Traceability

As a food business operator – including final importer – you must be able to trace and identify where your products came from and where they are going, to rapidly provide this information to health and safety authorities if required.

See the specific requirements under My export for more information on traceability.

Contaminants

Specific limits exist for certain antibiotics, heavy metals, and other chemicals in food. See My export for per product information on contaminant levels.


Special provisions on novel food

Novel foods are defined as foods or ingredients that were not popularly used for human consumption within the EU before 15 May 1997.

Companies may first search the Novel Food Catalogue whether the products they intend to sell have been recognised and listed.

In case the product is new, companies must apply to the competent body of a Member State for authorisation. The application should show:

  • The name and address of the applicant
  • Name, description, and composition of the food
  • How the food was produced
  • How it should be used, presented and labelled.
  • It should be able to name the studies proving the product is:
    • Not dangerous
    • Not misleading to the consumer
    • Does not provide lower nutrition to consumers compared to existing products they intend to replace

The resulting authorisation will define the conditions of use, the designation of the food or ingredient, its specification and the specific labelling requirements.

  • Some novel foods or ingredients may be seen as highly equivalent to existing foods by the national assessment body. These may be eligible for simplified procedures.
  • Some novel foods may be traditional foods from a third country. In this case the applicant should mention the country of origin and its history of safe use in the third country.

You are not allowed to state:

  • Health could be affected by not consuming the food.
  • Specific rates or amounts of weight loss that could be achieved.
  • References or recommendations by specific doctors or health professionals about the food.
  • The food reduces the risk of a disease without acknowledging that the disease has multiple risk factors, and altering one of these factors may or may not have a beneficial effect.

Standard labelling rules

  • NAME UNDER WHICH THE PRODUCT IS SOLD. Unless specific EU or national provisions apply, the name should be a customary name or a description. A trademark, brand name or fancy name may be used in addition to the generic name.
  • LIST OF INGREDIENTS, INCLUDING ADDITIVES.
    • Exception: single-ingredient foods, where the name of the food is identical to the name of the ingredient or enables the ingredient to be clearly identified.
    • Novel foods must detail properties (composition, nutrition, use, etc.) that make it dissimilar to existing foods or ingredients.
    • Novel foods must list any ingredient not already present in existing foods which may cause ethical concerns.
    • Novel foods must list any of its ingredients with Genetically Modified Organisms (GMOs).
    • States the importance of a varied and balanced diet and a healthy lifestyle.
    • Indicate any substances that might cause allergic reactions or health implications, and the health risks if the food are consumed to excess.
  • NET QUANTITY
  • MINIMUM DURABILITY DATE. Format: "best before DD/MM/YYYY"
  • SPECIAL CONDITIONS FOR STORAGE OR USE
  • NAME OR BUSINESS NAME AND ADDRESS of the manufacturer, packager, or seller established in the EU.
  • PLACE OF ORIGIN OR PROVENANCE, where its omission could be misleading for consumers.
  • LOT MARKING on pre-packaged foodstuffs. Format: "L..."

Rules on special nutrition and health claims

The EU has special rules for foods which have nutrition claims (e.g. no added sugar). These claims must be clear to understand, accurate, and based on scientific evidence.

Specific rules on nutrition and health claims include:

  • The presence, absence, or reduced content of a nutrient shown to have beneficial nutritional or physiological effects.
  • The presence, absence or reduction of a nutrient is at a suitably high/low level to produce the claimed nutritional/physiological effect.
  • Where applicable, the nutrient is available at a high enough level to be used by the body.
  • The food provides a significant amount of the nutrient to satisfy the claims made.
  • Comparative nutrition claims need to be made with foods of the same category.

A register of nutrition and health claims permitted in the EU allows food business operators to find existing permitted nutritional and health claims.

The European Food and Safety Authority (EFSA) is responsible for verifying scientific evidence behind health claims. These claims may be:

  • General function health claims (e.g. the role of a nutrient in body development, psychological function, weight control, etc.)
  • New function health claims (claims based on new or owned scientific evidence)
  • Disease risk reduction claims
  • Child development/health claims

These claims may already be in use or suggested by food business operators. The EFSA maintains a guidance page on how to apply for new health claim evaluations.


Novel food from organic production (voluntary)

Producers or importers may wish to make reference to a good being produced by organic methods. In this case the EU recognises ways in which organic plant production takes place:

  • Responsibly uses energy and natural resources such as air, water, soil, and organic matter while minimising the use of non-renewable resources
  • Excludes the use of any GMOs in production (e.g. GMO fertilisers) except for veterinary medical products
  • Additional substances like fertilisers, conditioners, or plant protection products can only be used if they are compatible with organic production principles.
  • Only certain products are allowed in the processing of food for it to be certified as organic. A full list of the products permitted can be accessed at the Database of the Organic Farming Information System website.

Processed food can only be labelled as organic if all or almost all of the agricultural-based ingredients are organic. The exception to this are processed food ingredients that cannot be obtained organically, such as from hunting.

EU countries may also have extra rules when it comes to organic production rules. Please consult with the relevant authorities in this case.

  • Pre-packed goods meeting all organic requirements and advertise as organic use the Organic logo of the EU. This makes it easy to be identified by consumers.
  • Next to the new EU Organic logo, the code number of the control body as well as where the agricultural raw materials came from should be displayed.
  • The logo can also be used for non-prepacked organic goods exported to the EU, as long as they fill all the EU requirements for organic goods.