How to Import Nuts to Europe: Step-by-Step Guide

Importing tree nuts and dried fruits into the European Union is a well-established trade - but the regulatory requirements can be daunting for first-time importers. From phytosanitary certificates to aflatoxin testing, customs declarations to TRACES notifications, there are multiple checkpoints between your supplier's warehouse and your European customer.

This guide walks through the entire process step by step, covering the documentation, testing requirements, customs procedures, and practical timelines you need to plan for.

Overview of EU Import Requirements

Importing food into the EU requires compliance with several layers of regulation:

• General Food Law - Regulation (EC) No 178/2002 establishes the principle that food placed on the EU market must be safe and traceable.
• Official Controls Regulation - Regulation (EU) 2017/625 governs how EU authorities inspect imported food at borders.
• Contaminant limits - Regulation (EC) No 1881/2006 (now consolidated in Reg. 2023/915) sets maximum levels for aflatoxins, heavy metals, pesticide residues, and other contaminants.
• Increased import controls - Commission Implementing Regulation (EU) 2019/1793 subjects specific product-origin combinations to mandatory testing.
• Phytosanitary requirements - Regulation (EU) 2016/2031 on plant health requires phytosanitary certificates for many plant products.
• Food labelling - Regulation (EU) No 1169/2011 sets requirements for consumer-facing food labels.

The importer (the EU-based "food business operator") bears full legal responsibility for the safety and compliance of the product they place on the market.

HS Codes for Nuts and Dried Fruits

The Harmonized System (HS) is the international classification system for traded goods. The EU uses the Combined Nomenclature (CN), which extends HS codes to 8 digits. Getting the correct CN code is critical - it determines duty rates, import controls, and documentation requirements.

HS Codes for Nuts

HS Code	Product	Notes
0801.10	Desiccated coconut	Dried, shredded coconut meat
0801.21 / .22	Brazil nuts	.21 in shell, .22 shelled
0801.31 / .32	Cashew nuts	.31 in shell, .32 shelled
0802.11 / .12	Almonds	.11 in shell, .12 shelled
0802.21 / .22	Hazelnuts (filberts)	.21 in shell, .22 shelled
0802.31 / .32	Walnuts	.31 in shell, .32 shelled
0802.41 / .42	Chestnuts	.41 in shell, .42 shelled
0802.51 / .52	Pistachios	.51 in shell, .52 shelled
0802.61 / .62	Macadamia nuts	.61 in shell, .62 shelled
0802.70	Kola nuts
0802.80	Areca (betel) nuts
0802.91 / .92 / .99	Other nuts	Pine nuts, pecan nuts, etc.
1202.41 / .42	Groundnuts (peanuts)	.41 in shell, .42 shelled

HS Codes for Dried Fruits

HS Code	Product	Notes
0803.90	Dried bananas / plantains
0804.10	Dates	Fresh or dried
0804.20	Figs	Fresh or dried
0804.50	Guavas, mangoes, mangosteens	Fresh or dried
0806.20	Dried grapes (raisins, sultanas, currants)
0813.10	Dried apricots
0813.20	Dried prunes
0813.30	Dried apples
0813.40	Other dried fruits (cranberries, etc.)
2008.19	Prepared/preserved nuts	Roasted, salted, coated - different duty rates

Required Documentation

Every nut or dried fruit shipment entering the EU needs the following core documents:

Document	Issued By	Purpose
Commercial invoice	Exporter/seller	States value, terms of sale, product description. Basis for customs duty calculation.
Packing list	Exporter/seller	Details number of packages, weights (gross/net), marks and numbers.
Bill of lading (B/L) or airway bill	Shipping line / airline	Contract of carriage, receipt of goods, document of title.
Certificate of origin	Chamber of Commerce in exporting country	Proves country of origin. May be required for preferential duty rates under GSP or FTAs.
Phytosanitary certificate	National Plant Protection Organisation (NPPO) of exporting country	Confirms the consignment meets the importing country's plant health requirements. Required for most unprocessed nuts and dried fruits under Reg. (EU) 2016/2031.
Certificate of Analysis (COA)	Accredited laboratory	Reports test results for aflatoxins, pesticide residues, heavy metals, moisture, microbiological parameters.
Health certificate	Competent authority of exporting country	Required for products under increased import controls (Annex II of Reg. 2019/1793).
CHED (Common Health Entry Document)	EU importer, submitted via TRACES NT	Pre-notification to EU border authorities. Must be submitted before the consignment arrives.
Fumigation certificate	Fumigation company	If the consignment was fumigated. States chemical used, dosage, exposure time.
Insurance certificate	Insurance company	Proof of cargo insurance. Required if trading CIF/CIP.

