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European Heat Council · Position 03

Issued 2026-06-25

Under Council authority

Ingredient quality and provenance

The Council’s position on adulteration risk, pesticide residue concentration, and the country-of-origin transparency consumers can expect from EU food labels.

Part I. Findings

The Council records three conditions relevant to ingredient quality and provenance in the European food supply. Each is supported by sources cited at the foot of this Position.

Finding 1. Adulteration of herbs and spices in EU supply chains is documented and persistent.

The European Commission’s EU-wide coordinated control plan on the authenticity of culinary herbs and spices, executed by the Joint Research Centre across 21 Member States plus Switzerland and Norway, examined 1,885 samples through nearly 10,000 analyses and found measurable rates of suspected adulteration: 48 per cent for oregano, 17 per cent for pepper, 14 per cent for cumin, 11 per cent for curcuma, 11 per cent for saffron, and 6 per cent for paprika or chilli[1]. The Joint Research Centre records that herb and spice supply chains are among the most vulnerable to fraud of any food category examined[2]. In its 2025 edition, the Europol-coordinated Operation OPSON XIV reported 631 individuals referred to judicial authorities, 11,566 tonnes of food and 1.4 million litres of beverages removed from the market, with a total value of EUR 95 million[3].

Finding 2. Pesticide residue non-compliance in herbs, spices, and chillies concentrates in specific non-EU origins.

The European Food Safety Authority’s 2023 EU report on pesticide residues in food records that, among samples exceeding the maximum residue limit for ethylene oxide, the majority of non-compliances were traced to a small number of non-EU countries of origin[4]. The 2022 EFSA report documents that a single sample of paprika powder of unknown origin contained up to 43 different pesticide residues, with a high frequency of multiple residues observed in cumin seed and paprika powder as a category[5]. The European Commission’s RASFF Window portal makes the year-on-year geographic and product-category distribution of safety notifications publicly verifiable[6].

Finding 3. EU rules on country-of-origin labelling for the primary ingredient of a food are conditional and narrow.

Commission Implementing Regulation (EU) 2018/775 requires that the country of origin of the primary ingredient of a food be indicated only where the origin of the food itself is given on the label and is different from the origin of the primary ingredient[7]. The European Commission’s own interpretive Notice of January 2020 confirms that the obligation is triggered by the food’s own origin claim, not by the primary ingredient’s identity, and that where no origin is claimed for the food no obligation to disclose the primary ingredient’s origin arises[8]. The Food Safety Authority of Ireland’s published guidance to food business operators sets out the same conditional triggering, confirming that national competent authorities read the rule the same way[9]. The practical consequence is that a consumer buying a product whose principal named ingredient is, for example, chilli has no statutory guarantee that the country of origin of that chilli will appear anywhere on the label.

Part II. Position

On the basis of these Findings the Council holds that:

  1. Ingredient quality and traceable provenance are food safety and consumer rights concerns, not luxury concerns. The Council’s adulteration and contamination findings sit in the public record of EU bodies, not in marketing material.
  2. EU consumers should have access to the country of origin of the principal ingredients in their food, regardless of how the finished product is otherwise labelled. The current scope of Regulation (EU) 2018/775 leaves a transparency gap that does not serve the consumer.
  3. Producers committed to traceable, single-origin sourcing carry a structurally lower exposure to the adulteration and contamination patterns documented above. The Council holds that buyers, regulators, and the press should treat that commitment as material information about a producer, not as marketing.

Part III. Commitments

The Council will:

  1. Publish and maintain a Council standard for traceable single-origin ingredient sourcing, against which members may make verifiable claims.
  2. Submit comment in EU consultations on country-of-origin labelling, food fraud, and primary-ingredient declaration rules, advocating for narrower exceptions and broader baseline disclosure.
  3. Publish, on a regular cadence, a brief on EU food fraud findings affecting the spice, herb, and chilli supply chain, drawing on public DG SANTE, JRC, OPSON, and RASFF sources.

Revision

This Position will be reviewed annually, or sooner if Regulation (EU) 2018/775 is amended, if Regulation (EU) No 1169/2011 is materially revised, or if the JRC publishes a successor to its 2021 herbs and spices coordinated control plan.

Sources

  1. [1]European Commission, DG SANTE, Results of an EU wide coordinated control plan to establish the prevalence of fraudulent practices in the marketing of herbs and spices, JRC126785, November 2021. https://food.ec.europa.eu/system/files/2021-11/food-fraud_action_herbs-spices_report_jrc126785_0.pdf
  2. [2]Joint Research Centre, European Commission, Results of the largest investigation into the authenticity of culinary herbs and spices on the European market, 25 November 2021. https://joint-research-centre.ec.europa.eu/jrc-news-and-updates/results-largest-investigation-authenticity-culinary-herbs-and-spices-european-market-2021-11-25_en
  3. [3]Europol, Counterfeit and substandard food worth EUR 95 million seized in global operation (Operation OPSON XIV), 2025. https://www.europol.europa.eu/media-press/newsroom/news/counterfeit-and-substandard-food-worth-eur-95-million-seized-in-global-operation
  4. [4]European Food Safety Authority, The 2023 European Union report on pesticide residues in food, EFSA Journal, 2025. https://efsa.onlinelibrary.wiley.com/doi/10.2903/j.efsa.2025.9398
  5. [5]European Food Safety Authority, The 2022 European Union report on pesticide residues in food, EFSA Journal, 2024. https://efsa.onlinelibrary.wiley.com/doi/10.2903/j.efsa.2024.8753
  6. [6]European Commission, RASFF Window (public portal of the Rapid Alert System for Food and Feed). https://webgate.ec.europa.eu/rasff-window/
  7. [7]Commission Implementing Regulation (EU) 2018/775 of 28 May 2018 laying down rules for the application of Article 26(3) of Regulation (EU) No 1169/2011 on the provision of food information to consumers, as regards the rules for indicating the country of origin or place of provenance of the primary ingredient of a food. https://eur-lex.europa.eu/eli/reg_impl/2018/775/oj/eng
  8. [8]European Commission, Commission Notice on the application of provisions of Article 26(3) of Regulation (EU) No 1169/2011, 30 January 2020 (citation to be locked from Official Journal). https://food.ec.europa.eu/food-safety/labelling-and-nutrition/food-information-consumers-legislation/origin-labelling_en
  9. [9]Food Safety Authority of Ireland, Country of origin labelling — primary ingredient interpretation guidance for food business operators. https://www.fsai.ie/business-advice/labelling/labelling-country-of-origin/country-of-origin-labelling-primary-ingredient

Issued under Council authority. European Heat Council, 2026-06-25.

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