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

All foods sold in Europe must be safe for consumption. Additives must be approved, harmful contaminants are banned and information on food packaging is tightly regulated. Mandatory requirements have become equally important to private requests from importers. Those include compliance with food safety, quality and sustainability standards. Exporters need to monitor the market closely, as requirements change frequently. In 2020, for example, regulations were changed for nearly 60 different pesticide residues.

1. What are the mandatory requirements?

Apart from the customs procedures, almost all mandatory requirements related to the import of spices and herbs (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 established 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, including exporters from developing countries. To achieve this, all food business operators need to implement the Hazard Analysis of Critical Control Points (HACCP) (pdf) 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 the supplying country. For most of the processed fruit and vegetables imported from developing countries, the tariff rate is zero. However, in order to benefit from these low tariffs, most single spices and herbs must be fully obtained in the supplier country. On the other hand, spices in mixtures are allowed to originate from different countries.

For most spices and herbs, tariffs are calculated as a certain percentage of import value, also called the ad valorem tariff. For example, dried sweet pepper from China faces an ad valorem tariff of 9.6%. In some cases, tariffs for spices and herbs are also calculated on a specific basis. For example, a tariff of CHF 5/100 kg is applied for the import of dried thyme from Tunisia to Switzerland.

Phytosanitary inspection

The European Union inspects food products to protect citizens, animals and plants from diseases and pests. A common way of protection is the inspection of food and the issuing of a phytosanitary certificate before export. Phytosanitary certificates are issued for plants or plant products which can be reproduced within Europe after import, such as bulbs, tubers or food containing seeds. Phytosanitary certificates are not required for most spices and herbs. The exceptions are seeds used for sowing and fresh spices such as garlic or ginger.

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 a suspension of imports from that country. Those stricter conditions usually include health certificates and analytical test reports for a certain percentage of shipments from specified countries. Products from countries that have shown repeated non-compliance are put on a list included in the Annex of the Official Controls Regulation.

Nevertheless, only a small part of the products imported and marketed in Europe is subject to official (physical) controls, since the first responsibility for their safety lays with the commercial operators, such as importers. Importers will therefore conduct most of the checks required to verify the product’s safety, and may also demand certification and other proof of quality and safety. Table 1 provides the frequency of official control for spices and herbs in the latest issue of the EU border control regulation.

Table 1: Official controls for spices and herbs (as of October 2020)

Product	Country of origin	Hazard	Frequency of official controls (%)
Black pepper	Brazil	Salmonella	20
Dried sweet peppers	China	Salmonella	20
Curry leaves	India	Pesticide residues	50
Dried chillies and sweet peppers	Sri Lanka	Aflatoxins	50
Spice mixes	Pakistan	Aflatoxins	50
Coriander leaves	Vietnam	Pesticide residues	50
Pepper, chillies, sweet peppers, ginger, saffron, turmeric (curcuma), thyme, bay leaves, curry and other spices	Ethiopia	Aflatoxins	50
Nutmeg	Indonesia	Aflatoxins	20
Betel leaves	India	Salmonella	10
Dried chillies and sweet peppers	India	Aflatoxins	20
Nutmeg	India	Aflatoxins	20

Source: EUR-Lex

Apart from border controls, official food controls include regular inspections that can be carried out during all further stages of marketing, up to the 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 for the general public.

RASFF reported 4,118 non-compliances found by official inspections in 2019, of which 1,499 were classified as border rejections. In the spices and herbs category, 110 border rejections were recorded. Most were related to microbiological contamination (mostly salmonella and Clostridium botulinum), the addition of unauthorised substances (very often in chillies), mycotoxins and pyrrolizidine alkaloids. However, it is estimated that the number on non-compliances is much larger, since the results of many controls conducted by private companies are not recorded by RASFF.

Control of contaminants

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

The most common requirements regarding contaminants in spices and herbs are related to microbiological contaminants, mycotoxins, and pesticide residues.