Phytosanitary Requirements

Under Regulation (EU) 2016/2031 (the EU Plant Health Regulation), most unprocessed nuts and many dried fruits require a phytosanitary certificate issued by the National Plant Protection Organisation (NPPO) of the exporting country. This certificate confirms that the product has been inspected and found free from quarantine pests.

Key points:

• The phytosanitary certificate must be issued no more than 14 days before the date of export.
• It must reference the specific consignment (container number, marks) and be in one of the official EU languages (English is universally accepted).
• Processed products (roasted, blanched, or otherwise treated) may be exempt from phytosanitary requirements, depending on the level of processing.
• The EU may impose specific emergency measures for certain pests from certain origins - always check the latest version of the EU plant health import requirements in the EUROPHYT database.

Food Safety Testing at the EU Border

When a consignment arrives at a EU Border Control Post (BCP), it may be subject to three levels of official controls:

1. Documentary check (100% of consignments)

Every consignment is checked for the presence and validity of all required documents: CHED, phytosanitary certificate, health certificate (if required), COA, commercial documents. This is performed on all consignments.

2. Identity check (varies)

A visual inspection to verify that the product matches the documentation - checking labels, seals, container numbers, and a visual assessment of the product. Frequency varies by product category and risk level.

3. Physical check (risk-based frequency)

Sampling and laboratory testing of the product. For aflatoxins, this follows the official sampling protocol under Regulation (EC) No 401/2006. Physical check frequency depends on whether the product-origin combination is listed in Reg. 2019/1793:

• Standard products - Random physical checks, typically 1-5% of consignments.
• Annex I products (increased controls) - Physical checks at the frequency specified in the regulation (typically 10-50%).
• Annex II products (special conditions) - Mandatory documentation from origin plus EU border testing at the stated frequency (up to 50%).

The main contaminants tested for at the border include:

• Aflatoxins (B1, B2, G1, G2, total) - The most common reason for rejection.
• Pesticide residues - Maximum Residue Levels (MRLs) set by Regulation (EC) No 396/2005.
• Heavy metals - Lead, cadmium, mercury, arsenic (limits in Reg. 2023/915).
• Salmonella - Particularly relevant for ready-to-eat products.
• Ochratoxin A - Relevant for dried vine fruits (raisins), dried figs, and some spices.

Increased Import Controls (Regulation 2019/1793)

Commission Implementing Regulation (EU) 2019/1793 is updated regularly (typically every 6 months) and lists specific product-origin combinations that face increased official controls at the EU border. The regulation is based on RASFF notification data and risk assessments.

Examples of nut and dried fruit origins with increased controls:

• Groundnuts from India - Annex II, 50% physical checks (aflatoxins)
• Pistachios from Iran - Annex II, 50% physical checks (aflatoxins)
• Pistachios from Turkey - Annex II, 50% physical checks (aflatoxins)
• Dried figs from Turkey - Annex I, 20% physical checks (aflatoxins)
• Sesame seeds from India - Annex II, 50% (salmonella, pesticide residues)
• Groundnuts from Brazil - Annex I, 20% physical checks (aflatoxins)
• Dried apricots from Turkey - Annex I, 10% (sulphites)

Customs Procedure: Step by Step

1. Pre-notification via TRACES NT - The importer (or their customs agent) creates a CHED-D (Common Health Entry Document for food and feed of non-animal origin) or CHED-PP (for plant products requiring phytosanitary checks) in the EU's TRACES NT system at least 1 working day before the consignment's arrival at the BCP.
2. Arrival at BCP - The consignment arrives at a designated Border Control Post (e.g., Port of Rotterdam, Hamburg, Antwerp, Felixstowe). The BCP authority is notified through TRACES NT.
3. Documentary check - BCP officials verify all documents. If documents are incomplete or incorrect, the consignment is held until rectified.
4. Identity check - If selected, officials verify the physical product matches the documentation.
5. Physical check (if selected) - Samples are taken according to the official sampling protocol and sent to an accredited laboratory. Results typically take 2-5 working days for aflatoxins.
6. BCP decision - If the consignment passes, the CHED is finalised with a "satisfactory" result. If it fails, the importer is given options: re-dispatch (return to origin or send to a non-EU destination), destruction, or special treatment (if applicable).
7. Customs clearance - With a satisfactory CHED, the importer files a customs declaration (Single Administrative Document - SAD) via the national customs system. Import duties and VAT are calculated and paid.
8. Release for free circulation - The goods are released and can be transported to the importer's warehouse or directly to the customer.

