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

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Takes 36 minutes to read

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 2019, for example, regulations were changed for nearly 80 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.

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 regulation on increased level of official controls on imports.

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 May 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 and sweet peppers

Ethiopia

Aflatoxins

50

Nutmeg

Indonesia

Aflatoxins

20

Betel leaves

India

Salmonella

10

Dried chillies and sweet peppers

India

Aflatoxins

20

Nutmeg

India

Aflatoxins

20

Dried chillies

India

Pesticide residues

10

Dried chillies

Pakistan

Pesticide residues

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.

Tips:

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

Control of contaminants

Food contaminants are unwanted and harmful substances in food that can cause consumer illness. These substances may be present in 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 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

Tips:

  • Follow the most recent trends on food safety testing developments. Increase the amount of quick tests on site. Automating and computerising food safety testing methods can help you in your production process.
  • Read the news on the webpage of the European Food Safety Authority (EFSA) to stay up to date on the latest food safety developments.
  • Follow the Code of Hygienic Practice for Low Moisture Food published by Codex Alimentarius, to prevent microbiological contamination.
  • Follow the General Guideline for Good Agricultural Practices on Spices and Culinary Herbs (pdf) to prevent any type of contamination.
  • Invest in heat sterilisation, such as with saturated steam at 121°C, to guarantee food safety concerning pathogen microorganisms. European buyers favour heat sterilisation, as it is natural and chemical- and radiation-free. As heat treatment equipment is a capital investment, you can use the services of a third party in Europe to do the important heat treatment according to your customer’s requirements.

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

Source: 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 not found in processed fruit and vegetables but in plant extract formulas, flavourings, essences and chili pepper.

Control of mycotoxins is best achieved by good 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.

Heavy metals

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.

Tips:

Limited use of pesticides

The European Union has set maximum residue levels (MRLs) for pesticides in and on food products. If your product contains illegal pesticides or higher amounts of pesticides 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. There were 80 changes to this list during 2019. The European Union Directive on Maximum Residue Levels on Pesticides (pdf) defines MRLs and should be checked frequently. As of November, there were also more than 30 changes in MRLs in 202 alone. One of the most important changes is the level of chlorpyrifos, which is set at 0.01ppm from November 2020.

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 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.

Tips:

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

Control of chlorate

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.

Tips:

  • Read more about additives for spices and herbs in the Food Additives Regulation under section twelve.
  • Use the European Commission’s Food Additives Database to check which food additives are allowed in Europe.
  • Prepare in advance for the potential changes of food additives limits by checking the re-evaluation of food additives on the website of European Commission.
  • Stick to the rules! New laboratory testing methods can easily discover the addition of non-permitted colours, flavours or undeclared ingredients. It takes a long time and a lot of money to build a good reputation in European markets, but it can be lost very quickly if you are caught with adulterated or sub-standard products.

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.

During a meeting of the European Council in July 2020, it was agreed that a new tax will be applied in the European Union from 1 January 2021 on non-recycled plastic packaging waste at a rate of €0.80 per kilo. The tax was announced within the agreed EU recovery deal to support member states during the coronavirus pandemic, and the revenue generated by the tax is set to go directly into the EU budget.

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:

  • Labelling of the energy value and the quantities of fat, saturates, carbohydrates, protein, sugars and salt.
  • Presentation of allergens (like soy, nuts, gluten, lactose) for pre-packed foods (emphasis on font, style or background colour) in the list of ingredients.
  • Mandatory allergen information for non-pre-packed food, including in restaurants and cafes.
  • Minimum font size of 1.2mm for the mandatory information.

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.

In addition to this regulation, all food in retail packs in Europe must be labelled with an indication of origin as of 1 April 2020. For example, if a product is packed in the Netherlands, the packaging still needs to indicate the origin. This can be done by indicating a country (for example Egypt), by indicating ‘non-EU’, or by declaring ‘product does not originate from the Netherlands’.