Contaminants by foreign bodies

Insects represent an important contamination issue for spices and herbs imported to the European market. Insects (or insect body parts) may be found dead in the packaging, but some types of insects can develop inside spices, such as whole chillies or nutmeg, and continue their growth during storage. Other types of contamination with foreign bodies include excreta of animals (such as mice, rats, cattle, birds or insects), sand, mud, stones, glass or metal parts (for example, from agricultural machinery and tools).

There is no official limit for foreign bodies in spices and herbs shipments to the European market. Most European buyers define their own specification requirements or follow the cleanliness specification of the American Spice Trade Association (ASTA). The cleanliness specification of ASTA defines the maximum presence of dead insects, excreta, moulds and other foreign matter. The Quality Minima Document (pdf) of the European Spices Association does not allow presence of any foreign objects greater than 2mm in diameter.

In order to prevent contamination with insects, suppliers from developing countries should implement preventive measures, such as heat treatment or fumigation. If using fumigation, you must apply only officially approved fumigants. For example, methyl bromide and ethylene oxide as fumigants are banned in the European Union. Using optical, metal and similar detectors is also recommended to prevent contamination with foreign bodies. However, physical sorting and eye-hand control is always recommended, even if detectors are installed.

Reducing the risk of microbiological contaminants

The most common type of microbiological contaminant in spices and herbs is salmonella. RASFF reported 90 cases of border rejection of spices and herbs due to the presence of salmonella in 2019. Many of those cases were related to imports of infected black pepper from Brazil.

In the European Union, over 9,000 salmonellosis cases are reported each year. EFSA has estimated that the overall economic burden of human salmonellosis could be as high as €3 billion a year.

Salmonella is usually transmitted to spices and herbs by irrigation with unsafe water, by use of untreated manure as fertiliser and/or by harvesting with dirty hands. Also, infestation with salmonella by animals or birds can happen in areas where the drying process is performed in the open air (often directly on the ground).

The European regulation on microbiological criteria for foodstuffs sets limits for pathogenic microorganisms, their toxins, and metabolites for certain products, but does not specify limits for spices. Table 2 lists the limits for the most common pathogens.

Table 2: Limits for the most important pathogens for spices and herbs after heat treatment

Pathogen or Toxin	Limit
Salmonella	Absent
E. coli	Absent
Enterobacteriaceae	100 cfu/g
Bacillus cereus	100 cfu/g
Yeast and mould	100 cfu/g

Mycotoxins control

The main reasons for border rejections for imported spices and herbs are related to microbiological contamination. 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 mycotoxins found in spices and herbs are aflatoxins, followed by Ochratoxin A. Aflatoxin contamination is most frequently found in imported dried chillies, but also in many other ground types of spices.

European food contaminants legislation sets aflatoxins and ochratoxin A limits for certain spices and herbs as presented in table 3.

Table 3: Aflatoxin limits in certain spices and herbs (as of September 2020)

Mycotoxin	Product	Limit (μg/kg)
Aflatoxins	Dried chillies and paprika, pepper, nutmeg, ginger, turmeric, mixtures of spices containing one or more of the listed	5 for B1 10 for sum of B1, B2, G1 and G2
Ochratoxin A	Pepper, nutmeg, ginger, turmeric, mixtures of spices containing one of the listed spices (including mixtures containing capsicum)	15
Ochratoxin A	Dried chillies and paprika	20

EUR-Lex

The EFSA launched a public consultation in 2019 and 2020 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 (causing genetic mutations) and carcinogenic (causing cancer). If new studies on the toxicity of ochratoxin A validate these results, the EFSA may reduce the current limits. However, more scientific data is necessary. The latest results show that the highest concentration is found in plant extract formulas, flavourings, essences and chili pepper.

Control of mycotoxins is best achieved by good agricultural and post-harvesting practices, such as a timely harvest or proper drying after harvest. It is recommended to dry spices and herbs only in thin layers and to frequently turn layers over. Appropriate moisture and temperature conditions during storage and transport are equally important. Timely detection and removal of contaminated material from the food supply chain is also an important control measure.

