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What requirements should spices or herbs comply with to be allowed on the European market?

Takes about 19 minutes to read

The primary focus in legal requirements for spices and herbs on the European market is on food safety and quality, and especially on avoiding contamination. For market requirements, corporate social responsibility (CSR) and sustainability have become important as well, following the wider European trend towards ethical and responsible consumption.


1 . With which legal requirements must your product comply?

Food safety – hygiene, traceability and control

When exporting spices and herbs to the Europe, you need to comply with various legal requirements. The General Food Law is the legislative framework regulation for food safety in the European Union. The requirements mainly deal with food safety, as compliance to this legislation ensures that the spice or herb is safe to eat.

To guarantee food safety and to allow appropriate action in cases of unsafe food, your spices and herbs must increasingly be traceable throughout the entire supply chain. This means being increasingly aware of where your products come from and keeping records on this, and being able to provide any necessary information to potential buyers on the origin of your products.

An important tool to control food safety hazards throughout the whole supply chain is the implementation of food safety management based on Hazard Analysis Critical Control Points (HACCP) principles. HACCP planning consists of consecutive steps to:

  • identify food safety hazards
  • determine how you can control them (the CCPs, i.e. critical control points)
  • implement corrective measures when you cannot guarantee the safety of the foods produced.

Also important is subjecting food products to official controls. If European companies or authorities find out that the safety of your product cannot be guaranteed, they will take the product off the market. Your product will then be registered in the European Union’s Rapid Alert System for Food and Feed. In most cases, European importers will not pay for the product or demand their money back. Additionally, a food safety issue will damage your reputation on the market.

Due to repeated non-compliance, spices and herbs from certain countries (especially Indonesia and India) have been subject to additional and stricter customs controls in the European Union over the past years. Measures imposed by the European Union include requiring a health certificate and an analytical test report.

At the moment, spices and herbs are not subject to additional controls. However, due to continuing problems with excessive levels of aflatoxins and pesticides, as well as salmonella contamination, it is likely that controls will become stricter in the future.

Tips:

  • Have a look at the Quality Minima Document of the European Spice Association (ESA). This is the leading document for the most important European buyers, providing an overview of legal requirements as well as non-legal requirements (e.g. quality, food safety and labelling).
  • European buyers will often ask you to implement a food-safety management system based on hazard analysis and critical control points (HACCP) principles. You can read more about HACCP and health control on the European Commission Trade Helpdesk website. Select your specific product code under product code 09.
  • Check regularly whether there are any increased levels of controls for your product or country. The list of spices and herbs and their supplying countries is updated regularly. Check the website of EUR-Lex for the most recent list (see latest document under Amended by).
  • Search in the European Union Rapid Alert System for Food and Feed (RASFF) database to see examples of spices and herbs withdrawn from the market and the reasons behind these withdrawals.
     

Avoid contamination

Contaminants are substances that may be present in spices and herbs as a result of the various production stages: growing, processing, packaging, transport and storage. Common forms of contamination are pesticides, mycotoxins, salmonella, polycyclic aromatic hydrocarbons and food additives.

  • Pesticides: The European Union has set maximum residue levels (MRLs) for pesticides in and on food products. A problem for European buyers is that a large share of spice and herb crops worldwide do not comply with European Union limits. As a result, this issue is very important for them and a controlled use of pesticides by farmers is crucial. This also means that farmers at all times should stay in close contact with their European buyer on which pesticides and what amounts to use to comply with European limits.

Please note that buyers in several European countries use MRLs which are even stricter than the MRLs laid down in European legislation. Many supermarket chains have their own requirements for pesticides as well, stricter than legislation. If your buyers do business with these supermarkets, they will apply these requirements to your products as well.

