EU import compliance
Pesticide residues and contaminants in food imported into the EU
A consignment that meets its commercial specification can still be stopped at an EU border because of a pesticide residue or a contaminant. Two regulations set the limits; a third decides which products are checked more often. An analysis plan should be built around all three before the first container ships.
Last reviewed: November 5, 2026
01
Pesticide residues: Regulation (EC) No 396/2005
Regulation (EC) No 396/2005 sets maximum residue levels (MRLs) for each pesticide on each product, for food produced in the EU and for imports alike. The values are published in the EU Pesticides Database.
Where no specific MRL exists for a product, no default value is set for the substance, and the substance is not exempted, the applicable level is 0.01 mg/kg (Article 18). In practice this is close to the limit of quantification: a substance permitted in the country of production but not approved for that crop in the EU can make a lot non-compliant.
MRLs apply to the product as placed on the market. For dried or processed products, such as dried herbs or tomato paste, the level is assessed with processing factors, so the fresh-product MRL is the starting point, not the answer.
02
Contaminants: Regulation (EU) 2023/915
Commission Regulation (EU) 2023/915 sets maximum levels for contaminants in food. It applies from May 25, 2023 and replaced Regulation (EC) No 1881/2006 without changing the limits it contained.
| Group | Examples | Products to watch |
|---|---|---|
| Mycotoxins | Aflatoxins, ochratoxin A | Groundnuts, spices, dried fruit, cereals |
| Plant toxins | Pyrrolizidine alkaloids, tropane alkaloids | Dried herbs, herbal infusions, cereals |
| Metals | Lead, cadmium, inorganic tin | Canned foods, rice, fresh herbs |
| Processing contaminants | Polycyclic aromatic hydrocarbons, 3-MCPD and glycidyl esters | Dried herbs and spices, vegetable oils |
For dried, diluted, processed and compound foods, Article 3 requires the maximum level to be applied taking account of the change in concentration and the proportion of each ingredient.
03
Increased checks at the border
Implementing Regulation (EU) 2019/1793 lists combinations of product, origin and hazard that face a higher rate of identity and physical checks at the EU border control post, and in some cases require an official certificate and analysis report issued in the country of export. The list is reviewed regularly; the most recent amendment at the time of writing is Implementing Regulation (EU) 2026/194, in force from February 18, 2026.
- Check the current consolidated annexes on EUR-Lex for the product's CN code and origin before quotation
- Where an official certificate is required, the lab results must come from the sampling the regulation specifies
- Consignments are pre-notified through the Common Health Entry Document (CHED) in TRACES
04
Building an analysis plan
| Scope | Multi-residue pesticide screen plus the contaminants relevant to the product group |
|---|---|
| Laboratory | Accredited to ISO/IEC 17025 for the methods used |
| Sampling | Per lot, by a stated method, before shipment |
| Reporting | Results against the current EU limit, with the limit of quantification for each analyte |
| Release | No shipment until results are within limits and shared with the buyer |
05
How we handle it
- Analysis plan agreed per program against EU MRLs and contaminant limits before the first order
- Lot results shared with the buyer before shipment, not after arrival
- Products under increased official controls identified at quotation, with the certificate and analysis they need
- Producing-site records checked for crop treatments not approved in the EU
Product programs this guide applies to
Next step
Planning a program that has to meet these requirements?
Send the product, target market, pack format and expected volume. We review the commercial fit and come back with the questions that matter before a quotation.
Source and scope
Source. Regulation (EC) No 396/2005 on maximum residue levels of pesticides, in particular Article 18; Commission Regulation (EU) 2023/915 on maximum levels for certain contaminants in food; Commission Implementing Regulation (EU) 2019/1793 as amended, most recently by Implementing Regulation (EU) 2026/194. European Commission: EU Pesticides Database. EUR-Lex: Regulation (EU) 2023/915. EUR-Lex: Implementing Regulation (EU) 2026/194.
Scope. General information for commercial importers, not legal advice. Limits and the list of products under increased controls change; check the current values for your product, origin and CN code before contracting.
Inquiries: sales@alphatradecorp.com