Plant toxins

Some toxins may be naturally present in weeds, which can contaminate products in the field. Limits for some plant toxins are set in the European contaminant legislation, but not yet for spices and herbs. The most important plant toxins for spices and herbs are tropane alkaloids (TA) and pyrrolizidine alkaloids (PA). The potential maximum levels are currently under discussion. Proposed limits (still not approved) for PA are 400 μg/kg, specifically for dried herbs and cumin seeds.

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

Polycyclic aromatic hydrocarbons

Several of the polycyclic aromatic hydrocarbons (PAH) contained in smoke, such as benzo(a)pyrene, can increase the risk of cancer. Excessive level of PAHs can contaminate spices and herbs, especially in cases where they are processed by heating and smoking. The level of PAHs can increase if the heat is too high, if fossil fuels are used and/or when smoking lasts too long. Crushing spices may also increase the level of PAHs, as crushed spices absorb more smoke compared to whole spices.

If spices are processed by smoking, it is particularly important to use only wood to produce smoke and not fossil fuels or gas. Also, it is important not to use coniferous types of wood and any type of wood that is chemically treated, because of its higher PAH level. Current European legislation on contaminants sets the maximum level of PAH for almost all spices and herbs with the exception of cardamon and smoked Capsicum spp. The maximum level for benzo(a)pyrene is set to 10μg/kg and for sum of all PAHs to 50μg/kg.

In 2020, 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 cover only the German market.

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. Specific limits for the presence of heavy metals in spices and herbs are not yet set in the European legislation on contaminants, but this may soon change.

The European Commission launched a review process for the maximum allowed levels of lead in 2020. New limits for some products may be set in 2021. Proposed limit values for lead (in mg/kg) are 0.60 for fruit spices, 1.5 for root and rhizome spices, 2 for bark spices, 1 for bud spices and flower pistil spices, and 0.9 for seed spices.

Irradiation

Irradiation of spices and herbs is not often used but is authorised as a way of sterilisation by the European Union. Irradiated foods must be labelled. European consumers dislike irradiated food. Buyers in Europe are commonly asking for radioactivity contamination tests for imported spices and herbs. Food irradiation legislation, maximum permitted levels of radioactive contamination and the European Union radiation protection legislation are the basic regulations for laboratory tests for the detection of the increased level of radioactivity in food.

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 sampling and testing, which often leads to public naming 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 in this list during 2020. The European Union Directive on Maximum Residue Levels on Pesticides (pdf) defines these MRLs and should therefore be checked frequently. As of November 2020, there were already more than 30 changes in MRLs in 2020 alone.

In 2020, the European Union implemented a set of policies and actions called the European Green Deal, with the aim of making the European economy more sustainable and climate neutral by 2050. The action plan also includes a 50% reduction in the use of pesticides and an increase 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.

In 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.

When assessing the MRL, pesticide residues found in dried spices and herbs have to be measured in relation to fresh products. In the case of dried products, such as dried herbs, article 20 of the European MRL regulation permits concentrations caused by the drying process to be taken into account when determining the MRL. The European Spice Association recommended different dehydration factors (pdf) for several spices and herbs, ranging from 3 for dried garlic up to 13 for coriander leaves. For seed spices, the dehydration factor does not apply.

Note that in organic products, the use of synthetic pesticides is not allowed. In practice, a very low level of residues is permitted in the product, if it can be proven that this is the result of cross contamination and not illegal use. However, the applicable limit is often a factor of 10 to 100 lower than that of conventional products, generally standing at 0.01 ppm.

Industry sources have been informing about bad practices of mixing spices containing excessive levels of residues with free-from pesticides spices to meet the required MRL. Although the final product may be in the required MRL limit, this practise should be avoided, as it is dangerous and not sustainable.

Control of chlorate and perchlorate

One of the most recent changes regards the level of chlorate adopted in 2020, set to 0.07 mg/kg for all spices. Legislation on levels of chlorate entered into force in June 2020. Chlorate is no longer approved as a pesticide, but it can come in contact with food by using chlorinated water during processing. Another source may be the use of chlorinated detergents used for cleaning facilities and processing equipment.

In its scientific opinion on the presence of chlorate in food, the EFSA found that current chlorate levels in drinking water and foods were too high and could negatively impact iodine uptake, especially among infants and children. Therefore, suppliers of spices and herbs must control the use of water and detergents in their production facilities. This includes water used for washing products before drying, water used to clean facilities and machines, but also water used in steam sterilisation processes.

