Italy Food Shipping: EU Organic Certification (EC 834/2007) for Chinese Herbal Products

In recent years, Italy’s organic food market has been growing steadily, offering significant opportunities for Chinese herbal product manufacturers. However, to export herbal products to Italy, businesses must comply with the EU Organic Regulation (EC 834/2007) and address the challenges of customs clearance in Italian cities like Florence and Naples. Below is a detailed guide:

Overview of EU Organic Regulation (EC 834/2007)

Regulation (EC) No 834/2007 establishes the principles and rules for organic production within the EU, including requirements for organic agricultural production, processing, labeling, and certification. It aims to ensure the quality and safety of organic products while protecting consumer interests. Key provisions include:

• Production Rules: Organic producers must adhere to strict ecological farming principles, avoid the use of synthetic chemical pesticides and fertilizers, and prohibit the use of genetically modified organisms (GMOs). Organic livestock must be fed organic feed, and animal welfare standards must be met.
• Processing Standards: Organic processed foods must primarily use organic agricultural ingredients. Non-organic agricultural ingredients may only be used if authorized under specific conditions. Additives and processing aids must comply with EU regulations and be limited to those permitted in organic production.
• Labeling Requirements: Organic products must prominently display the EU organic logo and indicate the certification body. The label must also specify the origin of the raw materials. Since July 1, 2010, the EU logo has been mandatory for organic food products, along with raw material origin information, which must be visible alongside the logo.
• Control Systems: Compliance with the regulation is ensured through a control system based on Regulation (EC) No 882/2004. EU member states appoint authorities responsible for overseeing organic product marketing activities and conducting pre-market inspections. Authorities may delegate control tasks to accredited bodies but remain accountable for supervision.

Italy’s Organic Food Import Requirements

• Regulatory Framework: Italy follows the EU’s organic food regulations, primarily Regulation (EC) No 2092/91 and Regulation (EC) No 834/2007. Imports of organic products from non-EU countries are permitted only if they meet EU-equivalent production and certification standards.
• Import Procedures:
  • For Products from “Recognized Third Countries”: Countries such as Argentina, Australia, Canada, Chile, Costa Rica, India, Israel, Japan, South Korea, Switzerland, Tunisia, the United States, and New Zealand are recognized by the EU. Organic products from these countries may be imported into the EU under specific conditions. After January 1, 2027, a trade agreement for organic products must be in place, or products must comply with Option 2 requirements.
  • For Products from Other Third Countries: These products must be certified by an EU-recognized Control Body (CB). By December 31, 2024, during the transition from equivalence to the new compliance system, recognized equivalent CBs listed in Annex I of Regulation 2021/2325 will continue to certify products under the previous regulation’s equivalence rules. Third-country CBs must reapply to the EU for certification compliance under Regulation 2018/848. From January 1, 2025, only CBs listed in Annex I of Regulation 2021/1378, recognized for certification under Regulation 2018/848, may certify products for EU import.
• Documentation Requirements: Each batch of organic products imported into the EU must be accompanied by an electronic Certificate of Inspection (COI) generated via the TRACES (Trade Control and Expert System) platform. Exporters and importers must register in the TRACES database. Shipments must undergo official control by the third-country CB, which conducts systematic document checks and risk-based physical inspections before the shipment departs. The COI must be issued in TRACES according to the model in Annex I of Regulation (EU) 2021/2306. Since June 2022, COIs can no longer be issued on paper and must bear a qualified electronic seal. Importers or their representatives must notify the relevant competent authority responsible for verifying organic shipments via TRACES and additional email notifications. Depending on the product type, verification occurs at the Border Control Post (BCP) or the point of release for free circulation. Competent authorities perform official controls to verify compliance with Regulation 2018/848, including reviewing the COI and other supporting documents, as well as residue test results or analyses if required.
• Phytosanitary Certificate Requirements: Organic produce requiring a phytosanitary certificate must pass through Border Control Points (BCPs), which have stricter controls and a limited number of EU entry points.

Key Points for Customs Clearance in Florence and Naples

• Florence Customs Clearance:
  • Preparation of Documentation: Ensure that all required documents, such as the COI, phytosanitary certificate, commercial invoice, packing list, and certificate of origin, are complete and accurate. The commercial invoice must detail the product name, specifications, quantity, value, and applicable HS codes.
  • Advance Notification: Notify the customs broker or agent in Florence at least one working day before the shipment arrives to allow sufficient time for document review and clearance preparation.
  • Inspection and Quarantine: Expect potential inspections and quarantine checks by Italian authorities. Inspectors may verify whether the imported herbal products comply with EU organic standards and Italian regulations, including checking product quality, labels, and packaging. Products failing to meet requirements may face delays, returns, or destruction.
• Naples Customs Clearance:
  • Logistics Coordination: Naples is a major port city in southern Italy. Coordinate closely with logistics providers to ensure timely arrival of goods at the port and smooth transfer to customs clearance facilities. Monitor logistics progress to address any issues promptly.
  • Compliance with Local Regulations: In addition to EU regulations, Naples may have specific local customs requirements. Stay updated on local customs policies and rules to avoid unnecessary delays. For example, certain herbal products may require additional permits or certifications.
  • Customs Broker Selection: Partner with an experienced customs broker familiar with Naples’ customs procedures and regulations. A skilled broker can provide professional guidance, assist with document preparation, and help resolve issues during clearance, expediting the process and reducing risks.

Strategies for Chinese Herbal Product Manufacturers to Meet Italian Organic Certification Requirements

• Obtain EU Organic Certification: Choose a reputable certification body to conduct EU organic certification for herbal products. Ensure compliance with EC 834/2007 requirements throughout the production and processing stages, including the use of organic ingredients, adherence to production processes, and proper labeling.
• Establish a Quality Control System: Implement a robust quality control system to monitor the entire production process of herbal products. This ensures consistent product quality, meeting EU organic standards and Italian market requirements.
• Strengthen Supplier Management: Audit and evaluate raw material suppliers to ensure their products meet organic standards. Establish long-term partnerships with reliable suppliers to secure high-quality raw materials.
• Conduct Staff Training: Regularly train employees on EU organic regulations, certification standards, and quality control requirements to enhance their awareness and expertise. This ensures strict adherence to relevant standards during production and handling.

Differences Between Italian and EU Organic Certification Requirements

• Labeling Requirements: While the EU mandates the use of the EU organic logo on organic products, Italy may have additional labeling requirements. For instance, Italian regulations may require more detailed information about the product’s origin, production methods, and ingredients.
• Inspection Standards: EU regulations set general organic product inspection standards, but Italian authorities may adopt stricter inspection criteria and methods. Italian customs and agricultural departments may impose higher requirements on the quality and safety of imported herbal products.
• Documentation Requirements: Beyond EU-standard documentation, Italy may require supplementary documents for imported organic products, such as a detailed production process description or a certificate of origin issued by an Italian-recognized authority.

Common Issues and Solutions During Customs Clearance

• Documentation Incompleteness: Ensure all required documents are prepared and submitted accurately. Maintain clear communication with customs brokers and address any document-related issues promptly.
• Non-Compliance with Labeling Requirements: Verify that product labels meet EU and Italian labeling standards. If discrepancies arise, promptly relabel the products or provide supplementary documentation to explain the situation.
• Inspection Failures: If imported herbal products fail inspection, collaborate with Italian authorities to identify the issues and implement corrective measures. This may involve rework, additional testing, or obtaining new certifications. In severe cases, products may need to be returned or destroyed.