transmitted via contaminated irrigation water, manure, hands or animals if products are dried outside. In 2024, almost 10% of all 277 issues reported in the RASFF database related to salmonella.

Black pepper from Brazil is still the largest contributor to the subgroup of salmonella issues, but the number of salmonella issues caused by Brazilian black pepper has decreased drastically – from 45 in 2022 to 18 in 2023, and to only 2 in 2024. This was largely due to a lower export volume to Germany, which has always been the main country reporting these issues in RASFF.

Plant toxins

Since December 2020, following Commission Regulation (EU) 2020/2040, there have been maximum limits put in place for certain foodstuffs containing pyrrolizidine alkaloids (PA). In addition to the limit of 400 μg/kg for cumin seed and most dried herbs, there is a higher limit of 1,000 μg/kg in place for borage, lovage, marjoram, oregano and mixtures of these herbs. The number of reported issues grew from 25 in 2022 to 46 in 2023, and it increased further to 55 in 2024, primarily because of excessive PA levels in oregano and cumin from Türkiye.

Plant toxins can be transmitted to spices and herbs from weeds like:

• ragwort (Jacobaea vulgaris),
• Datura stramonium,
• black nightshade (Solanum nigrum) and
• potato berries.

Mycotoxins 

In 2024, approximately 8% of all issues reported in the RASFF database were due to mycotoxins. Mycotoxins are toxic compounds that are naturally produced by fungi, more commonly called moulds. The most common mycotoxins in herbs and spices are aflatoxins and Ochratoxin A. Aflatoxin contamination can take place in several spices including nutmeg, dried chillies, turmeric and ginger. The RASFF database shows that this kind of contamination is frequently found in nutmeg from Indonesia. 

To protect consumers, the EU has set aflatoxins and ochratoxin A limits for specific herbs and spices (see Commission Regulation (EC) 1881/2006).

Table 3: Aflatoxin limits for specific spices and herbs in the European Union

Source: EUR-Lex (25/05/2023)

Ochratoxin A was the subject of scientific research in the EU between 2018 and 2022. Studies have suggested that ochratoxin A may be genotoxic (causing genetic mutations) and carcinogenic (causing cancer). So far, these studies have not resulted in sharp reductions in the EU’s limits. 

Polycyclic aromatic hydrocarbons (PAH)

Smoke contains polycyclic aromatic hydrocarbons (PAH), most notably benzo(a)pyrene. PAH can increase the risk of cancer. Because of this, the EU has set PAH limits for spices and herbs (except cardamon and smoked Capsicum spp): 10μg/kg for benzo(a)pyrene and 50μg/kg for the sum of all PAHs.

High PAH levels can be the result of high heat, using fossil fuels and/or a long smoking process. Although excessive levels of PAHs in spices and herbs are uncommon, heating and smoking do pose a risk. Crushed spices absorb more smoke than whole spices. The number of issues reported in the RASFF was relatively stable, with 5-6 cases about high PAH levels each year between 2022 and 2024. These cases involved a wide range of spices and herbs, including ginger, paprika, black pepper, turmeric, bay leaves, chillies, garlic and cinnamon.

Metal contaminants

Metals like lead naturally occur in the environment, such as in soil and in water. Pollution from human activity adds to metals being present in the environment too. As a result, metal residues can occur in food. Contamination can happen during food processing and storage.

The EU has had lead residue limits for spices since 2021:

• 0.60 mg/kg for fruit spices
• 1.5 mg/kg for root and rhizome spices
• 2.0 mg/kg for bark spices
• 1.0 mg/kg for bud spices and flower pistil spices
• 0.9 mg/kg for seed spices

The number of issues was relatively stable, with 3-5 cases reported each year. Excessive lead was found several times in Vietnamese cinnamon, and lead was also found in batches of turmeric, cinnamon, cardamom, chillies and cloves from Vietnam, Indonesia, Madagascar and Uganda.

Labelling and packaging

The labelling of herbs and spices requires careful attention. The 2024 RASFF overview contains 7 labelling issues (down from 11 in 2023), most of which related to allergens. In a few cases, the allergen declaration was missing, but most concerned an undeclared allergen (celery, mustard, sesame).

Food imported into the EU must meet the legislation on food labelling. Bulk packaging labels must contain: 

• Name and variety of product
• Batch code
• Net weight in metric system
• Shelf life of the product or best before date, and recommended storage conditions.
• Lot identification number
• Country of origin
• Name and address of the manufacturer, packer, distributor or importer

The lot identification and the name and address of the manufacturer, packer, distributor or importer may be replaced by an identification mark. Labels can also include details such as brand, drying method and harvest date. These batch details can also be included in the Product Data Sheet.