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 and anti-caking agents) and flavourings (like smoke or oleoresins), which lists substances that are allowed to be used. Authorised additives are listed in Annex II of the Food Additives Regulation. Authorised uses of additives are listed according to the category of food to which they may be added.

Spices and herbs are often used as natural flavourings and colour enhancers. However, in some cases flavourings are also used to intensify the colour or flavour of spices. This practice, although sometimes used, is not appreciated. If those additives are not declared, this practice is considered fraud. Equally bad practice is false declaration of the spice, for example labelling dried sweet peppers as naturally smoked when smoke flavour is added. Placing undeclared substances in spices can ruin the reputation of the company doing so.

Examples of the most frequent problems with spices and herbs are related to excessive or undeclared content of food colours. According to the European Food Additive legislation, spices and spice blends may not contain added colours, although adding colours is allowed for seasonings. Typical examples are colours Sudan 1 and Orange II, which are sometimes used to intensify the colour of spices such as curcuma or dried chillies. Apart from being fraud, adding undeclared colours in spices can sometimes be dangerous too. A recent case has revealed that adding chromate pigment to curcuma contained an excessive level of lead.

Another example is false presentation of vanilla bean extract. Some vanilla extract is found to be adulterated with cheaper tonka bean extract. Tonka bean extract smells and tastes like vanilla bean extract, due to the presence of a compound called coumarin. Other food fraud examples include mixing oregano with other leaves (for example strawberry or olive), placing powdered materials in ground spices (such as brick powder or rice flour), placing used seeds (from the oleoresins production) in coriander, and replacing saffron with artificially dyed fibres.

Several organisations and projects have launched different initiatives to fight food fraud. The European Spice Association published the Adulteration Awareness document and the UK Spice and Seasoning Association published a guidance on the authenticity of herbs and spices.

Safe packaging and informative labelling

Export packaging must be in line with the European legislation on weighting, it must 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 first requirement is that the packaging is food safe (food grade) and that content in the packaging corresponds 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). Please note that in some European countries, labour health and safety legislation allows workers to lift a maximum of 20 kg. Therefore, the maximum size of export packaging must be in line with those rules.

Consumer packaging materials that come in contact with food (like cans, jars), have specific health control provisions. Food contact materials must be manufactured so that they do 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 of foodstuffs.

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 the inner coatings of jar lids. The use of BPA is currently still allowed, but its use is under review. The official opinion of the European Union Food Safety Authority will be published in 2020. However, BPA is more of a concern for the European spice companies, because they often sell spices and herbs in jars or plastic packaging. Most imported spices are packed in other types of bulk packaging.

The European Union has announced the introduction of new legislation concerning plastic packaging, mandating Member States to collect 90% of their plastic throw-away bottles from 2029. Also, some single-use plastics will be banned from 2021, 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. By 2030, all bottles in the European Union must be made from at least 30% recycled materials. You must be aware of those requirements and adapt to new export packaging materials in a timely manner.

From January 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 it is used to support Member states during the coronavirus pandemic.

Labelling requirements for retail food products

In the European Union, the labelling rules enable the citizens to get comprehensive information about the content and composition of food products. Labelling helps consumers make an informed choice while purchasing 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 the 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 Indonesian cinnamon is packed in Germany, the packaging must indicate the origin. The way to do this is to indicate “Indonesia” as the origin, but the packer can also write “non-EU” or declare “cinnamon does not originate from Germany." It is in your interest to negotiate with the buyer about clearly stating your country as the origin, although you usually do not have control over this.

Regarding spices and herbs, celery and mustard must be declared as allergens. Some spice mixtures can also contain allergens such as gluten, wheat or nuts. Sulphur dioxide (which is sometimes used as a preservative in spices) must also be declared as an allergen.

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, such as on allergens and composition.

It is possible to place additional nutritional information on a voluntary basis, such as the content of fibre, vitamins or minerals. In order to better inform consumers about healthier food choices, several voluntary nutritional labelling schemes were developed in Europe. The most famous and widely accepted by consumers 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) and 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.

