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Exporting food from the EU

Food exported from the EU must meet EU food law unless the destination says otherwise. Animal products and plants often need an export certificate, issued by the member state's competent authority, many through the Commission's TRACES platform. The exporter lodges an export declaration with an EORI number, and proves origin to claim a lower tariff.

Updated · Each section links to the official source it comes from

Food law on exports
Article 12 of Regulation (EC) No 178/2002
Animal product certificates
Member state officers, often on harmonised certificates in TRACES
Plants, fruit and vegetables
Phytosanitary certificate for export, where the destination requires it
Declaration
Electronic export declaration in AES, with an EORI number
Origin
List rules by HS heading; REX statements or EUR.1

Before the goods leave

The questions to answer, in the order they usually come up.

  1. 1Does the food meet EU food law, or has the destination asked for something different? Read more
  2. 2Does the destination require a health, veterinary or phytosanitary certificate, and is there a harmonised certificate in TRACES? Read more
  3. 3Is the food, or the destination, subject to an export restriction or sanction? Read more
  4. 4Does the food meet the agreement's list rule, and what proof of origin will go with it? Read more
  5. 5Who lodges the export declaration, and are the invoice and packing list ready? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

EU food law on exported food

Whether food made for export must meet the same rules as food sold in the EU.

  • Food and feed exported or re-exported from the EU for a third country's market must comply with the relevant requirements of EU food law (Article 12 of Regulation (EC) No 178/2002).
  • The exception is where the importing country's authorities ask otherwise, or its laws, regulations, standards or codes of practice set different requirements.
  • In other cases, food that cannot be placed on the EU market may be exported only if the destination's competent authorities have expressly agreed, after being fully informed why. Food injurious to health cannot be exported.
  • Where a bilateral agreement between the EU or a member state and the third country applies, exported food must meet its provisions.

How we help: Compliant Always keeps the destination's stated requirements beside your product file, so a departure from EU rules is documented with the shipment. Ask about this

Export health and phytosanitary certificates

The certificates destinations ask for, and who in the EU issues them.

  • TRACES is the Commission's online platform for sanitary and phytosanitary certification, used for EU exports of animals and certain animal products as well as imports.
  • The Commission's Export library helps officers in member states issue export certificates, covering harmonised certificates agreed with the destination and SPS requirements that go beyond the EU's. It currently covers Canada and Ukraine.
  • Harmonised certificates for Ukraine, such as for poultry products, are available in TRACES and issued by certifying officers in member states; the EU and Armenia have agreed 13 veterinary harmonised certificates.
  • Where a destination requires a phytosanitary certificate for plants or plant products, the competent authority issues it at the operator's request, if the operator is registered, has the goods under its control, and the goods meet the destination's requirements.
  • The authority may base it on inspections, sampling and testing, pest status information or a plant passport, and may not delegate its issue. Re-exported plants get a certificate for re-export.
  • Identification and health marks on products of animal origin moved from 'European Community' abbreviations to 'European Union' ones.

How we help: Compliant Always keeps each export certificate with the shipment and lot it covers, dated, and reads it against what the destination asks for. Ask about this

Export restrictions, licences and sanctions

Goods and destinations that need an export licence or cannot be exported at all.

  • Access2Markets says the export of some goods, or exports to certain destinations, may be prohibited or restricted and need a licence; check TARIC for export licences and the EU Sanctions Map for restrictions.
  • Restricted or prohibited types include some live animals, meat and plants, certain food products, dangerous chemicals, drugs and medicines, dual-use goods, waste, cultural goods and counterfeit goods.
  • Member states may exceptionally have national restrictions, which are checked with their competent authorities.
  • The export procedure includes presenting export licences, and an oral declaration is not allowed for goods subject to prohibitions or restrictions.
  • EU sanctions on Russia (Regulation (EU) No 833/2014) prohibit exports of listed goods and oblige operators to contractually prohibit the re-export of certain sanctioned goods.

How we help: Compliant Always keeps any licence with the shipments it covers and shows when it is near its end, before the next shipment is declared. Ask about this

Origin and proof of origin

Preferential origin under EU trade agreements, how it is proved, and certificates of non-preferential origin.

  • To get a lower or zero tariff under a trade agreement, goods must be wholly obtained in the EU or sufficiently worked or processed there under the product-specific 'list rules' of the agreement's origin protocol, read by HS heading.
  • The Commission's Rules of Origin Self-Assessment tool (ROSA), in Access2Markets' My Trade Assistant, helps check a product against the rules and explains which proof of origin to prepare.
  • For food, the list rules often require wholly obtained materials: for meat (HS Chapter 2), all materials of Chapters 1 and 2 must be wholly obtained; soups (ex 2104) cannot be made from non-originating prepared or preserved vegetables.
  • Proof can be a movement certificate EUR.1 or EUR-MED issued by customs, or a self-declaration by the exporter on a commercial document: a statement on origin, or an invoice or origin declaration.
  • EU exporters must be registered in REX, with their national competent authorities, to make out statements on origin under agreements including those with Canada, Japan, Vietnam, Singapore, the UK, New Zealand and Chile, and the EU-MERCOSUR Interim Agreement.
  • Without a REX number, an exporter may make out statements on origin for consignments of originating products worth up to EUR 6 000 (EUR 10 000 for trade with the OCTs).
  • Suppliers' declarations let an exporter rely on the originating status of materials bought in the EU. Exporters keep copies of proofs of origin and related records for at least three years.
  • A Binding Origin Information (BOI) decision from customs fixes the origin of goods for up to three years, but does not replace the proof of origin.
  • A certificate of non-preferential origin may be required by the destination; Access2Markets says these are usually issued by the local chamber of commerce, and in some countries by ministries or customs.