  • Mycotoxins: For piper nigrum, capsicums, nutmeg, mace, turmeric, ginger and mixtures containing one or more of the spices mentioned, the maximum level of aflatoxin is between 5.0 μg/kg for aflatoxin B1 and 10 μg/kg for the total aflatoxin content (aflatoxins B1, B2, G1 and G2). For the same products, the maximum level of ochratoxin A (OTA) is set at 15 μg/kg.

For capsicum, a limit of 20 μg/kg was determined in 2015. Unfavourable weather conditions during growth and harvest make it hard to control the level of ochratoxin A.

  • Salmonella: There are no specific requirements laid down in European Union legislation for salmonella contamination of spices and herbs as there are for other products. However, according to Article 11 of the General Food Law, food products introduced to the European Union market must be safe. To this end, food business operators are also testing spices and herbs for salmonella.

Food safety authorities can withdraw spices and herbs from the market or prevent them from entering the European Union when salmonella is found.

  • PAHs: Polycyclic aromatic hydrocarbons (PAHs) are chemicals that are formed by the incomplete burning of such things as coal, oil and gas, garbage and other fossil fuels. Artificial drying with fire can, for example, contaminate spices and herbs with PAHs when smoke is mixed with the product.

Traditional smoking and processing methods applied to smoked paprika and cardamom result in high levels of PAHs. However, these products are exempt from the maximum levels. Consumption of these spices is low, so this kind of contamination will not affect the health of consumers.

  • Food additives: Some herbs and spices may contain colourings, flavourings or sweeteners. There is specific legislation for additives and flavourings that list which E numbers and substances are allowed. Many of the spices and herbs rejected by customs authorities or buyers have undeclared, unauthorised or excessive limits of extraneous materials.

The European Spice Association’s (ESA) Quality Minima Document sets a maximum level of extraneous matter at 1% for spices and 2% for herbs. Spices and herbs (especially those ground and crushed) can be intentionally adulterated with cheaper varieties, salt, sand, synthetic varieties and products with a similar appearance, hence the limit on extraneous matter. Unintentional adulteration (e.g. spillovers from fertilisers and insects) also happens.

Food adulteration is an important issue for European buyers and the European Union and national governments are becoming stricter in enforcing food fraud monitoring.

To control contamination caused by micro-organisms, viruses, bacteria or insects, using irradiation on dried spices and herbs is permitted. EU legislation requires that the irradiated product is declared at all levels within the food chain and irradiation is only permitted in irradiation plants approved by the EU.

Tips:

  • Read more about MRLs, mycotoxins, contaminants on the European Commission Trade Helpdesk. You can consult the Trade Helpdesk for a full list of requirements. Select your specific product code under Chapter 09.
  • Do not interpret residues or detection limits yourself (e.g. margins of error in testing). Discuss at length with your buyers what levels are acceptable for them.
  • To reduce pesticide levels, promote integrated pest management (IPM) among the farmers with whom you work. This agricultural pest control strategy uses complementary strategies such as good growing practices and chemical management. For more information on Integrated Pest Management, see the FAO website.
  • Better understand growing, drying, processing and storage practices to prevent contamination, and discuss them with your suppliers. Valuable sources are the guidelines on the Code of Hygienic Practice for Spices and Dried Aromatic Plants (Codex Alimentarius) and Good Agricultural Practices (GAP) Spices (IOSTA).
  • For information on safe storage and transport of spices and herbs, go to the website of the Transport Information Service.
  • Many buyers in Europe expect a test report on the microbiological contamination of your products. Providing this service makes it easier to find buyers in Europe.
  • In the European Union, steam sterilisation is the preferred method to combat salmonella as well as other types of microbiological contamination. Providing this service yourself can be costly, but you may be able to receive a premium. Working together locally with reliable service providers is also an option.
  • If you use additives, make sure that they are legal and agreed with your buyers. Also make sure to mention them in the list of ingredients.
  • It is impossible for buyers to test spices and herbs for every possible extraneous material. As a result, they will tend to refrain from buying processed spices and herbs from outside the European Union or will buy only from suppliers that they trust. The burden of proof is with suppliers. You will have to build a track record, and provide transparency and references if you are to succeed on this market.

