What requirements should tea meet to be allowed on the European market?

The European market has strict demands regarding food safety and quality. The most important being the legislation regarding residue limits of pesticides. Other important issues are hygiene and contaminants. In addition, sustainability has become an increasingly important condition for market access. Mainstream certifications (e.g. Rainforest Alliance and UTZ Certified) are commonly required in the mass-market segment. Fairtrade certification also becomes increasingly adopted in the mass-market segment. In the higher quality and specialty segment, Fairtrade and organic certification prevail.

1. What legal requirements must my product comply with?

The most important demand of European buyers is that the tea complies with the strict food-safety legislation of the European Union. In this regard, issues concerning pesticides and contamination receive by far the most attention.

‘My number one question to potential new suppliers is: “Does the tea meet European MRL levels?”’ – European tea trader

Food safety: Traceability, hygiene and control

Food safety and food control are key issues in European food legislation. The General Food Law is the legislative framework regulation for food safety in the European Union. To guarantee food safety, it must be traceable throughout the supply chain, and risks of contamination must be limited. Implementing a quality management system can be an important tool in controlling food safety hazards.

The European Union exercises official checks on tea to guarantee compliance with the European food safety standards. The most common issue is compliance with maximum residue levels (MRLs), especially regarding tea from China. Non-compliance cases are registered in the RASSF database. In the event of (repeated) non-compliance, tea from non-complying countries is registered and included in a list for increased levels of official checks.

Maximum Residue Levels (MRLs) of pesticides in food

The use of pesticides is permitted in tea cultivation, but it should be strictly controlled. Pesticide residues are an important issue in the tea trade, particularly for tea from Asian countries (e.g. China, Vietnam, India, Indonesia, Sri Lanka).The European Union sets maximum levels on the amount of pesticides allowed on imported foods including tea. However, individual buyers in Germany for example, may have stricter requirements on MRLs than the official limits as part of their private standard (such as 30% of the level of the European Union). In addition, thresholds have become more rigorous as accredited laboratories are increasingly able to detect lower residue levels on dried tea leaves. The residues that are most commonly found in tea are dicofol, ethion, quinalphos, hexaconazole, fenpropathrin, fenvalerate and propargite. Residues vary by country of origin, however, and are constantly changing.

In recent years, issues have emerged with regard to the maximum level of anthraquinone, which is set at 0.02mg/kg for food, including tea leaves. In many cases, anthraquinone has not even been used as a pesticide on tea plants. The tea becomes contaminated during drying or packaging, or by smoke caused by tea drying. The European industry is continuing its research to find out the root cause for anthraquinone contamination. If anthraquinone contamination is not the result of pesticide contamination, it might fall under the contaminant regulation in the future.

Note that there is a lot of discussion about the implications of the regulations on both the tea producers and traders. Limits in the European Union are sometimes considered to be unrealistic or unnecessary strict and advocacy groups try to lobby for more workable and globally recognised MRLs.

Contaminants in food

The European Union has set maximum levels for certain contaminants. Besides pesticide residues, monitoring may take place for:

• Foreign matter: contamination by foreign matter such as plastic and insects is a threat when food safety procedures are not carefully followed.
• Mycotoxin contamination: Although mycotoxins are generally not a major problem in tea production, the situation may be different for some herbal teas.
• Microbiological: although tea is a low-risk commodity, contamination with salmonella can be a serious threat. The current European legislation has no microbiological criteria for tea. Food safety authorities can, however, withdraw imported food products from the market or prevent them from entering the European Union when salmonella is found to be present.

Pre-packed tea sold to consumers must adhere to strict requirements from the European Union concerning labelling, presentation and advertising of foodstuffs. It prescribes all of the information that must be mentioned on consumer packaging, including the list of ingredients, net quantity and the possible presence of allergens.

Although tea itself normally does not contain allergens, this may change if you sell mixes of (for example) herbal tea.

