# Ethylene oxide in Indian botanicals: what EU buyers test for in 2026

Source: https://gfclinics.pl/insights/ethylene-oxide-testing-indian-botanicals/
Updated: 2026-10-17

Ethylene oxide residues are measured as the sum of ethylene oxide and 2-chloroethanol. EU limits sit at the limit of quantification. As of October 2026, many Indian spices and botanical food-supplement ingredients still need an official certificate and lab report at the EU border.

Ethylene oxide (EtO) is a gas that has been used outside the EU to fumigate dry foods such as seeds and spices. In the EU it is not approved as an active substance in plant protection products, and its residues in food are controlled as pesticide residues. For botanicals from India, EU buyers deal with two layers: the residue limit itself and the border controls set by Implementing Regulation (EU) 2019/1793.

## Why did ethylene oxide become an issue?

On 9 September 2020, Belgium notified ethylene oxide in sesame seeds from India through the Rapid Alert System for Food and Feed (RASFF). Some batches exceeded the 0.05 mg/kg limit by more than 1,000 times. According to the Commission, the seeds and derived products had reached 24 Member States and 9 third countries. Member States withdrew and recalled the products. The Commission stated that processed and composite foods made with non-compliant sesame also could not stay on the market.

The EU then acted in steps:

- **October 2020.** Implementing Regulation (EU) 2020/1540 placed Indian sesame seeds under special import conditions, including pre-export testing and an official certificate.
- **January 2022.** Implementing Regulation (EU) 2021/2246 extended the ethylene oxide measures to several spices, calcium carbonate and food supplements containing botanicals from India.
- **2024–2026.** Regular reviews changed check frequencies and split entries by commodity. The latest change is Implementing Regulation (EU) 2026/1206, in force since 30 June 2026.

## How is the residue defined?

The legal residue definition is **the sum of ethylene oxide and 2-chloroethanol, expressed as ethylene oxide**. 2-chloroethanol is a degradation product of ethylene oxide. A laboratory report that covers only ethylene oxide is therefore incomplete. Because the result is expressed as ethylene oxide, the laboratory converts the 2-chloroethanol found into its ethylene oxide equivalent before adding the two. Ask for both individual results and the calculated sum.

Maximum residue levels (MRLs) are listed in Annex V of Regulation (EC) No 396/2005. Regulation (EU) 2015/868 set them at the lower limit of analytical determination. In practice, a residue above the limit of quantification exceeds the MRL.

| Product group | EtO MRL (mg/kg) |
|---|---|
| Oilseeds, including sesame | 0.05 |
| Tea, coffee, herbal infusions and cocoa | 0.1 |
| Spices: seeds, fruits, bark, roots and rhizomes (e.g. ginger, turmeric), buds, stigma, aril | 0.1 |
| Food additives (stated in Regulation 2019/1793) | 0.1 |

Check the exact product code in the EU Pesticides Database before you agree a specification.

## Which Indian goods face border controls in 2026?

Regulation 2019/1793 has two lists. **Annex I** sets a higher rate of identity and physical checks at the border control post. **Annex II** adds special conditions: each consignment needs an official certificate from the Indian authority and the results of sampling and analysis. The table shows the ethylene oxide entries for India after Regulation 2026/1206.

| Annex | Goods from India (ethylene oxide hazard) | Share of consignments checked |
|---|---|---|
| II | Sesame seeds | 20% |
| II | Nutmeg; mace; cardamoms | 30% each |
| II | Coriander; cumin; seeds of anise, badian, caraway or fennel, and juniper berries; ginger; saffron; turmeric; curry; fenugreek seed; thyme; bay leaves; other spices | 20% each |
| II | Sauces, mixed condiments and seasonings (CN 2103) | 20% |
| II | Food supplements containing botanicals, including raw materials for them, except guar gum (ex CN 1302, ex 2106) | 10% |
| I | Cinnamon and cinnamon-tree flowers (moved from Annex II in 2026) | 20% |
| I | Pepper (*Piper*); dried, crushed or ground fruit of *Capsicum* or *Pimenta* | 20% |
| I | Mixtures of food additives containing locust bean gum or guar gum | 20% |
| I | Calcium carbonate | 30% |

The Commission reviews these lists at least every six months. Confirm the current consolidated text before each contract.