General requirements on packaging and labelling

Clear labelling of your spices and herbs is important for both bulk and pre-packed consumer products. Product labels should inform about composition, manufacturer, storage methods and preparation of the spice or herb. European labelling legislation applies to pre-packed consumer products and bulk products alike, but in a slightly different way. For consumer products, all information should be mentioned on the label while for bulk products it is allowed that some of the mandatory information is given in the commercial documents and does not need to be printed on the bag or label.

The allergen legislation demands that pre-packed food products should state clearly whether they contain allergens. Spices and herbs or mixtures thereof can contain extraneous material (e.g. gluten, mustard or sesame seeds, milk, nuts – see Annex IIIa) that can cause allergic reactions and therefore have to labelled as containing allergens.

Note that there is also non-product-specific legislation on packaging and labelling in the European Union Directive 2009/32/EC that apply to all goods marketed in the European Union.

Tips:

  • Always inform your buyer when your products contain allergens, even when you are not taking care of final packing. For bulk goods, the list of ingredients should be given in the commercial documents. 
  • For a full overview of requirements for spices and herbs, consult the European Union’s Trade Helpdesk. You can select your specific product codes under Chapter 9.
  • Pay attention to potential cross-contamination within your company or in the supply chain. Cross-contamination might happen when different products are intentionally or unintentionally mixed during harvesting, processing or transport. Watch out especially for contamination with cereals containing gluten, peanuts (groundnuts), nuts, celery, mustard, sesame seeds and products containing these allergens.

2 . Which non-legal (additional) requirements do buyers often have?

In addition to legal requirements, you should also consider compliance with the following market requirements that can be selection criteria for European buyers.

Food safety certification

As food safety is a top priority in all European Union food sectors, many players request extra guarantees in the form of certification. Requirements by the retail sector and consumers regarding food safety and traceability are becoming stricter.

European spices and herbs companies are subject to stringent checks, as standards are becoming more detailed and demanding and compliance needs to be demonstrated by certification. These companies, in turn, pass part of this task on to their suppliers in origin countries, for example through elaborate supplier questionnaires and their own standard.

Many buyers in the European Union (for example, traders, food processors and retailers) require the implementation of an HACCP-based food safety management system.

The most important food safety management systems in the European Union are:

  • BRC (British Retail Consortium)
  • IFS (International Food Standard)
  • FSSC 22000 (Food Safety System Certification)
  • SQF (Safe Quality Food Standard).

These management systems are recognised by the Global Food Safety Initiative (GFSI), which means that any of them should be accepted by multiple retailers. However, in practice, some buyers still have preferences for a specific management system.

Tips:

  • As European market entry requires a certified food safety management system, it is important to familiarise yourself with them.
  • Before you consider certification according to one of these standards, check which one your potential buyer prefers. Different buyers may have different preferences for a certain management system. For example, British retailers often require BRC, while IFS is more commonly required in the rest of Europe.
  • Choose a management system that is approved by the Global Food Safety Initiative.
  • Have a look at the Standards Map for more information on the different Food Safety Management Systems.

Corporate social responsibility (CSR)

 European buyers are increasingly paying attention to their corporate responsibilities regarding the social and environmental impact of their business and this is expected to continue to grow in the future. European buyers may expect you to comply with their supplier codes of conduct regarding social responsibility, which are often based on the International Labour Organization’s standards. This can be the importer’s own code of conduct or a code of conduct as a part of an initiative in which the importer is participating. 

Common requirements include signing a suppliers’ code of conduct in which you declare that you do your business in a responsible way. This procedure means that you (and your suppliers) respect local environmental and labour laws, stay away from corruption, and so on.

Important issues in the supply chain for spices and herb are the correct use of pesticides, child labour, healthy and safe working conditions and fair payment.