Extraction solvents

These can be used for decaffeination of tea. There are maximum residue limits restrictions for the extraction solvents such as methyl acetate (20 mg/kg) and dichloromethane (5 mg/kg).

2. What additional buyer requirements do buyers often have?

Next to the legally binding requirements, you should also consider complying with the following non-legal requirements which may be requested by European buyers.

Widespread sustainability certification for tea

Corporate social responsibility (CSR) and sustainability have become a major focus of the European food industry. Tea suppliers should therefore follow this trend closely, as it is increasing the demand for sustainability certification.

Relevant consumer labels on the European tea market include Rainforest Alliance, UTZ Certified, organic and Fairtrade. The mainstream market shares for Rainforest Alliance, and to a lesser extent UTZ, are experiencing a particularly strong increase. Note that, although mainstream sustainability certification is considered almost a ‘must’ for exporters to Europe, you will not necessarily receive a premium price for such certification. Such certification may nevertheless offer several positive financial effects, including the possibility of offering a competitive advantage to farmers and exporters (for providing related services), along with improved income due to increased efficiency and insight into their positions along the supply chain.

The Ethical Tea Partnership (ETP) is a not for profit membership organisation that works to improve tea sustainability, the lives of tea workers, and the environment in which tea is produced. Members range from large international tea packer brands to small independent labels.

Food safety management and traceability

Due to the growing attention for food safety, large retailers and other buyers, such as importers and processors in Europe, more often request food safety management systems (FSMS). The most important food safety management systems in the European Union are BRC, IFS, ISO22000 (FSSC22000) and SQF, which are mainly relevant for packers of consumer teas (not so much for farmers or traders).

All mentioned management systems are recognised by the Global Food Safety Initiative (GFSI), which means that any of them should be accepted by the major retailers. However, in practice some buyers still have preferences for one specific management system. So before considering certification against one of these standards, it is advised to check which one is preferred (e.g. British retailers often require BRC, whereas IFS is more commonly required on the European mainland).

Note that, even if a buyer has no strict requirement for a food-safety management system, the fact that you have implemented one demonstrates that you take food safety seriously. Furthermore, a food-safety management system may make it easier for you to ensure that your products meet the most important demand of your buyer: compliance with European food-safety legislation.

3. What are the requirements for niche markets?

In addition to the legal and non-legal requirements regarding food safety and sustainability, complying with the following niche requirements could offer you a competitive advantage and make it easier to find buyers in specific market segments (e.g. the market for specialty teas).

Sustainable product certification: Fairtrade and Organic certification

Where setting requirements regarding sustainability has become common practice in the European market for mainstream tea, there is a niche market for organically produced tea and tea produced according to fair trade principles. In general, prices for Fairtrade certified and organic tea are higher.

Organic

Organic tea is produced using natural techniques (such as crop rotation, biological crop protection, green manuring and, composting) instead of using chemical sprays and fertilisers. The main reasons that buyers have for purchasing organic tea is that it is considered healthier than conventional products, as it contains fewer residues and reduces the environmental impact of tea production.

To market tea as organic in Europe, tea must be grown using organic production methods as laid down in legislation drafted by the European Union. The growing and processing sites must be audited by an accredited certifier, as well as all players in the supply chain including the growers, traders and/or processors, this to ensure a chain of custody.

After certification, you are allowed to put the European Union organic logo on your products, as well as the logo of the standard holder (e.g. Soil Association and Organic Farmers and Growers in the United Kingdom and BCS Öko-Garantie or Naturland in Germany).

Fairtrade Certification

Having your tea Fairtrade certified according to the Standard of the Fairtrade Labelling Organisation (FLO Standard) is a way to show that your business is in line with sound social conditions. After certification by an independent third party, you are allowed to put the Fairtrade logo on your product. In general, prices paid for Fairtrade certified products are higher and consist of a minimum price plus a premium.

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