If the imported product is going directly to retail, the product labelling must meet EU regulations regarding the provision of food information to consumers. These regulations include clear requirements for nutrition values, origin, allergen labelling and the minimum font size for mandatory information. For herbs and spices, the label must declare allergens, such as celery and mustard. Spice mixes might also contain allergens, including gluten, wheat and nuts. Additionally, sulphur dioxide – sometimes used as a preservative – must be declared as an allergen.

Control of unauthorised agents

The EU has strict regulations on what substances are allowed in foods. This is to ensure safe food for consumers. Regulation 1333/2008 establishes the overall framework for the use of food additives in the EU. This regulation contains a list of approved food additives and their permitted uses, as well as labelling rules. Regulation 231/2012 provides additional, detailed purity criteria for food additives. It lists the specific chemical composition, purity standards and production methods that approved additives must meet.

For spices and spice mixes, the restrictions for colouring agents are especially relevant. Of the 277 issues reported in the RASFF for 2024, 7 concerned the unauthorised use of colouring agents. This was about the same as in 2023, but it was significantly less than the total of 16 in 2022. Examples of colouring agents found in spice mixes include Sudan I, II and IV, as well as Rhodamine B. 

Fighting adulteration 

Another issue is the adulteration of herbs and spices. The more valuable the product, the more likely adulteration is. Examples are vanilla extract made from tonka beans, oregano mixed with strawberry leaves and saffron mixed with cheap components. 

Several organisations and projects have launched initiatives to fight food fraud. The ESA has published an Adulteration Awareness Document (available to ESA members), and the UK Spice and Seasoning Association offers guidance on the authenticity of herbs and spices.

Phytosanitary inspection

The EU inspects food products to protect citizens, animals and plants from diseases and pests. Common tools are food inspections and phytosanitary certificates. Special phytosanitary certificates are issued for plants or plant products that can be reproduced within Europe after import, such as for food containing seeds. Traders of herbs and spices require phytosanitary certificates only for seeds used for sowing and for fresh herbs and spices, such as fresh garlic, ginger and herbs. For more details on exporting fresh herbs to Europe, read the CBI’s study about exporting fresh herbs to Europe. 

2. What additional requirements and certifications do buyers ask for in spices and herbs?

European buyers often have additional requirements, beyond legal obligations. Many of these requirements concern the European Spice Association (ESA) quality minima for specific products. Others relate to food safety, and sustainable and ethical business practices. 

Product quality requirements

Product quality is a key issue for European buyers. Several factors determine the quality of spices and herbs, including subjective aspects, like flavour and colour. Buyers often ask suppliers to comply with the ESA quality minima (available to ESA members only). 

While the applied quality criteria vary by product, several are used for all herbs and spices:

Cleanliness or purity

Herbs and spices must be free from diseases, foreign matter, foreign odours and other issues. The ESA sets the maximum presence of external matter at 10 g/kg, and foreign objects should be smaller than 2mm in diameter. Some buyers use more specific indicators from the American Spice Trade Association (ASTA) Cleanliness Specifications. These can include the maximum presence of dead insects, excreta, moulds and other foreign matter. Other indicators in this category include ash level and acidity.

Moisture content

The ESA also sets the minimum moisture content for different spices and herbs. Some buyers may ask for a different moisture content.

Mesh or particle size of ground spices

To measure particle size, spices and herbs are ground to pass through a sieve of a specific diameter, expressed in microns. 95–99.5% of the powder should pass through the specified sieve size.

Odour and flavour

Herbs and spices must have a characteristic odour and flavour. This mainly depends on the chemical components of the essential oil. The variety and cultivar also have an effect, as do the geographic, climatic and growth conditions.

Essential oil

The quality of spices and herbs is typically better when the ash percentage is low and the essential oil content is high. ESA sets a minimum essential oil content for most spices and herbs.

For several spices and herbs, internationally recognised standards set specific criteria for quality and specification:

• Codex Alimentarius runs a committee on spices and culinary herbs (CCSCH) with standards developed for 14 different types of spices and herbs. Most of these standards were published in 2022, and a few were added in 2024: for small cardamom, for allspice, juniper berry and star anise, and for curcuma.
• The International Standards Organisation (ISO) has product specifications for various spices, culinary herbs and condiments. The most recent specifications developed were for fennel (2023) and for sumac (2022). 

Irradiation

Irradiation is not often used for spices and herbs. Although the EU allows sterilisation by irradiation under the condition of labelling, European consumers do not appreciate irradiated food. Because of this, European buyers often require radioactivity contamination tests for imported spices and herbs.