How we help: Compliant Always keeps the REX number, suppliers' declarations and each statement on origin or certificate with the shipment it covers, and shows which proofs are missing or out of date. Ask about this

EORI and the export declaration

Who may export, the registration number every declaration carries, and the two stages of the export procedure: export and exit.

  • The export procedure (Article 269 UCC) is obligatory for EU goods leaving the EU customs territory, with very few exceptions, so that export measures such as restrictions are applied.
  • An EORI number is mandatory for customs operations in the EU, export included. It is assigned by the customs authority of the member state where the operator is established, and does not expire.
  • Access2Markets says an exporter normally needs to be established in the EU, including a VAT registration; a non-EU resident needs a person established in the EU, such as a logistics provider or customs agent, to act as exporter.
  • The export declaration is lodged electronically in the Automated Export System (AES), at the customs office for the place where the exporter is established or where the goods are packed or loaded (Article 221(2) UCC-IA).
  • It gives the origin of the goods, the destination country, commodity codes, customs procedure codes and the value. Customs may release the goods, ask for documents, or check them physically.
  • The goods and the Master Reference Number (MRN) are then presented at the customs office of exit, which supervises their departure. Goods stay under customs supervision until they leave.
  • Keep invoices, transport documents and packing lists for at least three years. Exports are exempt from EU VAT if records and the customs proof of export are kept.

How we help: Compliant Always keeps the EORI, invoice, packing list, MRN and proof of exit with each shipment, dated, and shows what is missing before the goods are declared. Ask about this

Who answers for what

WhoWhat they answer forHow we help
Food business exporterFood that meets EU food law or the destination's stated rules, the export declaration, and proof of origin.The shipment's certificates, declaration and origin proofs kept together, by lot.
Producer or supplierSuppliers' declarations on origin, and the information the certifying officer relies on.Suppliers' declarations dated and shown when they lapse.
Member state competent authorityIssuing export health, veterinary and phytosanitary certificates.Each certificate kept with the lot it covers.
Customs representative or forwarderLodging the declaration and presenting the goods for export and exit.The documents behind the declaration, ready before it is lodged.

Member states

The export rules are EU law, but member states run them. The EORI number, the export declaration, origin registrations such as REX and approved exporter status, and dual-use licences go through the national authorities of the member state concerned.

Export certificates for food, animal products and plants are issued by member states' competent authorities; the Commission supplies harmonised certificates through TRACES and guidance in its Export library. Certificates of non-preferential origin are usually issued by local chambers of commerce.

Where are the goods going?

Most of what food have to meet is set where they are sold. Each guide sets out the rules on arrival, with the official source for each.

Questions businesses ask

Does food exported from the EU have to meet EU food law?
Yes, unless the importing country's authorities ask otherwise or its laws set different requirements. Food injurious to health cannot be exported, and food not allowed in the EU needs the destination's express agreement.
Who issues export health certificates for food in the EU?
Officers of member states' competent authorities. Many certificates for animal products are issued in TRACES, the Commission's platform, which also holds harmonised certificates agreed with some destinations.
How do I get a phytosanitary certificate to export fruit or vegetables from the EU?
Ask the competent authority. It issues one where the destination requires it, if you are registered, have the goods under your control and they meet the destination's requirements.
Can I export seafood or shellfish from the EU to the US?
Bivalve molluscs such as mussels, clams, oysters and scallops: from the end of February 2022, Spain and the Netherlands may export them to the US, after the Commission and the FDA recommended that the safety systems be considered equivalent.
Is there an EU export certificate for meat or poultry to Ukraine?
Yes. The EU and Ukraine have harmonised certificates, such as for poultry products, available in TRACES and issued by certifying officers in member states. The Export library also compares Ukrainian certificates for fresh beef, pork and fishery products.
What is the Commission's Export library?
An online resource from DG SANTE that helps member state officers issue export certificates. It sets out SPS requirements beyond EU rules for certain destinations, currently Canada and Ukraine.
Does EU meat qualify for preferential origin?
Under the list rule for HS Chapter 2, meat is originating only if all the materials of Chapters 1 and 2 used are wholly obtained. Check the rule in the agreement that applies.
What proof of origin do I need to export food to Japan or Canada?
A statement on origin by an exporter registered in REX. Unregistered exporters may make one out for consignments worth up to EUR 6 000.
Can food not allowed in the EU be made for export?
Only if the destination's competent authorities have expressly agreed, after being fully informed why it cannot be sold in the EU, and never where it is injurious to health.
How does Compliant Always help with exporting from the EU?
Our team reads the rules for the routes you ship. Compliant Always shows which export documents apply to your product, keeps them with the shipment beside what the destination asks for, and watches the sources for changes. It shows what the requirements say and what your documents show; you decide.

Sources

Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

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