The European Union has set maximum residue levels (MRLs) for pesticides in and on food products. Products containing more pesticide residue than allowed will be withdrawn from the European market. The European Commission currently includes 647 pesticide residues with limits varying from one pesticide residue to the other and one product to the other. For substances that are not yet included in the European regulation, the default MRL of 0.01mg/Kg applies.

Some commonly tested pesticide residues in olive oil include pyrethroids, organochloro pesticides, organophosphorus pesticides, poly-chlorinated biphenyls and nitrogen-containing pesticides.

High levels of pesticide residue are not common for olive oil; however, some European importers request a detailed test for the presence of pesticide residues. In 2018, 0.6% of the tested olive oils on the European market contained pesticide residues above the allowed limits and a non-approved pesticide iprodione in virgin olive oil.

Note that buyers in several Member States, including Germany, apply MRLs that are stricter than those established in the European Unio legislation. The MRLs applied and their relative strictness very according to the buyer. Always consult your buyer to determine the specific adopted MRLs.

According to FAO, contaminants are substances that have not been intentionally added to food, but might have entered the food from the environment or during the production process (during manufacturing, handling, storage, processing or distribution). One of the most common problems faced by olive oil exporters is contamination derived from the raw material or from foreign matter. Therefore, Tips  Consult the EU pesticide database to identify relevant MRLs for your product (olives, for oil production). The database can be searched according to product or the pesticide used. A list of of approved pesticides authorized for use by the European Union can be found on EUR-Lex.  Check the latest official test report for olive oil, which is among the 12 most consumed food products that are tested every three years by the European Union control program.  Check the supermarket factsheet on pesticides from PAN Europe to know more about the standards of some supermarket chains in Europe regarding pesticide levels.  One good way to reduce the amount of pesticides involves the application of integrated pest management (IPM), an agricultural pest control strategy using complementary strategies, including growing practices and chemical management. Read more about IPM on the European Commission website. it is crucial for the exporter to know of and comply with the maximum levels allowed by European legislation. The European Commission Regulation sets maximum levels of certain contaminants in food products. The EU frequently releases updates to the regulations set on 19 December 2006. The latest update on 14 October 2020 specifies the maximum levels in the table below.

Current EU legislation does not specify and microbiological criteria for olive oil or other vegetable oils. Nevertheless, food safety authorities can withdraw imported food products from the market or prevent them from entering the EU if salmonella or other microbes are found in them. Although irradiation is one way of combating microbiological contamination at the level of raw materials, EU legislation prohibits its use for oilseeds. Contamination by foreign matter (e.g. chemicals, dust) is likely to occur in vegetable oils if food safety procedures are not carefully followed. In some cases, olive oil can become contaminated by foreign matter, thus posing a major threat in terms of food safety.

Extraction solvents can be used in the production or fractionation of vegetable and other oils. Be aware that maximum residue limits restrictions also apply to extraction solvents (e.g. 5 mg/kg for ethyl-methyl-ketone in the fractionation of oils; 1 mg/kg for hexane in the production and fractionation of oils). Olive Oil ClassificationContaminantsSource of ContaminationOilPolycyclic aromatic hydrocarbons (PAHs)Mostly related to drying process, during which combustion gases may come into contact with the raw materialBenzo(a)pyrene < 2.0μg/kgVegetable oils, not destined for refinementAflatoxinsOlives can be contaminated by molds when stored for long periods; contamination can potentially be transferred to olive oilB1 < 2.0μg/kgVegetable oilsDioxins and PCBs Dioxins and furans are released into the air from the combustion processes.Sum of dioxins (WHO-PCDD/F-TEQ) < 0,75 pg/g fatSum of dioxins and dioxin-like PCBS (WHO-PCDD/F-PCB-TEQ)<1,25 pg/g fatSum of PCB28, PCB52, PCB101, PCB138, PCB153 and PCB180 (ICES – 6) < 40 ng/g fatOilsHeavy metals (most commonly tested: iron, copper, caldmium, lead and mercury)Olives can be contaminated with metals from soil and air and from the use of pesticides or fertilizers, with the potential contamination of olive oil during its extraction from the fruits.Olive oil 3-monochloropropanediol (3-MCPD), 3-MCPD fatty acid esters and glycidyl fatty acid esters3-MCPD and its esters can be formed in heat-processed fat-containing foods from glycerol or acyl glycerides, in the presence of chloride ions. Glycidyl fatty acid esters (GEs) are processing induced contaminants primarily found in refined fats and oils, and foods containing fats and oils.(composed of refined olive oil and virgin olive oil): contaminant level < 1250μg/kgVegetable oilsInherent plant toxins (Erucic acid)A natural occuring plant toxin (not significantly high in olive oils)20.0 g/kg+E11G9:I14Maximum Levelsum of benzo(a)pyrene,benz(a)anthracene, benzo(b)fluoranthene and chrysene < 10.0μg/kgSum of B1, B2, G1 and G2 < 4.0 μg/kg0.10 mg/kg wet weightPomace olive oil: contaminant level < 2500 μg/kg Extraction solvent limits (e.g. the use of acetone is prohibited in the refining of olive-pomace oil) apply in addition to the requirements described in Commission Regulation (EEC) No 2568/91, specifically for olive oil.

