The European market has strict demands regarding food safety and quality. The most important being the legislation regarding residue limits of pesticides. Other important issues are hygiene and contaminants. In addition, sustainability has become an increasingly important condition for market access. Mainstream certifications (e.g. Rainforest Alliance and UTZ Certified) are commonly required in the mass-market segment. Fairtrade certification also becomes increasingly adopted in the mass-market segment. In the higher quality and specialty segment, Fairtrade and organic certification prevail.
1 . What legal requirements must my product comply with?
The most important demand of European buyers is that the tea complies with the strict food-safety legislation of the European Union. In this regard, issues concerning pesticides and contamination receive by far the most attention.
Food safety: Traceability, hygiene and control
Food safety and food control are key issues in European food legislation. The General Food Law is the legislative framework regulation for food safety in the European Union. To guarantee food safety, it must be traceable throughout the supply chain, and risks of contamination must be limited. Implementing a quality management system can be an important tool in controlling food safety hazards.
The European Union exercises official checks on tea to guarantee compliance with the European food safety standards. The most common issue is compliance with maximum residue levels (MRLs), especially regarding tea from China. Non-compliance cases are registered in the RASSF Database In the event of (repeated) non-compliance, tea from non-complying countries is registered and included in a list for increased levels of official checks.
Maximum Residue Levels (MRLs) of pesticides in food
The use of pesticides is permitted in tea cultivation, but it should be strictly controlled. Pesticide residues are an important issue in the tea trade, particularly for tea from Asian countries (e.g. China, Vietnam, India, Indonesia, Sri Lanka).The European Union sets maximum levels on the amount of pesticides allowed on imported foods including tea. However, individual buyers in Germany for example, may have stricter requirements on MRLs than the official limits as part of their private standard (such as 30% of the level of the European Union). In addition, thresholds have become more rigorous as accredited laboratories are increasingly able to detect lower residue levels on dried tea leaves. The residues that are most commonly found in tea are dicofol, ethion, quinalphos, hexaconazole, fenpropathrin, fenvalerate and propargite. Residues vary by country of origin, however, and are constantly changing.
In recent years, issues have emerged with regard to the maximum level of anthraquinone, which is set at 0.02mg/kg for food, including tea leaves. In many cases, anthraquinone has not even been used as a pesticide on tea plants. The tea becomes contaminated during drying or packaging, or by smoke caused by tea drying. The European industry is continuing its research to find out the root cause for anthraquinone contamination. If anthraquinone contamination is not the result of pesticide contamination, it might fall under the contaminant regulation in the future.
Note that there is a lot of discussion about the implications of the regulations on both the tea producers and traders. Limits in the European Union are sometimes considered to be unrealistic or unnecessary strict and advocacy groups try to lobby for more workable and globally recognised MRLs.
