Importing Indian spices into the EU: documents and tests

The paperwork that matters for an Indian spice container arriving in the EU is not the paperwork most first-time buyers ask for. Indian export documents — the Spices Board registration, our licences, our lab report — are not what the EU border checks against. One EU regulation decides almost everything about how your consignment is treated on arrival, and it is rewritten twice a year.

The regulation in force

It is Commission Implementing Regulation (EU) 2019/1793, which implements Regulation (EU) 2017/625 and Regulation (EC) No 178/2002. It does two things: it imposes a temporary increase of official controls at the entry into the Union on certain food and feed of non-animal origin from certain third countries (Annex I), and it imposes special conditions on entry for certain consignments because of contamination risk from mycotoxins including aflatoxins, pesticide residues, microbiological contamination, Sudan dyes and plant toxins (Annex II).

The version you need is 2019/1793 as last amended by Commission Implementing Regulation (EU) 2026/1206 of 9 June 2026. The amendment before that was (EU) 2026/194 of 28 January 2026, published in OJ L, 2026/194, 29.1.2026. Both work the same way: Article 1 says the Annexes are replaced by the text set out in the Annex to the amending regulation. Not edited — replaced. An annex printout from last year is worthless.

Two annexes, two different outcomes

Annex I is headed "Food and feed of non-animal origin from certain third countries subject to a temporary increase of official controls at border control posts and control points". Each row gives the country, the goods with their CN code, the hazard, and a column for the frequency of identity and physical checks as a percentage. In the January 2026 revision the Commission set or raised frequencies of 20%, 30% and 50% on various goods. That percentage is a sampling rate applied across consignments. You cannot predict which of yours will be drawn, and you should price and schedule as if it will be.

Annex II is the heavier regime: special conditions for entry, meaning official documentation issued in the exporting country and analytical results travelling with the goods, on top of the border checks. Entries move between the two lists in both directions. In January 2026 the Commission deleted one Annex II entry and transferred it to Annex I at a 20% check frequency, on the basis of the number of consignments seen in recent years.

Listings also get narrowed rather than deleted outright. Okra from India had been under increased controls since July 2018 for both pesticide residues and ethylene oxide; the Commission found the ethylene oxide results satisfactory and removed that hazard, while the pesticide residues listing stayed. A product can be "off the list" for one contaminant and still fully listed for another. Read the hazard column, not just the product name.

Every six months, without fail

Article 12 of 2019/1793 obliges the Commission to review the lists at intervals not exceeding six months. That review is driven by RASFF notifications and by Member States' own official control results. So the correct question is never "is turmeric listed?" It is "what does the Annex in force on the date my container arrives say for this CN code and this hazard?" Check it after you fix the shipment date, not when you place the order.

Getting the analysis right

Where a consignment is listed, 2019/1793 prescribes how the sampling and analysis must be done. In the consolidated text, sampling for possible non-compliance with maximum residue levels for pesticides is to follow Directive 2002/63/EC, and sampling and analysis for mycotoxins in feed follows Regulation (EC) No 152/2009. A report from a good laboratory that used a different sampling plan is still a report from a good laboratory — but it is not the one the regulation asks for. If your product is Annex II listed, tell us before we book the lab, because the sampling protocol, not the analytical method, is usually what goes wrong.

What the Indian documents are for

We hold Spices Board registration as an exporter of spices (CRES), APEDA RCMC, an FSSAI central licence, ISO 22000:2018 and ISO 9001:2015. These govern whether we may export from India and under what oversight. None of them is the document an EU border control post asks to see. Where a listing or a Member State requires an official certificate or health certificate, it is issued by the designated Indian authority in the model the EU regulation sets out, not by us and not by the Spices Board on its own initiative. Confirm with your customs broker which certificate your specific CN code needs before the container is stuffed — retro-fitting an official certificate after loading is not possible.

Great Britain diverges

If you also ship to GB, do not assume one list covers both. Great Britain amends its own assimilated version of 2019/1793 by statutory instrument — for example the Official Controls (Import of High-Risk Food and Feed of Non-Animal Origin) (Amendment of Commission Implementing Regulation (EU) 2019/1793) (England) (No. 2) Regulations 2024, SI 2024/1169, which substituted both annexes for Great Britain. The products and the check frequencies are not identical to the EU's.

Practical note

We are a merchant exporter in Veraval, Gujarat. We do not own farms or processing plants and we are not organic certified. Every lot is tested before shipment and the certificates of analysis ship with the documents. Minimum order is 1,000 kg per product and mixed containers are fine — which matters here, because a mixed container can put one Annex II product alongside several unlisted ones, and the listed line sets the pace for the whole box. Send us the CN codes you intend to declare and we will tell you what we can document. Verify the annexes yourself on EUR-Lex before you contract.

Sources

• Commission Implementing Regulation (EU) 2026/194 of 28 January 2026 amends 2019/1793; published OJ L, 2026/194, 29.1.2026; Article 1 replaces Annexes I and II; entry into force on the twentieth day after publication. — eur-lex.europa.eu
• Recitals of 2026/194: purpose of Annexes I and II of 2019/1793 (increased controls; special conditions for mycotoxins including aflatoxins, pesticide residues, microbiological contamination, Sudan dyes, plant toxins); Article 12 six-month review obligation; frequencies set at 20%, 30% and 50%; an Annex II entry deleted and transferred to Annex I at 20%; okra from India listed since July 2018 for pesticide residues and ethylene oxide, ethylene oxide results satisfactory. — eur-lex.europa.eu
• Commission Implementing Regulation (EU) 2026/1206 of 9 June 2026 amending Implementing Regulation (EU) 2019/1793 is the most recent amendment identified. — eur-lex.europa.eu
• Consolidated 2019/1793: sampling for pesticide residues under Directive 2002/63/EC; sampling and analysis for mycotoxins in feed under Regulation (EC) No 152/2009. — eur-lex.europa.eu
• Great Britain amends its own version of 2019/1793 by statutory instrument; SI 2024/1169 substitutes Annexes 1 and 2 for Great Britain. — legislation.gov.uk