Requirements for processed vegetables, fruit, berries and nuts
There are mandatory requirements that must be fulfilled in order for your product to be allowed on the European Union (EU) market. These requirements insure that all food that is sold on the EU market is safe for consumption. Besides the mandatory requirements, there are voluntary requirements such as organic certification and compliance with private standards. These are not required by EU law, but may be requested by your importer or retailer in the EU.
The processed food industry is very wide and therefore we chose to limit this information to include only mandatory requirements for processed vegetables, fruit, berries and nuts.
Processed foods make up a large share of the Swedish food and grocery market, import turnover reaches nearly 8 million euros a year.
Please bear in mind that for you as an exporter, by fulfilling some of the private standards that are used and are common for your products, you may fulfil some of the mandatory requirements that are described on this page. We therefore always recommend you to have a dialogue with your importer or retailer on what private standards they request and how you may be able to fulfil them.
Your tariff code
To understand what mandatory requirements your product must fulfil, you have to start by defining your product, in particular identifying the tariff code. The code will differ depending on which type of products you as an exporter have.
A tariff code is a product-specific code as documented in the Harmonized Commodity Description and Coding System (HS code) which is an international standardised system of names and numbers for the classification of commodities. The vast majority of the countries around the world use the HS code system, including the EU. The EU’s tariff codes are 10 digits long, adding 4 digits after the international HS-code. The tariff code is also called “product code” or TARIC code in Europe.
The tariff codes relevant for this information falls under chapter 20: Preparations of vegetables, fruit, berries, nuts or other parts of plants (group 2001- 2009) in the Harmonised System (HS). Example of tariff codes:
- cornichons, preserved in vinegar or acetic acid 2001 10 00 90
- peanut butter 2008 11 10 00.
What are the mandatory requirements for processed vegetables, fruit, berries and nuts?
The EU has a comprehensive set of rules that covers the entire food production and processing chain within the EU, as well as imported and exported goods. The purpose is to ensure that all foodstuff placed on the EU market, whether produced in the EU or imported, is safe and follows the same rules.
Below you will gain a better understanding of the mandatory requirements for processed vegetables, fruit, berries and nuts and how they may affect you as an exporter. If you have any questions, do not hesitate to contact Open Trade Gate Sweden.
Hazard Analysis Critical Control Points (HACCP)
The EU rules on food safety rest on an important tool throughout the whole production and supply chain: food safety management based on Hazard Analysis Critical Control Points (HACCP) principles. HACCP planning consists of consecutive steps to: identify food safety hazards, determine how you can control them (i.e. critical control points) and to implement corrective measures when you cannot guarantee the safety of the foods produced. EU law has specific rules about hygiene of food products, including guidance on the HACCP system. These need to be respected by companies in the EU as well as companies in countries outside of the EU, that are interesting in exporting food products to the EU.
In practical terms, this means that you should establish and operate food safety programmes and procedures based on the HACCP principles. This includes for instance that employees should be trained in the application of the HACCP principles. You also need to have procedures that describe how your products are handled in your company, including documentation of record keeping of the procedures.
Guidelines on how to implement HACCP principles in practice (EUR-lex website)
Another way of learning about HACCP principles is to do HACCP trainings and obtain certification. There are many courses (some online) and you should visit the websites of standardisation bodies if you want to obtain certification.
EU law defines traceability as the ability to trace and follow any food, feed, food-producing animal or substance that will be used for consumption, throughout all stages of production, processing and distribution. The principle behind traceability is to insure that food and feed that are put on the EU market is safe for consumers. Food business operators are the ones that must comply with the requirements for traceability and have a system in place with information to the competent authority in the respective member state, upon request.
It is important to mention that traceability provisions does not apply outside the EU, but can affect you as an exporter anyway. This because the EU importer must be able to identify from whom the product was exported.
All food that are marketed in the EU must comply with EU’s labelling rules, which aims at ensuring that consumers get all the essential information to make well-informed choices while purchasing their food.
The EU has a regulation that defines which mandatory information should be on the label for processed vegetables, fruit, berries and nuts. These are:
- Name of product,
- List of ingredients,
- Allergen information,
- Quantity of certain ingredients or categories of ingredients,
- Net quantity of the food,
- Date of minimum durability ('best before' date) or the 'use by' date,
- ‘Best before date’,
- Storage conditions and/or usage,
- Nutrition declaration (energy value, amounts of fat, saturates, carbohydrate, sugars, protein and salt),
- Name and address of the packer and/or dispatcher,
- Instructions for use where it would be difficult to make appropriate use of the food in the absence of such instructions.
In Sweden, labelling needs to be in Swedish.
Labelling of specific food groups
There are also labelling provisions which apply to specific groups of processed products such as fruit juices and fruit jams, jellies, marmalades and sweetened chestnut purée.