European nutrition and health claims are important for exporters from developing countries aiming to sell labelled retail products directly to final consumers. It does not apply to business-to-business communication. European labelling legislation forbids misleading the consumer.

Claims that any food can prevent, treat or cure a human disease cannot be made on labelling in the European Union. Some spices and herbs are used in traditional western medicine and in eastern medicine such as Ayurveda. They are therefore often promoted as health beneficial. However, if you want to promote the nutritional and health benefits of spices and herbs, you must base any claim on solid scientific evidence.

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 traditionally been eaten outside of the European Union. Novel food must be approved and safe for consumption and properly labelled.

The European legislation on novel foods regulates the import of new and innovative foods to the European market, while maintaining a high level of food safety for European consumers.

For the notification of traditional foods from third countries, the new regulation simplifies the authorisation process 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 the EFSA. Within four months of receiving the valid notification, a Member State or the EFSA may submit safety objections to the notified traditional food entering the market.

2. What additional requirements do buyers often have?

European buyers often require proof of any implemented food safety standards in the form of specific certificates issued by the independent control bodies. Some of the buyers will have their own control lists and a number of different quality requirements. Aside from food safety and product quality aspects, there is an increasing demand for proof of sustainable and ethical business practices.

Product quality requirements

The quality of spices and herbs is determined by several factors, some as subjective as taste or flavour. Quality criteria may also vary by product. For example, for chillies, specific criteria are measured such as colour (for example using ASTA units) or pungency (using Scoville heat units). Those quality criteria are not always used for other spices and herbs. Some quality parameters are used for spices and herbs in general, including the following:

• Cleanliness or purity: spices and herbs must be free from diseases, foreign matters, foreign odours, and other disorders. The European Spice Association (ESA) says the maximum presence of external matter should be below 1% by weight for all spices. However, this requirement can vary depending on buyers’ requests and may involve more specific indicators, such as the maximum allowance of defective fruits or seeds, the number of dead insects or measuring of specific foreign matters (like in ASTA Cleanliness Specification).

Impurities of spices and herbs are also measured by burning the product at 550ºC to constant weight and measuring the ash residue. For different kinds of spices and herbs, different maximum levels are set for levels of acid in the ash. You can find them in the Quality Minima Document of the European Spice Association.

When shipped, the variety or cultivar should be declared in the product specification. If varieties or cultivars other than declared are present in the packaging, some buyers perceive it as fraud, but some buyers tolerate certain levels.

• Moisture content: the minimum moisture content for different spices and herbs is set in the Quality Minima Document of the European Spice Association. Still, buyers may request a different moisture content.
• Mesh or particle size: when spices and herbs are exported in powdered form, they are ground to pass through a sieve of a specific diameter. Sieves are often specified in micron sizes and typical requirements are that 95% to 99.5% of ground product can pass through the specific size of the sieve.
• Odour and flavour: specific spices and herbs must have a characteristic odour and flavour. The flavour profile of spices and herbs mostly depends on the chemical components of the essential oil. The flavour profile varies depending on the variety, cultivar, geographic, climatic and growth conditions.
• Essential oils: the quality of spices and herbs is generally higher when the percentage of ash is low, and the content of essential oils is high. The European Spice association defined a minimum content of essential oils for most spices and herbs.

Internationally recognised standards set quality and specification criteria more precisely for a few spices and herbs. Codex Alimentarius Standards for spices and herbs include standards for black, white and green pepper, cumin, dried thyme and for food-grade salt. The United Nations Economic Commission for Europe published a specific standard for dried whole chillies, and the International Standards Organisation (ISO) published several product specifications for different spices, culinary herbs and condiments.

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 food European food importers. Most established European importers will not work with you if you cannot provide some type of proof of food safety certification as the basis for cooperation.

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

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

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

Although different food safety certification systems are based on similar principles, some buyers may prefer one specific management system. For example, British buyers often require BRCGS, 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.