Third-party laboratory tests

The microbiological, chemical and physical conditions of the product are so important to buyers, that they increasingly ask for laboratory test reports. Buyers from Northwest Europe may request testing for more than 500 different pesticide residues. Deliveries are commonly accompanied by documentation from accredited laboratories. These documents should not be older than six months. 

The laboratories must be accredited, which can be an issue for suppliers in some developing counties. In some countries, laboratories can only perform a limited number of tests, so they need to send samples to other countries for analysis. The Indonesian company Nusa Harvest found the local laboratory SUCOFINDO to do the analysis of a batch of vanilla beans and posted the first page of the analysis report on Instagram. 

Figure 2: Instagram post from Nusa Harvest showing lab-analysis results

Source: Nusa @ Instagram

Food safety certification

Food safety is crucial for the European market. Although legislation addresses many potential risks, it is not enough on its own. The 277 issues reported in the RASFF database in 2024 show that problems can still occur. As a result, importers prefer to work with producers and exporters who have food-safety systems with certificates recognised by the Global Food Safety Initiative (GFSI).

For processors and traders of spices and herbs operating internationally, the most widely accepted certification programme is the Food Safety System Certification (FSSC 22000). This is a third-party certification programme based on the ISO methodology. 

Sooner or later, exporters to Europe are likely to come across buyers who require certification from the International Featured Standards (IFS) or British Retail Consortium Global Standards (BRCGS). These certification programmes are particularly relevant if you target certain European food-retail markets.

Having programmes with third-party certification is an asset to your company, and it helps attract new buyers. However, serious buyers may also want to visit and audit the production facilities of potential suppliers.

Sustainability compliance

Although less important than product and food safety requirements, social and environmental compliance is increasingly demanded by European buyers. This often means that suppliers have to undersign the buyer’s code of conduct. Buyers may also ask for certification from a third-party scheme like Rainforest Alliance.

Codes of conduct

Codes of conduct (CoC) vary from company to company, but they are often similar in structure and the issues they cover. In 2022, the ESA published guidelines for their members. Since a lot of European herb and spice companies are members of the ESA, you will likely come across these guidelines sooner or later. Under this sustainability code of conduct, ESA members monitor their own operations and those of their suppliers on a range of social and environmental criteria. 

Third-party certification: Rainforest Alliance and B Corp

Several third-party certification schemes set criteria for both social and environmental issues. The most important ones are Rainforest Alliance, Fairtrade and B Corp. For companies with FSSC22000 certification, it might also be worthwhile to consider the social-sustainability certification FSSC24000. 

The Rainforest Alliance is quite a common certification scheme applied in mainstream agricultural value chains. Since 2022, the Rainforest Alliance and the Union for Ethical BioTrade (UEBT) have had a joint Herbs & Spices Programme in place. There are two types of certifications in this programme: 

• Farm certification, with the UEBT/Rainforest Alliance requirements compiled in a Field Checklist and two system checklists: one for organisations in sourcing areas and another for organisations elsewhere.
• Supply chain certification, in which companies that buy from certified farms have to meet the Rainforest Alliance 2020 Sustainable Agriculture Standard’s Supply Chain Requirements.

Probably the fastest growing sustainability certification scheme is B Corp. Fairtrade certification – which we discussed in the chapter on requirements for niche markets – ensures that individual products meet high social and environmental standards. In contrast, B Corp certifies entire companies in a comprehensive and demanding way. B Corp certification requires companies meet high standards of performance, accountability and transparency on a wide range of factors.

These factors include:

• employee benefits,
• charitable giving,
• supply chain practices, and
• input materials.

Companies can acquire the B Corp certificate by:

1. Demonstrating they have high social and environmental performance. The company must achieve what is known as a ‘B Impact Assessment score’ of 80 or above and pass a risk review.
2. Making a legal commitment by changing the corporate governance structure to be accountable to all stakeholders and not just shareholders.
3. Being transparent by allowing information about the company’s performance on the standards to be publicly available on their B Corp profile on B Lab’s website.

Transparency initiatives

The Supplier Ethical Data Exchange (Sedex) is a well-known global initiative that aims to make global supply chains more transparent. Sedex is a global, collaborative forum for buyers, suppliers and auditors to store and share information. Sedex offers participating companies tools (like the SMETA audit template) for managing sustainability performance. Unlike certification programmes that specify third-party audits and certification by definition, the Sedex tools can manage sustainability performance through first-party or second-party audits. 

The aim of sharing all this information is to manage performance on sustainability. This covers labour rights, health and safety, the environment and business ethics. As such, Sedex is not a certifiable scheme nor a standard-setting body. By participating in this platform, companies show their willingness to share data and use information to manage and improve ethical standards in the supply chain.