Common Rejection Reasons

Based on RASFF data, the most common reasons for border rejection of nuts and dried fruits at EU borders include:

• Aflatoxin levels exceeding maximum limits - By far the most common, accounting for the majority of nut-related border rejections.
• Pesticide residues above MRLs - Particularly chlorpyrifos, ethylene oxide (widely banned in EU), and other organophosphates.
• Salmonella contamination - Especially in sesame seeds and ready-to-eat nut products.
• Sulphite levels - In dried apricots and other sulphured dried fruits (max 2000 mg/kg SO2 for dried apricots).
• Missing or invalid phytosanitary certificates - Certificate not original, expired, or not matching the consignment.
• Ethylene oxide residues - A significant issue since 2020, particularly in sesame seeds from India. Ethylene oxide is not approved for food sterilisation in the EU.
• Undeclared allergens - Cross-contamination with other tree nuts or peanuts.

Incoterms Commonly Used

The most common Incoterms (International Commercial Terms, ICC 2020) used in the nut and dried fruit trade:

• FOB (Free on Board) - Seller delivers the goods on board the vessel at the named port of shipment. Risk transfers to buyer once goods are on the ship. Common for buyers who have their own freight arrangements or freight forwarders. Example: "FOB Nhava Sheva" (Mumbai port).
• CIF (Cost, Insurance, Freight) - Seller pays for freight and insurance to the named destination port. Risk still transfers at shipment, but the seller arranges and pays for transport. The most commonly used term for nut imports into Europe. Example: "CIF Rotterdam".
• CFR (Cost and Freight) - Like CIF but without insurance arranged by the seller. The buyer must arrange their own cargo insurance.
• DAP (Delivered at Place) - Seller delivers to the buyer's named destination (e.g., the buyer's warehouse). Seller bears all transport costs and risks until delivery. Less common in commodity trade but used by some European distributors.

Step-by-Step Timeline: Order to Delivery

Phase	Duration	Key Activities
1. Order & contract	1-5 days	Agree on specs, price, Incoterms, payment terms. Issue purchase order / proforma invoice.
2. Production & testing	1-3 weeks	Supplier processes, grades, packs. Pre-shipment lab testing (HPLC aflatoxin, pesticides, COA).
3. Export documentation	3-7 days	Phytosanitary certificate, health certificate, fumigation cert, certificate of origin, export customs clearance.
4. Sea transit	14-35 days	Varies by origin: India 18-25 days, Vietnam 25-30 days, West Africa 14-20 days, Brazil 18-22 days to NW Europe.
5. EU border inspection	1-7 days	CHED verification, documentary check, identity check. Physical check if selected (add 2-5 days for lab results).
6. Customs clearance	1-2 days	Customs declaration, duty and VAT payment, release for free circulation.
7. Inland transport	1-3 days	Container transport from port to warehouse or direct delivery to customer.

Total typical timeline: 5-10 weeks from order to delivery in warehouse. Budget additional time for products under increased import controls, first shipments from new suppliers, or peak season port congestion.

Document Checklist

Document	Required for All Imports?	When Needed
Commercial invoice	Yes	Before customs declaration
Packing list	Yes	Before customs declaration
Bill of lading / airway bill	Yes	After shipment
Certificate of origin	Recommended (required for GSP)	Before shipment
Phytosanitary certificate	Yes (most unprocessed nuts)	At export, max 14 days before departure
Certificate of Analysis (COA)	Strongly recommended	Before shipment
Health certificate (Annex II products)	Only if listed in Reg. 2019/1793 Annex II	Before shipment
CHED-D or CHED-PP via TRACES NT	Yes	Min. 1 working day before arrival at BCP
Fumigation certificate	If fumigated	At export
Insurance certificate	If CIF/CIP terms	Before shipment
Organic certificate	Only for organic products	Before shipment, registered in TRACES