Laboratory control

In practice, food safety certification (although almost obligatory) is very often less important than 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 the laboratories that are performing testing is important to 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 can only perform a limited number of tests and for some, analysis samples must be sent to other countries. It is common for European buyers to ask for tests for more than 500 different pesticide residues.

Retail chains and other private sector requests

Although most European retailers will support the above listed certification schemes, many of them will ask for 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 not yet 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” has moved this limit to 30%.

The British retailer “Tesco” developed the specific certification scheme called “Tesco NURTURE.” Suppliers of this retail chain already needed the GlobalG.A.P. certification, and now they 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. Still, they are not widely recognised by all market segments.

Some ingredient users 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 use only pesticides from specifically developed lists.

Sustainability and corporate social responsibility (CSR) requests

Social, environmental and ethical activities relating to CSR in the European spices and herbs industry can be implemented at each level of the supply chain. From farm and production level, to the processing of spices and herbs, up to delivery to the consumer. Companies have different requirements for social responsibility. Some companies will require you to adhere to their code of conduct, or follow common standards such as the Supplier Ethical Data Exchange (SEDEX), Ethical Trading Initiative (ETI) or Business Social Compliance Initiative code of conduct (amfori BSCI).

Important sustainability issues in spices are related to pesticide residues and inadequate drying methods, leading to, among other things, aflatoxin problems. In order to improve sustainable production and sourcing of spices, a group of companies and organisations formed the Sustainable Spice Initiative (SSI). One of the aims of SSI members is to reach or exceed 25% sustainable sourcing in at least the top three product categories by 2025.

Sustainability has become one of the most important topics on the official European agenda. The European Union has implemented a set of policies called the European Green Deal, which aims to make the European economy sustainable and climate neutral by 2050. Specific measures included in the policies may impact supply from developing countries, for example the intended 50% reduction in the use of more hazardous pesticides and the increase of the share of agricultural land under organic farming to 25% by 2030.

Sustainability is also an important part of new certification schemes. The sections below describe several existing certifications focusing on environmental and social aspects. There are new certification schemes based on CO2 emissions, such as MyClimate and Carbon Footprint Certification. One certification scheme supporting several sustainability aspects is Planet Proof (PDF), which covers energy and climate, crop protection, biodiversity and landscape, soil fertility, clean water, packaging and waste.

Table 4: Most important certifications requested by buyers in processed fruit and vegetables sector