Olive oil packaging volume and material varies according to the destination. Bulk packaging includes various sizes and containers, such as steel drums, reusable (intermediate) bulk plastic containers, flexi tanks and truck cisterns. Bulk packaging can vary in size and range from 200 kg (drums) to over 20 tonnes (flexi tanks). For the food service sector, most pack sizes vary between 5 kg and 25 kg and very often tin cans are used. For specialized olive oil stores and the food service sector, olive oil is also packed into special dispensers between 5 L and 15 L, or in bag-in-box packaging.

For retail sales of olive oil, the maximum container capacity should not exceed 5 liters, according to the European olive oil marketing regulation. Such packaging shall be fitted with an opening system that can no longer be sealed after the first time it is opened. Packaging can be larger if the oil is sold to food service (restaurants, hotels) or public segments (hospitals, governments). The most preferred packaging is a dark-colored glass bottle that protects the oil from light. Transparent bottles do not protect the oil from light, which induces oxidation reactions.

Glass is the preferred type of retail packaging, mostly due to consumer preferences and image of quality olive oil. Still, olive oil is packed in many other materials for retail sales, including plastic bottles (such as PET and PVC), aluminum cans, tinplate cans and coated paperboard. Even ceramics is used for some premium olive oils.

Another packaging requirement is that the content in the packaging corresponds to the indicated quantity (in weight or volume) on the label. Importers check the packaging size and weight to ensure that pre-packed products are within the limits of tolerable errors. Most common sizes of retail olive oil bottles in Europe are between 0.5 and 1 liter. Premium olive oils are mostly packed in sizes of 0.5 L and 0.75 L. Sometimes it is packed into smaller bottles of 100 ml, 250 ml, and even 20 ml single-use bottles for restaurants and catering.

According to the EU olive oil marketing regulation, extra virgin olive oil (EVOO) can only be sold in single-use sealable containers for retail sale; refilled dispensers should only be used for flavor-infused olive oil.

Food Contact Materials

Specific health control provisions apply to consumer packaging materials that come into contact with food (e.g. bottles, containers). For example, food contact materials made from recycled or other plastic and ceramic must be manufactured in a manner that prevents them from transferring constituents to food in quantities that could endanger human health, change the composition of the food in an unacceptable way or cause deterioration in the flavor and odor of foodstuffs. Commonly restricted substances include vinyl chloride monomer N-nitrosamines, N-nitrosatable BADGE, NOGE, BFDGE and heavy metals.

European olive oil marketing standards regulate the information that must be placed on the label and what optional information can be included. According to these regulations, virgin olive oils must be labelled with a ‘designation of origin’. However, it is enough to state that the oil is produced within or outside the European Union, or as blend of different origins.

