Carob Export to the European Union and Legislation
The European Union is both a large consumption market for carob and carob products and one of the regions with the most detailed food safety rules. An exporter sending carob fruit, cracks, powder, seeds or extracts to the EU; It should evaluate the contaminant and pesticide residue limits, official control system and labeling rules together.
In this article, we discuss the main topics of EU food legislation concerning carob exports, the lessons that can be learned from the ethylene oxide crisis in 2021, and the pre-export checklist with its sources. Since the legislation is updated frequently, the information here is a starting framework; the texts in force should be checked before each shipment.
Why Do Carob Products Require Special Attention in the EU Market?
Carob is not just a single product. Pods collected from the garden; It turns into different products such as broken (kibble), powder, syrup, extract and carob gum (E410) obtained from the seed. In terms of EU legislation, each of these products can be considered in a different category. For example, while dried pods and broken agricultural products are subject to pesticide residue rules, carob gum is also within the scope of additive rules as a food additive.
This diversity means the following for the exporter: It is not enough to say "I export carob". The definition of the shipped product in EU legislation, which limit table it falls into and how the end user will use it should be clarified from the beginning. The labeling obligations of carob powder that goes to a food factory as a raw material are not the same as packaged carob powder to be sold directly to the consumer.
The business that places a product on the market in the EU has to demonstrate that the product complies with the legislation, and buyers naturally pass this burden on to their suppliers. For this reason, certificate of analysis, traceability records and technical specifications have become almost standard demands in the carob trade to the EU.
Contaminants: Regulation No. 2023/915 and Basic Principles
In the EU, the basic framework for contaminants in food is drawn by the Council's Regulation No. 315/93; the maximum levels on a product basis are determined by the Commission's Regulation (EU) 2023/915. This regulation, dated 25 April 2023, was published in the Official Journal of the EU on 5 May 2023 and repealed Regulation (EU) No 1881/2006, which had been applied for many years.
The main groups of contaminants covered by the Regulation are as follows (AGRINFO, 2022):
- Mycotoxins: aflatoxins, ochratoxin A, patulin, deoxynivalenol, zearalenone, fumonisins, T-2/HT-2 toxins, citrine, rye spur
- Heavy metals: lead, cadmium, mercury, tin
- Polycyclic aromatic hydrocarbons (PAH)
- Dioxins and PCBs
- Nitrate, 3-MCPD, melamine, perchlorate
- Vegetable toxins: erucic acid, tropane alkaloids, pyrrolizidine alkaloids, hydrocyanic acid, opium alkaloids
There are several principles in this charter that should be kept in mind in terms of carob products:
1. Food exceeding the limit cannot be supplied to the market. The regulation prohibits placing on the market the foods listed in Annex I if they exceed the maximum levels established.
2. Dilution by mixing is prohibited. A batch that meets the limits cannot be made "suitable on average" by mixing it with a batch that exceeds the limits. This rule is especially important for businesses where carob collected from different gardens and traders is combined; blending a problematic batch with good batches is not the solution.
3. Limits are set at a "reasonably achievable" level. According to AGRINFO's summary, the EU sets maximum levels at a strict level that can be achieved through good agricultural and production practices; for genotoxic carcinogens, the "lowest reasonably achievable level" (ALARA) approach is applied.
4. Some product lines have specific label rules for aflatoxin. There are separate labeling provisions for products that will go to further processing, such as peanuts, other oilseeds, nuts, dried fruits, rice and corn.
Carob is not a product that stands out as a separate title with its own name in the regulation. For this reason, the exporter must check which category his product falls into in Annex I or whether it does not fall into any category through the current consolidated text. General food safety obligations continue for products outside the category; most of the buyers write their own internal limits for aflatoxin, ochratoxin A and heavy metals in the specification.
Pesticide Residues: Framework 396/2005 and the "Carobs" Code
In the EU, maximum residue limits (MRL) for pesticide residues are set within the framework of Regulation 396/2005, and the annexes to the regulation are frequently amended. Carob has its own product code in this system: "0650000 Carobs/Saint John's breads". This code is located in the product group "Tea, coffee, herbal teas, cocoa and carob", immediately after the cocoa bean. For example, Commission Regulation 2024/341 of 22 January 2024 lists this code in its tables when changing the limits of certain active ingredients.
This detail is important in practice: Since there is a separate code for carob, the limit of an active ingredient in carob may differ from the limit in fruit or vegetables. Therefore, every drug used in the garden or in the warehouse must be checked in the EU's pesticide database under the code "carobs".
The European Food Safety Authority (EFSA) also evaluates limit requests for carob. For example, in EFSA's opinion on changing the deltamethrin limit in carob, an application made to the Spanish competent authority covering post-harvest use was examined; it was stated that there was an analysis method at the determination limit of 0.01 mg/kg in carob. In the same opinion, it was stated that the long-term purchase calculation indicates a consumer risk, while the contribution of carob to this purchase is small and the decision is left to the risk manager. This example is a guide in terms of reminding that spraying during storage is also evaluated in terms of residue.