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. 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.

Tips:

  • For practical guidance on food labelling for pre-packed products, see a guidance document on information about the new food labelling legislation (pdf) and check the official guidance document (pdf) published by the European Commission on the control of compliance with nutrient values declared on a label.
  • Note that the presence of allergens is becoming more and more important. The chance of cross-contamination — for example when a product is processed in a factory that also processes peanuts — is sometimes even considered to be possible at farm level.
  • For product-specific packaging requirements, read the product specific studies about promising export products.
  • Be aware of new plastic packaging rules in Europe and timely adapt to new packaging materials.
  • Ask your customer to approve the print concept, before you start printing or labelling.

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.

As of 1 January 2018, the new Regulation (EU) 2015/2283 on novel foods entered into force. The new Regulation improves conditions, so that food businesses can easily bring 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.

Tip:

  • To check if your product or ingredient is authorised as a novel food, check a Novel Food Catalogue. Note that the list is non-exhaustive and serves as orientation on whether a product will need authorisation under the Novel Food Regulation.

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.
  • Volatile and 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:

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.

Tips:

  • Read the Quality Minima Document of the European Spice Association (ESA). This document describes European buyers’ minimum quality requirements for dried herbs and spices.
  • Follow the Good Manufacturing Practices Guide for Spices by the American Spice Trade Association.
  • Get food safety certification. However, check with the importers and experts if the food safety certification company you consult is appreciated by European Union buyers. Examples of independent internationally accredited certification companies include SGS, CIS, TÜV and Bureau Veritas.
  • Make sure sampling is done according to the European sampling regulations, as a high sampling reliability of each separate lot is very important to mitigate the risks.

Private pesticide residues requests

Be aware that some European buyers may use stricter limits for pesticide residues than official MRL regulations. Most supermarkets have their own standards (codes of practices) regarding pesticides, which are stricter than legislation. Recent examples include the Danish operations of supermarket chains Coop, Aldi and Lidl, which have more stringent pesticide residue standards than legally required: Lidl requires 66% less residue, Coop 50% less and Aldi 20%–30% less than mandated by European Union legislation.

More European retailers are expected to increase their demands regarding pesticide residues. If your buyers do business with these supermarkets, they will impose these standards on your products too. Suppliers that are able to reduce pesticide residues in their products will improve their chances of selling to European retailers.

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 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, among which a 50% reduction in the use of more hazardous pesticides and increasing 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 or Carbon Footprint Certification. One certification scheme supporting several sustainability aspects is Planet Proof, which covers energy and climate, crop protection, biodiversity and landscape, soil fertility, clean water, packaging and waste.

Tips:

  • Do a self-assessment through the questionnaire from the BSCI website.
  • Follow Sustainable Agricultural Practices for Spices (pdf) issued by Sustainable Spices Initiative India.
  • If you are from India or Vietnam, join SSSI national platforms.
  • Ask your farmers to fill in the Farmer Self Assessment by the Sustainable Agriculture Initiative to check how sustainable their production is.
  • Consider implementing management systems such as ISO14001 (environmental aspects), OHSAS 18001 (occupational health and safety), ISO 26000 (a comprehensive system including all social responsibility aspects) or SA 8000 (labour and working conditions). Those systems are good ways to address sustainability and possibly gain a competitive advantage. Explore with your buyer whether they would appreciate this.

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.

The new EU regulation on organic production of 2018 is expected to enter into force in 2022. The new rules will allow for mixed farming, and combining conventional and organic production, provided that the two are sufficiently separated. Inspections of organic production and organic products will also become stricter to prevent fraud. Producers in third countries will have to comply with the same set of rules as those producing in the European Union.

Tips:

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

Social and 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.

Tips:

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.

Tip:

  • If you are focusing on the Jewish or Islamic market within Europe, you should become familiar with relevant certification procedures. You can find answers from many Halal or Kosher certification organisations.

 

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

 

Please review our market information disclaimer.

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