When it comes to labelling of fruit juices, the labelling has to make it clear if the product is a mixture of different fruits or if the product has been obtained entirely or partly from a concentrate.
Jams, jellies, marmalades and sweetened chestnut purée are defined on the basis of their composition, which you can read more about under related information. The product name is supplemented by an indication of the fruit or fruits used, in descending order of weight. However, for products manufactured from three or more fruits, the indication of the fruits used may be replaced by the words ‘mixed fruit’ or a similar wording, or by the number of fruits used.
In addition, the labelling of jams, jellies and marmalades must include the following:
- fruit content per 100 grams of product;
- total sugar content
- residual content of sulphur dioxide, if more than 10 mg/kg.
The Directive includes a list, Annex II, with ingredients that you are allowed to add to your products such as honey, fruit juice and citrus peel.
The responsibility of labelling lies with the EU importer, but as an exporter you should be able to provide the information to the EU importer, at least in English. Therefore, it is very important that you and your EU importer discuss what information needs to be visible on the label. You are more than welcome to contact Open Trade Gate Sweden for more information or clarifications.
Contaminants are substances that have not been intentionally added to food. These substances may be present in your products because of the various stages of production, packaging, transport or holding. They also might result from environmental contamination. Since contamination generally has a negative impact on the quality of food and may imply a risk to human health, the EU has taken measures to minimise contaminants (for example regarding certain fungi and metals) in food. Food containing a contaminant to an amount unacceptable from a public health point of view and in particular at a toxicological level are not allowed on the EU market.
Remember that a specific product, for example dried mango, may not be mentioned in the regulation, but are included in a broader group, e.g. fruit. You can read more about contaminants on Directorate-General for Health and Food Safety’s website. The website can be found below under related information.
Companies in the EU must stop sales of processed vegetables, fruit, berries and nuts if the products are found to have higher levels of contaminants than allowed. If it is found that the contaminant could also pose a health risk, the company must withdraw their products from the market and inform the consumers. In addition, the member state’s responsible national authority sends a warning message, via a digital system (Rapid Alert System for Food and Feed, RASFF), to all other EU countries.
The ultimate responsibility of the products lies on the EU importer, which means that they will need to trust you, as an exporter, and that you will send products of agreed quality. Therefore, it is important that you talk to your buyer and ask which contaminants may be relevant for your products. You need to stay informed on the rules and do proper testing of your products before you send them to the EU market. Your EU importer may ask you for report analysis after testing or other documentation in order to be sure that your products will pass inspection at the EU border.
Worth mentioning is that some countries have additional control measures they have to go through if exporting to the EU. This means that specific products needs to be accompanied with a health certificate and a report of analysis for different kind of pesticides or contaminants or other hazardous substances. Liability lies on your EU importer but we recommend that you keep yourself informed. The regulation is found under related information. Bear in mind that the rules may change over time, which means that it is important that you as an exporter need to know what is applicable. You can also contact Open Trade Gate Sweden for help with regards to this.
Pesticides are used to protect plants from pests, weeds and mold, but because they can be harmful to humans and the environment, they are tested thoroughly before being approved in the EU. EU law has strict rules for when and how pesticides may be used. Many pesticides that were previously used are no longer approved in the EU. Countries outside of the EU need to provide a plan guaranteeing monitoring of the groups of residues and substances used in processed food. Substances are not allowed to be used if they are prohibited by the EU. The European Commission has a pesticide database where you can browse and learn about acceptable levels of pesticides.
The EU pesticides database on the European Commission website
Like contaminants, products containing more pesticides than allowed are withdrawn from the EU market and if the pesticide pose a health risk, a warning will be sent to other EU member states via RASFF. An exporter needs to be aware if pesticides are present in their products and make sure they fall within the acceptable levels allowed in the EU.
Do not be surprised if your EU importer asks about which pesticides are used and which programmes you follow. You must prove, through testing, that your products meet the requirements for maximum permissible levels of pesticide residues. It may be a lot to manage and therefore it is very important that you check with your importer if she or he has additional or stricter requirements about pesticide residues than the EU’s acceptable levels.
There are rules that decides which food additives that are allowed, such as colorants, sweeteners and preservatives etc. If your product includes additives that is not allowed then your product will be stopped from being released on the EU market by the European authorities. The additives that are allowed are listed in Annex II of the food additive regulation, which can be found under related information. You can also use the European Commission’s food additives database where you can browse and learn more about which additives that are allowed in the EU.
Get further support
If you would like to find out more about the rules and regulations that your product must fulfil in order to be accepted on the EU market, you could consult one or several available online-tools.
And remember that you can always contact Open Trade Gate Sweden for any queries.