A similar harmonization process is underway on the Turkish side. TİM's Agricultural Bulletin dated January 2025 states that the amendment made to the Turkish Food Codex Regulation on Maximum Residue Limits of Pesticides on January 8, 2025, was prepared taking into account the relevant regulation of the EU. Nevertheless, what will be taken as a basis for exports to the EU are the EU limits in force in the recipient country.
The Ethylene Oxide Crisis: An Important Lesson for the Carob Gum
A recent incident that anyone sending carob products to the EU should be aware of is the presence of ethylene oxide in the carob gum (E410). Ethylene oxide is a substance that is not approved for use in food in the EU; in some third countries, it can be used for fumigation (sterilization) purposes.
According to Food Safety News, the problem started with sesame originating in India in September 2020, and in 2021 and 2022, warnings spread to additives such as carob gamut, guar gum and xanthan gum; these products also included additives originating from Turkey. According to the news of FoodNavigator on July 19, 2021, the food and feed crisis coordinators of the European Commission agreed to withdraw products containing E410 contaminated with ethylene oxide from the EU market and recall them from the consumer. The reason is that a safe level of exposure for consumers cannot be defined. It is also stated in the news that Spain's notification includes a stabilizer of Turkish origin used in ice cream produced in Spain.
The UK Food Standards Agency (FSA) also stated in its industry article dated August 5, 2021 that there are ethylene oxide levels ranging from 0.25 mg/kg to 29 mg/kg in the carob gum; It asked that products produced with dishwashing gum not be placed on the market and that those in the market be withdrawn.
This process has resulted in the EU tightening the rules. According to Food Safety News, the EU clarified in 2022 that ethylene oxide is not allowed in food additives, regardless of its source, and did not allow residue exceeding 0.1 mg/kg (the sum of ethylene oxide and 2-chloroethanol, in ethylene oxide) for the listed additives.
The lessons that can be learned from this incident for the carob industry are as follows:
- A problem with a single input can affect all the final products produced with that input; for products such as ice cream, recalls can spread to numerous countries.
- Fumigation and sterilization methods should be selected according to the legislation of the recipient country.
- Range manufacturers must not only monitor their own processes, but also all inputs, such as processing aids and packaging materials.
- Batch-by-batch traceability allows affected products to be quickly identified if a problem arises.
Official Controls and Border Inspection
Foods entering the EU can be sampled and inspected by member state authorities at border checkpoints and in the internal market. For some combinations of products and origins, "increased official control" is applied with the Implementing Regulation No. 2019/1793. A certain proportion of the products on this list are subject to identity, physical and laboratory control at the border.
According to the 2026 news of the Economy Newspaper, the Commission updates this list at least every six months; the news reports changes in the control rates of products originating from Turkey, such as tomatoes, dried figs, cumin, pistachios and chili peppers. In the same news, it is emphasized that these decisions do not mean an import ban, but subjecting more shipments to laboratory analysis weakens competitiveness. The news does not mention carob or carob gamut; nevertheless, it should be noted that the list may include new products with each update.
The EU's Rapid Alert System (RASFF) notifications are also an indicator that should be monitored in this respect. An increase in notifications in a certain product group may result in more frequent checks or additional documentation requirements in the future. The example of ethylene oxide has shown that problems in one product group can also affect the reputation of similar products from the same origin.
Labeling: Regulation No 1169/2011
Packaged carob products to be offered directly to the consumer must be labeled in accordance with EU Regulation 1169/2011 on informing consumers about food. According to the regulation, the mandatory information that must be included in pre-packaged foods is generally as follows:
| Mandatory information | The point to be considered in carob products |
|---|---|
| Name of food | It should be clear what the product is (e.g., roasted carob powder) |
| List of contents | Even in single-component products, if there is a mixture, all components should be written |
| Allergens | Cross-contamination should be evaluated for allergens processed in the same facility |
| Net quantity | With the unit suitable for the packaging type |
| History information | Expiry or recommended consumption date |
| Storage conditions | It is important due to its sensitivity to humidity and temperature |
| Name and address of the operator | Responsible operator in the EU market |
| Country of origin | When necessary; should not be misleading |
| Nutrition notification | Mandatory in products offered to consumers |
Since the formal conditions of the label, such as language and font size, are also determined in the regulation and the practice of the member country where the product will be sold, the label design should be clarified together with the buyer. For products sold to a food business as raw materials (in bulk or large packaging), the information in the technical specification, analysis certificate and shipping documents comes to the fore instead of the consumer label.
If health-related expressions are to be used in the promotion of carob products, care should also be taken. In the EU, nutrition and health claims are subject to separate rules; this is covered by a separate article.