European food labelling legislation requests nutritional information. The minimum font size for the mandatory information is 1.2 mm. European health claims regulations prohibit claims that any food can cure illnesses. Currently allowed health claims labelling for olive oil include only polyphenols, oleic acid, vitamin E and monounsaturated and polyunsaturated fatty acids. Beneficial effects of polyphenols can only be used on the label for olive oil that contains at least 5 mg of hydroxytyrosol and derivates per 20 g of olive oil. EU approval requires nutrition or health claims to be based on scientific evidence and to have advance approval from the European Food Safety Agency (EFSA).

Allergens

Pre-packed products (e.g. olive oil in consumer packaging) that contain allergens must be labelled in such a way that the presence of allergens is clearly visible to consumers. Under Regulation (EU) No 1169/2011, allergens must be highlighted in the list of ingredients. Requirements concerning allergen information also apply to foods that are not pre-packed, including those sold in restaurants and cafés. Although olive oil allergies are quite uncommon, undisclosed and illegal fillers (e.g. those containing nut oils) could be fatal to some consumers.

EU olive oil legislation defines the different categories of olive oils and olive pomace oils, as well as the relevant methods of analyses to be used by Member States’ control authorities. European legislation is in line with standards of the International Olive Council (IOC) .

Sales of fake or falsely declared olive oil in Europe is prevented through regular controls. Each European country must perform certain number of controls to ensure that marketing standards for olive oils are respected.

Authenticity tests on olive oil are performed to avoid fraud. Common frauds include adding cheaper vegetable oil, false quality grading, false organic certification and false geographical origin. Authenticity tests include detecting the amount of wax (revealing the presence of pomace oil), 2-glyceril-monopalmitate (the presence of re-esterified oils), stigmastadienes (the addition of refined oil), ECN42 (the addition of seed oil) and fatty acid composition (to find out if olive oil is a blend). There are also several other tests for authenticity.

Buyers and EU customs authorities may reject products with undeclared, unauthorized (e.g. mineral oil, Sudan 4 color) or high contents of extraneous materials. Specific EU legislation applies to additives and enzymes (e.g. colors, thickeners) and to flavorings . The substances that are allowed for use in food products are listed as E-numbers, which indicate approval by the EU. To obtain an E-number, an additive must have been fully evaluated for safety by the competent food safety authorities in the EU (EFSA). The use of extraneous materials is generally not allowed for olive oil, and caution is advised when using flavorings (e.g. truffle), as they are subject to this specific legislation.

Some buyers may have special quality preferences for olive oils in terms of intensity and olive ripeness. All olive oils can be classified as intense (robust), medium and light (delicate). Intensity is defined by fruitiness, bitterness and pungency. Depending on the harvest time, olive oil can be produced from unripe olives (green), from ripe olives and from a combination of both. Other preferences include infused, organic, monovarietal and olive oils from specific regions.

Some buyers specialize in premium olive oils. Although there is no official European categorization of premium olive oil, it is commonly understood as olive oil that has an extremely low acidity level, if possible, less than 0.3 g per 100 g. Premium olive oils are also promoted with remarkably high positive sensory attributes. The most common marketing method for premium olive oil is through international olive oil competitions. When olive oil wins competition awards, it is then commonly promoted as ‘premium’, ‘high-end’ or ‘superior quality’.

Food hygiene (based on HACCP methodology) is a legislative requirement for producers and exporters of olive oil entering European market.

Although food safety certification is not obligatory under European legislation, it has become a must for almost all European food importers. Most established European importers will not work with you if you cannot provide some type of comprehensive food safety certification. Compliance with such Tips  The International Olive Council has specific standards and guidelines for quality control within the olive oil industry, covering various stages of production in mills, refineries, packing plants and olive-pomace extraction plants.  For an overview of E-numbers, refer to the Annex to Regulation 1333/s2008 (see under Consolidated versions). Additional information is available in the CBI Buyer Requirements for the sector including natural colors, flavors and thickeners. additional standards can allow olive oil exporters to enter specific market segments or gain competitive advantages relative to their competitors. Certifications concerning general quality and food safety management systems from recognized and trustworthy sources demonstrate the supplier’s commitment to high and consistent quality and safety. This is highly relevant to the production and handling of olive oil, especially for olive oil in consumer packaging. As a general rule, quality management requirements become stricter at higher levels of processing and packaging.