The regulation applies to food and feed. Botanicals imported as starting materials for medicinal products follow pharmaceutical rules instead. State the intended use clearly in the import documents.

## What must accompany an Annex II consignment?

- **Official certificate** on the EU model, issued by the competent authority in India before the goods leave its control. It is valid for up to four months from issue, and no more than six months from the date of the laboratory results.
- **Results of sampling and analysis**, performed by a laboratory accredited to ISO/IEC 17025.
- **Identification code** of the consignment, shown on the certificate, the results and every bag.
- **Prior notification** by the operator through the Common Health Entry Document (CHED) in the EU's IMSOC system before the goods arrive. This step applies to Annex I goods as well.

The border control post checks the documents and carries out identity and physical checks, including sampling, at the listed rate.

## Do samples need the same paperwork?

Not always. Regulation 2019/1793 does not apply to trade samples, laboratory samples or exhibition items that are not intended for the market, up to 10 kg net for non-fresh products. Above that weight, the competent authority may still exempt such consignments from identity and physical checks. A pre-shipment analysis of the sample still shows whether the commercial lot is likely to pass.

## What do EU buyers ask suppliers for?

1. **CN code and intended use** for each product, agreed before the order.
2. **A pre-shipment report for each lot** that covers ethylene oxide and 2-chloroethanol, states the LOQ and the method, and comes from an ISO/IEC 17025-accredited laboratory.
3. **A written statement** that no ethylene oxide is used for fumigation or sterilisation, with a description of the microbial reduction step used instead.
4. **Lot traceability** from the field or collection area to the shipped batch.
5. **For Annex II goods:** draft copies of the official certificate and analysis before loading, so the codes and dates can be checked.
6. **An agreed plan for border holds**, covering who pays for sampling and what happens to a rejected lot.

Buyers also watch RASFF notifications for their products and origin. The Commission uses RASFF data and border-check results when it reviews the lists.

## How Green Future Clinics uses this

For Indian spices and botanicals, we ask suppliers for the documents in the list above before we confirm an order. We check that each analysis report covers both ethylene oxide and 2-chloroethanol and that its LOQ meets the EU limit. For Annex II goods, we compare the draft certificate with the shipping documents before loading. We report any gap to the customer in writing.

## Sources

- Commission Implementing Regulation (EU) 2019/1793, consolidated text of 30 June 2026: https://publications.europa.eu/resource/celex/02019R1793-20260630
- Commission Implementing Regulation (EU) 2026/1206 of 9 June 2026 amending Implementing Regulation (EU) 2019/1793: https://publications.europa.eu/resource/celex/32026R1206
- Commission Implementing Regulation (EU) 2020/1540 (sesamum seeds from India): https://publications.europa.eu/resource/celex/32020R1540
- Commission Implementing Regulation (EU) 2021/2246 (extension of ethylene oxide measures): https://publications.europa.eu/resource/celex/32021R2246
- Commission Regulation (EU) 2015/868 amending Annexes II, III and V to Regulation (EC) No 396/2005 (ethylene oxide MRLs): https://publications.europa.eu/resource/celex/32015R0868
- European Commission – Food and Feed Crisis Coordinators, summary record of 9 October 2020 on ethylene oxide in sesame seeds from India: https://food.ec.europa.eu/system/files/2021-01/rasff_ethylene-oxide-incident_crisis-coord_sum.pdf
- European Commission – Rapid Alert System for Food and Feed (RASFF): https://food.ec.europa.eu/food-safety/rasff_en
- European Commission – EU Pesticides Database: https://food.ec.europa.eu/plants/pesticides/eu-pesticides-database_en
- Regulation (EU) 2017/625 on official controls, consolidated text of 5 January 2025 (Article 56, CHED): https://publications.europa.eu/resource/celex/02017R0625-20250105