Pre-Carob Export Checklist to the EU
Putting together the legislative headings reveals a practical list that needs to be reviewed before shipment to the EU:
- Has the definition of the product in EU legislation been determined? (agricultural product, food ingredient, additive)
- Have the pesticides used in the garden and in the warehouse been compared to the EU limits under the code "carobs"?
- Were mycotoxin and heavy metal analyses performed in an accredited laboratory?
- Has it been confirmed that no substance is used in fumigation or sterilization that is not permitted in the EU?
- Were batches from different sources combined without mixing with the over-limit product?
- Can batch number, harvest zone and processing records be traced?
- Has the current status of the 2019/1793 list and RASFF notifications been checked?
- On retail products, is the label in the language of the target country and complies with 1169/2011?
- Are the internal limits and document requests in the buyer's technical specifications met?
This list is not a substitute for legal advice; however, it helps reduce the risk of the shipment having problems at the border or at the recipient's access control.
Frequently Asked Questions
Is there a separate pesticide limit for carob in the EU?
Yes. Carob is included as a separate product in the 396/2005 system with the code "0650000 Carobs/Saint John's breads". The limit for each active ingredient must be checked under this code.
Do carob products necessarily undergo laboratory analysis at the border?
There is no such obligation for every shipment; however, member state authorities can take samples. If a product falls under the increased control list under 2019/1793, a certain amount of physical and laboratory control is applied.
Does the ethylene oxide problem only concern the carob gamut?
The problem started with sesame seeds, then spread to additives such as carob gum, guar gum and xanthan gum. Since ethylene oxide is not approved for use in food in the EU, the fumigation method should be checked for all carob products.
Should the label of the bulk raw material and the packaged product be the same?
Packaged products offered to the consumer must carry the mandatory information in 1169/2011. In the raw material sent to a food business, technical specifications, analysis certificates and shipping documents come to the fore.
Supplying Carob to the EU Market with Carob Türkiye
While the EU market has a strong demand for carob products, meeting this demand depends on reading the legislation correctly and keeping records at every link of the supply chain. Contaminant limits, pesticide residues, additive purity rules and labeling may seem like independent headings, but in the eyes of the buyer, they boil down to a single question: "Can this batch be used safely?"
At Carob Türkiye, we supply carob fruit, crumbs, flour/powder, seeds, and extracts. Our Products Our Products page; Carob kibble, Carob flour/powder and Carob seeds You can find product details on the pages. For your wholesale and export requests Contact Now You can contact us on our page.
For general information about carob products What is Carob? and What is Carob Seed? You can also take a look at our articles.
Domestic resources
Karadeniz, Y., "Europe has increased the dose of inspection of Turkish agricultural products", Ekonomi Gazetesi, 2026. economy newspaper.
com/ sector- news/ Europe- turk- AGRICULTURE- your... Turkish Exporters Assembly (TIM), "Agricultural Bulletin", January 2025. tim.
org. en/ files/ downloads/ TİM_Tarim_Bulteni/ TarimBulletin... Foreign sources
European Commission, "Commission Regulation (EU) 2023/915 on maximum levels for certain contaminants in food and repealing Regulation (EC) No 1881/2006", Official Journal of the European Union L 119, 2023. eur-
lex. europa. eu/ eli/ reg/ 2023/ 915/ oj/ eng AGRINFO (COLEAD), "EU legislation on contaminants – maximum levels explained", 2022. agrinfo.
eu/ book- of- reports/ eu- contaminants- maximum- levels... European Commission, "Commission Regulation (EU) 2024/341 amending Annexes II and V to Regulation (EC) No 396/2005 as regards maximum residue levels for diethofencarb, fenoxycarb, flutriafol and pencycuron in or on certain products", 2024. lawplayer.
com/ eu/ act/ 32024R0341 EFSA, "Modification of the existing maximum residue level for deltamethrin in carobs/Saint John's breads", EFSA Journal. efsa.
europa. eu/ el/ efsajournal/ pub/ 6271 Askew, K., "'No safe level of exposure': EC orders mass recall of products contaminated with ethylene oxide", FoodNavigator, 2021. foodnavigator.
com/ Article/ 2021/ 07/ 19/ No- safe- level- of- exp... Food Standards Agency (FSA), "Advice on ethylene oxide (ETO) in Locust Bean Gum (E410)", 2021. bfff.
co. uk/ wp- content/ uploads/ 2021/ 08/ FSA- advice- on- ETO- i… Food Safety News, "EU to tighten ethylene oxide rule for food additives", 2022. foodsafetynews.
com/ 2022/ 08/ eu- to- tighten- ethylene- oxide- r… YesWeLab, "EU Regulation No. 1169/2011 – INCO". blog.
Scientific Resourcesyeswelab. fr/ en/ agrifood/ eu- regulation- no. - 1169- 2011- …