The Sedex organisation has also developed social auditing standards: the ‘SMETA’ (Sedex Members Ethical Trade Audit). This auditing template helps companies to assess suppliers’ working conditions in the social, ethical, and environmental domains.

Overview of certifications and CoC

Table 3 provides the most important certifications and codes of conduct for the herbs and spices sector, along with information about the costs and the process. Note that some important costs components of certification are ‘hidden.’ This means that these are hard to quantify, but you will likely find them in the offer of potential service providers. The most important hidden costs are: 

• Travel costs for the auditors – time and expenses.
• Accommodation costs for the auditors.
• Non-Conformity/Corrective Action Review. 

In addition, it should be clear that any preparation for certification may require you to invest in your facilities or quality assurance and control system. 

Last but not least, if a company is applying for certification against different schemes with the same certification body, the certification body will likely be able to offer a discount on the total certification costs. 

Table 4: Most important certifications and CoC requested by buyers in the herbs and spices sector

Source: GloballyCool (March 2025)

3. What are the requirements and certifications for spices and herbs niche markets?

Most additional buyer requirements apply to mainstream herb and spice markets. However, some niche markets have their own, specific requirements. While Fairtrade lays down requirements for sustainability in the social, environmental and ethical domains, product certification for the organic market mainly focuses on environmental requirements.

Sustainability certification

Although it is less important than product and food safety requirements, European buyers are increasingly demanding sustainability. The most obvious market in Europe for sustainably sourced products is the fairtrade market. 

Fairtrade

The fairtrade market is built on fairtrade certification. Every player in the supply chain needs to be certified to participate in this market. The fairtrade market is privately regulated.

In the global fairtrade market, there are several fairtrade certification organisations. Fairtrade International is the largest one. It gives you access to the European market and most other international markets, except the United States of America. An example of a smaller, more regional certification organisation is Fairtrade Original from the Netherlands.

Fairtrade International has specific standards for herbs, herbal teas and spices from small-scale producer organisations. This defines minimum prices and price premiums for conventional and organic products from several countries and regions. For herbs and spices without a fixed Fairtrade Minimum Price or fixed Fairtrade Premium, the Fairtrade Premium is set at 15% of the commercial price.

Organic certification

If you want to sell your herbs and spices as organic in Europe, they must be grown using organic production methods that comply with EU organic legislation (Regulation (EU) 2021/2306 supplementing Regulation (EU) 2018/848). Growing and processing facilities must be audited by an accredited certifier. Regulation (EU) 1235/2008 lists requirements for organic products to be imported to the EU from third countries. 

The certification procedure roughly follows these five steps:

1. Develop an organic farm management plan and implement organic production practices step-by-step. Familiarise yourself with the requirements for organic production and if possible, use local consultancy services.
2. Apply for certification when you meet the requirements. Select and negotiate a certification fee with an EU-recognised control body listed in Annex III of Regulation (EU) 1235/2008.
3. Arrange for inspection. An inspector verifies whether your organic farm management plan is true to reality. If they find critical non-conformities, you must correct these.
4. Become certified. If you have completed Step 3 successfully, a certificate will be issued, valid for one year. You can then put the EU organic logo on your products. You have to print the certifier code number together with the logo.
5. Manage batch documentation. Each batch of organic products imported into the EU must be accompanied by an electronic certificate of inspection (e‑COI), as defined in Annex V of Regulation (EC) No 1235/2008. This electronic certificate of inspection has to be generated via the Trade Control and Expert System (TRACES).

Dual certification

Dual certification is a clear asset in both the European fairtrade and organic markets. Consumers in these markets are typically more conscious than mainstream consumers. Because of that, they are more likely to appreciate and buy products that have both a fairtrade and an organic certification logo. 

Examples of spices and herbs producers that have obtained both organic and fairtrade certification are:

• Ceylbee International from Sri Lanka. Their spice products include pepper and cinnamon. In addition to the Fairtrade certificate, the company has organic certification for the EU, USA, Japan and Malaysia.
• Shochoch Trading from Ethiopia produces and exports coffee, honey and spices. Their range of spices consists of turmeric and ginger (both fresh and dry), bird’s eye chilli, black cardamom, black pepper, and long pepper and herbs. Their ginger and turmeric bear the fairtrade logo.
• Pure Life from Egypt is a producer and exporter that holds a fairtrade certificate for a wide range of dried herbs of Egyptian origin. They trade both organic-certified herbs (but not for the European market) and non-organic herbs. 

Figure 3: Promotional video of the Indonesian dual-certified spice producer Mega Inovasi Organik

Source: Mega Inovasi Organik @ YouTube

Globally Cool carried out this study on behalf of CBI.

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