Name of certification	Type	Cost for companies	Most used in European end market (s)	Further information on getting certification
International Featured Standards (IFS)	Food safety	The costs of certification are not fixed. They depend on the number of products, number of certification days and company size. The average price for the 2-day audit for SMEs and 3–5 products is usually around €3,000. Additional costs include annual re-certification. The certificate is valid until the end of the second calendar year after the first certification date. Initial certification may cover infrastructural investments (to be paid for separately).	Germany France Recognised in many other European markets.	You can find more information about the process on the IFS Academy portal. You can find more details about the offer and costs on the list of recognised certification bodies. To find consultants to prepare you for the certification, you can search the IFS Consultants Database. You may also ask other consultants for offers. There are many experienced food safety consultants who are not part of this database. Use the IFS Audit Time Calculator to calculate the audit duration. Use the smart phone application IFS Audit Manager to make a self-assessment.
British Retail Consortium Global Standards (BRCGS)	Food safety	The costs of certification are not fixed. They depend on the company size, number of products and your role in the supply chain. BRCGS certification costs are usually higher than IFS and FSSC 22000 certification costs. Typical certification costs for a small company with up to 3 products are around €3,500. For many companies, it is common to be certified with one more scheme in addition to BRCGS. In that case, the certification costs may be lower if both certificates are issued by the same body. Additional costs include accommodation costs for the auditors and an annual fee for A and B grades. For a C grade, an audit is performed every 6 months.	Mostly the UK retail market. but recognised in other markets too.	To find a consultant or certification body, visit the partner sections of the BRCGS website.
Food Safety System Certification (FSSC 22000)	Food safety	The certification costs depend on the company size, number of audit days and number of products. For small companies (<20 employees), the costs depend on the number of products, but they are typically in the range of €1,500–€3,500. An additional fee is paid for annual audits. The audit certificate is valid for 3 years. Typically, additional costs include a consultancy fee for the preparation of the first audit. Certification may also cover infrastructural investments.	The Netherlands Italy France Spain Switzerland Scandinavia	Find FSSC 22000 certification preparation courses in your country to prepare yourself for the certification. Find a list of conformity assessment bodies to ask for an offer.
Sedex Members Ethical Trade Audit (SMETA)	Social audit focused on working conditions	Certification costs include a membership fee of £100 per production site and audit costs paid to the SMETA approved agency. The costs of the first certification are agreed with the agency and are not fixed, but for most SMEs, they are around €1,000.	The UK Germany Most European buyers recognise the SMETA audit as a valid assessment.	Check SMETA Guidance documents to become familiar with the certification process.
Business Social Compliance Initiative (amfori BSCI)	Social audit focused on working conditions	The costs of certification are not fixed and are agreed with the audit company. For SMEs, the costs are generally similar to the SMETA audit costs, which are around €1,000.	Germany The Netherlands	Check the list of amfori BSCI auditing, training and consultancy companies to ask for an offer for your company.
Fairtrade	Sustainability and ethics	The costs of certification are not fixed. Certification costs for fruit processing companies depend on the number of hired workers, number of products and number of processing plants. For example, the costs for an SME that hires 20 people and wants to certify 2 products would be around €3,000 for the first year. This includes the application fee, the certification costs and the processing fee.	The UK Germany Benelux	Check Flocert Cost Calculator to get a first idea of potential certification costs.
Rainforest Alliance	Environmental	The costs of certification are not fixed. Companies must apply to the authorised certification body for an offer. Total costs include administrative costs, audit fees, a premium price paid to farmers, sustainability investment costs and a volume-based royalty.	It is used in all European countries, but most in western and northern Europe.	Contact the authorised certification body in the Rainforest Alliance directory to check certification costs.
Organic	Sustainability, environmental	Products must be certified at the farmer level before being processed. The costs for individual farmers are considerably lower if famers are united in an association and pay a joint fee. Averages costs are around €1,000 for SMEs and the certificate must be renewed every year.	Germany All European countries have their own national organic labels.	Contact the EU authorised control bodies in your country to check certification costs.

3. What are the requirements for niche markets?

Increasing demand for certified organic products

To market spices and herbs as organic in Europe, they must be grown using organic production methods according to European legislation. Growing and processing facilities must be audited by an accredited certifier before you can put the European Union’s organic logo on your products, as well as the logo of the standard holder, such as Soil Association in the United Kingdom and Naturland in Germany. The procedure for 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 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 that are approved by the European Union regulation (EC) No 1235/2008. A common cost-saving practice for small farmers is group certification.
• Step 3 – Be ready for inspection - During inspection, the inspector verifies whether the organic management plan is consistent with the reality and investigates any findings. After evaluating the report, the control body decides if a certificate can be issued or some non-conformities must be corrected before the certificate can be issued.
• Step 4 – Get certified - If the control body confirms that the organic management plan is consistent with the reality, the organic certificate is issued. After being audited by an accredited certifier, you may include the EU organic logo on your products, along with the logo of the standard holder. Together with the logo, a certifier code number must be indicated. Be aware that an organic certificate is valid for one year from the issue date.

• Step 5 – Submit the certificate of inspection for shipments - Every shipment of organic products must be accompanied by the certificate of inspection, which is only issued electronically by selected certifiers, through the central platform called TRACES. European importers must also submit an application form for the import of organic products from developing country exporters. This application must include the company information, the name of the certifier, and the date of the last inspection. The importer also needs to submit a confirmation from a third party that the certifier fulfils the requirements of ISO standard 65/EN 45011.

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 have 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.

Social and environmental certifications

The two most commonly used sustainability certification schemes are Fairtrade and Rainforest Alliance. Fairtrade international has developed a specific standard for herbs, herbal teas and spices for small-scale producer organisations. This FairTrade standard includes the Minimum and Premium Prices 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 of human rights and the environment throughout the whole supply chain.

According to the draft legislation, 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.

Ethnic certification

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

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

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