Importing dried herbs and spices from Egypt into the European Union is routine trade, and most consignments clear without difficulty. The ones that do not usually fail on something that could have been settled before the contract was signed. This guide follows an import in the order it happens: who carries responsibility, what to settle before the first order, the documents, the border, the food-law checks, and a closing checklist.
It describes how the EU framework works rather than quoting limits, because limits are revised. Confirm the values in force with your customs broker and laboratory for each shipment.
1. Know who carries the legal responsibility
In the EU, the business that places food on the market is responsible for its compliance. Under the General Food Law, Regulation (EC) No 178/2002, that is the food business operator, and for an imported consignment that is normally the importer. An exporter's certificates support your due diligence. They do not transfer your responsibility.
Two duties follow directly and shape everything else:
- Traceability. You must be able to identify who supplied each lot and to whom you passed it on: one step back, one step forward.
- Withdrawal. If a lot proves non-compliant, you must be able to find it and act.
Both are much easier when the invoice, packing list, bag labels and certificate of analysis all carry the same lot number. Make that a contract term.
2. Before the first order
Registrations
- EORI number. Every business lodging customs declarations in the EU needs an Economic Operators Registration and Identification number. Your customs broker cannot clear goods in your name without it.
- Food business registration. Under Regulation (EC) No 852/2004 a food business operator must be registered with its national competent authority. If you are new to food imports, do this first.
Tariff classification
Each product needs its Combined Nomenclature code, and the TARIC code that adds EU measures to it. As a rough guide, spices such as cumin, coriander, fennel and anise sit in Chapter 9; many herbs sold mainly for infusion, such as chamomile and peppermint, are commonly classified under heading 1211; dried onion and garlic under heading 0712; and dried pulses under heading 0713. Form and intended use can change the code, so confirm it with your broker in TARIC rather than copying it from a previous supplier.
Preferential origin
Egypt and the EU trade under the EU–Egypt Association Agreement. Goods that satisfy its rules of origin can enter at a preferential rate when the consignment carries valid proof of origin, usually an EUR.1 movement certificate or, where permitted, an origin declaration on the invoice. Many herbs and spices already carry a low or zero conventional duty, so check TARIC before assuming the preference changes the landed cost. Where it does, name the proof of origin in the contract as a required document.
Border-control status
Implementing Regulation (EU) 2019/1793 lists particular combinations of food and country of origin that face more frequent official checks at the EU border, or that may only enter with an official certificate and laboratory results issued before shipment. Products are added after repeated findings, such as pesticide residues, mycotoxins or Salmonella, and the lists are reviewed regularly.
Check whether your product from Egypt is listed before you contract, and again before each shipment. If it is, the consignment must enter through a designated border control post and be pre-notified in the EU's TRACES system with a Common Health Entry Document, the CHED-D.
A specification written against EU law
Two regulations decide most compliance questions for herbs and spices:
- Regulation (EC) No 396/2005 sets maximum residue levels for pesticides, per substance and per product. A substance with no specific level for a product falls under a default level.
- Regulation (EU) 2023/915 sets maximum levels for contaminants, including aflatoxins and ochratoxin A in certain spices, and pyrrolizidine alkaloids in herbal infusions and dried herbs.
Write into the contract that analysis is against the EU framework in force on the date of shipment, name the laboratory, and state whether it must be accredited to ISO/IEC 17025 for the methods used. "EU compliant" with no reference and no date is not a term either side can test.
3. The documents that travel with the goods
| Document | Issued by | Why it matters |
|---|---|---|
| Commercial invoice | Exporter | Customs value, Incoterm and lot references |
| Packing list | Exporter | Packages and weights per lot; the basis of any physical check |
| Bill of lading | Carrier | Document of title for sea freight; its on-board date matters for letters of credit |
| EUR.1 or origin declaration | Egyptian customs, or the exporter where permitted | Preferential tariff, where it applies |
| Certificate of origin | Chamber of commerce | Frequently required by banks and buyers |
| Certificate of analysis | Laboratory, per lot | Evidence against the agreed specification |
| Phytosanitary certificate | Egypt's plant quarantine authority | Only for plant products that EU plant-health law requires it for, listed in Implementing Regulation (EU) 2019/2072. Many dried, processed herbs and spices do not need one; confirm per product |
| Official certificate with laboratory results | Egyptian competent authority | Only if the product is listed for special conditions under Regulation (EU) 2019/1793 |
| Certificate of inspection (organic) | Control body, in TRACES | Only for organic consignments, under Regulation (EU) 2018/848 |
Our export documents page lists the set HS Herbs issues with each shipment.
4. At the border
Your broker lodges the import declaration, and duty and import VAT are settled. For most herbs and spices, customs then applies its normal risk-based controls and the goods are released.
If your product is listed under Regulation (EU) 2019/1793, the consignment is held at the border control post for documentary and identity checks, and for physical checks with sampling at the frequency the regulation sets. It is released only once the checks are complete, so allow for the time in your production plan.
Whatever its status, a product can also be sampled on the market by national food authorities at any time. A non-compliant finding may be notified in the Rapid Alert System for Food and Feed (RASFF), which every member state sees. Repeated notifications are what put a product and origin on the increased-controls list, which is why a careless shipment from one supplier can raise costs for every importer of that product from that origin.
5. The food-safety points behind most problems
- Pesticide residues. The most common single cause of findings. Ask for residue analysis per lot, with a scope that covers the substances used on that crop in Egypt, not only a standard multi-residue list.
- Ethylene oxide. It is not approved for use in the EU, and residues are enforced at the lowest level laboratories can reliably quantify. Since 2020 it has been a routine check on sesame and many other ingredients. Ask your supplier to confirm in writing that no ethylene oxide treatment is used anywhere in the chain.
- Microbiology. Salmonella is one of the most frequent reasons herbs and spices are notified. Buyer specifications normally require its absence in a stated sample weight, and many European processors add a validated microbial-reduction step such as steam treatment. If you need treated material, specify it. Irradiation is permitted in the EU for dried aromatic herbs and spices, but only in approved facilities, and the food must be labelled as treated.
- Mycotoxins. Most relevant for chilli, paprika and similar spices, and controlled by drying and dry storage.
- Pyrrolizidine alkaloids. These come from weeds harvested with the crop and matter for herbal infusions such as chamomile and for several culinary herbs.
- Authenticity. Substitution and bulking are checked increasingly often. See our guide to authenticity and adulteration.
6. After release
Bulk material sold on for processing moves with its trade documents and bag labels: product name, lot, net weight and origin. If you pack for retail, the consumer label falls under Regulation (EU) No 1169/2011 and is your responsibility, not the exporter's. Keep a retained sample of every lot until the end of its shelf life. It is the evidence you will need if a question is ever raised about that lot.
7. Checklist
- EORI number and food business registration in place.
- CN and TARIC codes confirmed for each product and form.
- Preferential origin checked, and the proof of origin named in the contract where it saves duty.
- Border-control status under Regulation (EU) 2019/1793 checked before contract and before shipment.
- Specification written against EU law, with the laboratory and the date basis named.
- Written confirmation that no ethylene oxide is used in the chain.
- One lot number carried on every document and every bag.
- Plant-health requirements confirmed per product.
- Retained samples kept for every lot.
HS Herbs ships FOB Alexandria with the full documentation set, and agrees the specification in writing before shipment. For the commercial side of a first order, see the B2B sourcing guide. To discuss an EU shipment, contact our export team.