Many European buyers already include the most important issues in their supplier audits. They follow common standards such as:

It is important to realise that European companies have different definitions, priorities and ambition levels with respect to corporate social responsibility. There is no single way to address these matters. The action to be taken may entail signing a code of conduct to ensure compliance with the most important issues, or establishing and addressing all the relevant concerns in your entire supply chain.

Tips:

  • Exporters interested in supplying to the European market should at least address the most important issues of corporate social responsibility. Many buyers are already using this aspect as a selection criterion for new suppliers.
  • List relevant issues through the use of existing standards. For example, ISO26000 for social responsibility and ISO14001 for environmental management, and ask your potential buyers what they consider the most important issues. Ask whether they are willing to provide their supplier audit form. This form will provide information on their most important issues.
  • You can self-assess in order to determine to what extent you or the farmers you work with comply with different sustainability standards. See the International Trade Centre’s Sustainable Spice Initiative Equivalency Tool for more information.
  • Read our fact sheet about sustainable spices and herbs on the European market for more information about the market, as well as the different trends and developments for sustainable spices and herbs.

3 . What are the requirements for niche markets?

Besides requirements you have to comply with to be allowed on the European market or to find a buyer, complying with the following requirements could offer you a competitive advantage and make finding a buyer easier.

Sustainable Certification

As a next step to demonstrate compliance with corporate social responsibility criteria, certification is the most common way. Sustainable certification in the spices and herbs sector is still a niche market. However, European demand for sustainable food products continues to increase and is expected to grow in the future. There is a growing market for certified products with well-known consumer logos. A price premium needs to be paid for spices and herbs with a certificate to compensate for certification costs. These premiums are paid on some niche markets, but in large parts of the mainstream market buyers are unwilling to spend more.

The interest in sustainability is stimulated by existing initiatives, such as the Sustainable Spices Initiative (SSI), but also by relatively new product-focused initiatives such as the Sustainable Vanilla Initiative (SVI). This initiative was established by a group of leading companies in the vanilla industry and represents over 70% of global vanilla bean purchases and has initially focused on collaboration with Madagascar. According to Innova Market Insights, the number one driver in confectionery and snacks is “mindful choices”, supporting the trend towards more sustainability. Consumers are more than ever conscious about making responsible food choices, in terms of a healthy lifestyle as well as ethically responsibly produced food products.

Each certification addresses different issues (social, environmental, economic) and serves different niches. Social and environmental issues are increasingly being integrated in the various certifications. For an explanation and comparison of sustainability standards you can look at the International Trade Sustainable Spice Initiative Equivalency Tool.

Understanding the different certification standards is an important step towards accessing the EU market. Most common certifications are listed below:

  • Rainforest Alliance and UTZ: Rainforest Alliance and UTZ are mainstream sustainability schemes in which social and environmental issues are addressed. In January 2018, the two organisations merged, forming one of the biggest sustainability organisations in the world.

Although interest in Rainforest Alliance from buyers is reportedly growing, the volume of spices and herbs that are Rainforest Alliance certified is still relatively low. One reason is that food processors (accounting for 80% of European sales) cannot certify composite processed food products according to a Rainforest Alliance standard.

In contrast, composite food products with organic and fair-trade certification are sold on the European market. Rainforest certified spices and herbs are therefore hidden ingredients with no added marketing value for food processors. Therefore, buyers are less willing to pay price premiums for Rainforest Alliance certified products.

  • Organic: Organic spices and herbs are produced and processed using natural techniques. To market spices and herbs in the European Union as organic, they must be grown using organic production methods which are laid down in the New Organic Legislation. Some buyers are prepared to pay more for organic spices and herbs because they believe the cultivation of such products is better for the environment, and/or that these products are healthier than conventional products.