Most European buyers, especially large retailers and private label manufacturers, will ask for Global Food Safety Initiative (GFSI) recognized certification. For olive oil, the most popular certification programs recognized by GFSI are:

• International Featured Standards (IFS): This standard corresponds to ISO 9001, but with a focus on food safety, HACCP, hygiene, the manufacturing process and business surroundings. The IFS is a quality and safety standard published by the union of German supermarket chains, HDE (Hauptverband des Deutschen Einzelhandels).
• British Retail Consortium Global Standards (BRCGS): This private institution promotes private (BRC) standards, which contain rules on Good Manufacturing Practices (GMP) that extend beyond the HACCP plan (e.g. regarding organization and communication).
• ISO 22000: This standard combines the HACCP plan with prerequisite programs (PRPs) . It specifies requirements for a food safety management system along the food chain, up to the point of final consumption.
• Food Safety System Certification (FSSC 22000): This standard is based on the existing international standards ISO 22000 and ISO/TS 22002-1.

This list is not exhaustive and food certification systems are constantly developing.

Although the various food safety certification systems are based on similar principles, some buyers prefer one specific standard over the other. For example, IFS is often required by German retailers. Food safety certification is only a basis to start exporting to Europe. Serious buyers will usually visit or audit your production facilities before buying.

To market olive oil as organic in Europe, the olives must be grown according to organic production methods under European legislation. Growing and processing facilities must be audited by an accredited certifier before exporters can put the European Union’s organic logo on the bottle, as well as the logo of the standard holder, for example, Naturland in Germany. A specific niche opportunity to sell organic olive oils at higher prices is to follow Demeter’s rules of biodynamic certification.

Importing organic products to Europe is only possible with an electronic certificate of inspection (e-COI). Each batch of organic products imported into the European Union has to be accompanied by an electronic certificate of inspection as defined in the regulation covering imports of organic products from third countries . This electronic certificate of inspection has to be generated via the Trade Control and Expert System (TRACES).

Sustainability is a broad term with many aspects, and there is still no recognized sustainability certification covering all aspects. One increasingly used aspect is to publish CO2 emission rates on products, but it is difficult to have reliable measurements for those claims. In olive oil production, sustainability is mostly promoted through waste reduction and by using production waste as biomass. Currently, the most famous certification schemes focus on environmental impact and ethical aspects.

Several sustainability private certifications, standards, audits and initiatives are already well known. Some focus on social and ethical impacts, such as FairTrade, SMETA, Ethical Trading Initiative, amfori BSCI, BCorp or Fair for Life . Some focus on a wider range of environmental issues such as Rainforest Alliance or ISO 14000, while some only deal with CO2 emission such as MyClimate or Carbon Footprint Certification.

There are also certification schemes that use a wide range of aspects, often based on ISO 26000 Guidance . One relatively new certification scheme supporting several sustainability aspects is Planet Proof . Planet Proof includes several themes such as energy and climate, crop protection, biodiversity and landscape, soil fertility, clean water, packaging and waste.

German buyers may expect you to comply with supplier codes of conduct regarding social responsibility, which are often based on the ILO labor standards . Some companies require adherence to their code of conduct or one or more of the common standards, such as the Supplier Ethical Data Exchange (SEDEX) , Ethical Trading Initiative (ETI), and Business Social Compliance Initiative code of conduct (BSCI) . If the olive oil is meant for the retail segment, suppliers will be asked to follow a code of conduct developed by the specific retailer. Many retailers have their own codes of conduct (such as Lidl and Rewe ).

Corporate responsibility initiatives also affect you as a supplier. Common requirements include signing a code of conduct for suppliers, in which you declare that you conduct your business in a responsible manner. More specifically, you declare that you (and your suppliers) observe such measures as respecting local environmental and labor laws and avoiding corruption. These

Islamic dietary laws (Halal) propose specific restrictions in diets. If you want to focus on the Islamic ethnic niche markets, consider implementing Halal certification schemes.