Although relatively small, the market for organic products in Europe is still growing and will continue to grow in the future. With this future growth, a stricter organic regulation and testing is also expected. Demeter is a biodynamic certification label and regarded as the highest grade of organic farming in the world. Certification is difficult to acquire and must be renewed annually. Currently, 480 producers of spices and herbs are Demeter certified.

  • Fair-trade certification: Spices and herbs traded according to fair-trade principles ensure a certain price and premium for smallholders. This should help them make a living. Examples of standards are Fairtrade and FairWild (for spices and herbs collected in the wild).

Although growing, the market for fair-trade certified spices and herbs is still small. The largest share is sold as spices and herbs in the retail channel. The largest user of spices and herbs – the food processing industry – is currently not a big buyer of certified spices and herbs. There is increased cross-over between organic and fair trade.

A large share of the fair-trade products are also certified organic. Fair trade has different standards depending on the place in the supply chain. For traders and processors the Smallholder Producer Standard for Spices and Herbs and Trade Standard are used. The Standard for Herbs and Herbal Teas for Hired Labour is specifically for herbs destined for herbal teas grown by producers with numerous workers (i.e. hired labour).

Tips:

  • Have a look at the International Trade Centre’s Standards Map database to learn more about the different organic standards. On the website of the International Federation of Organic Agriculture (IFOAM) you can find different organic labels that fall under this umbrella organisation.
  • Several organic certifiers have developed their own fair trade standards. Examples are the ‘organic and fair’ schemes of the Institute for Marketecology (IMO), Ecocert and Control Union. In these schemes, the role of producers in developing countries in the supply chain can be larger than in the Fairtrade scheme where they are merely seen as service providers. The producer can lead the process, work together with the grower and become the certificate holder.
  • Consult the International Trade Centre’s Standards Map for more information on the Fairtrade and FairWild label.
  • Find the local guidelines of Rainforest Alliance for various spices and herbs on the website of the Sustainable Spice Initiative. Traders and processors will have to comply with the Chain of Custody standard.
  • Have a look at the website of Rainforest Alliance to see who the main retailers and companies are that use this sustainability certification.
  • Most certification schemes have tools and other types of assistance to help you understand the criteria and educate you on how to become certified. For example, UTZ has a tool for steps to establish an internal control system.
  • For more information on sustainability, see our study sustainable spices and herbs.

Gluten-free labelling

Buyers are more and more confronted with elaborate testing on allergens when importing spices and herbs to the Europe. There is a growing European demand for gluten-free products and therefore also for related labelling. Although spices and herbs do not contain gluten naturally, contamination can still take place, for example due to seasonings that contain gluten. When eliminating gluten in spices and herbs, using the corresponding gluten free label is interesting when aiming for this market segment.

Tip:

  • Check the European Commission Regulation (EU) no. 828/2014 for harmonised requirements for the provision of information to consumers on the absence or reduced presence of gluten in food.

Allergen-free spices and herbs

Allergen-free spices and herbs are an increasingly important topic within the European spices and herbs market. Buyers are more and more confronted with elaborate testing on allergens, especially since cross-contamination is an issue in the sector. There is no clear EU regulation on this, each country has its own interpretation and sets different maximum levels. Particularly in countries where the requirements are strict (for example the Netherlands), it is expected that buyers will pass on (part of) the responsibility to their suppliers or at least work together with their suppliers to make sure that issues such as cross contamination are limited to a minimum. 

Allergen-free spices and herbs can be an interesting niche market. There are already several suppliers, such as Dutch Spices and EHL Ingredients, that are active on this market.

Tips:

  • Refer to the allergen legislation, which demands that pre-packed food products should state clearly whether they contain allergens.
  • Always inform your buyer when your products contain allergens, even when you are not taking care of final packing. For bulk goods, the list of ingredients should be on the label or in the commercial documents. For a full overview of requirements for spices and herbs, consult the European Union’s Trade Helpdesk. You can find your specific product codes in Section II (Vegetable products) under 09 (Coffee, tea, maté and spices).

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