India’s largest markets for chilies are in South and East Asia.

There, quality parameters remain

the predominant standards. In some countries, there are some regulations related to pesticide
residues and aflatoxin; yet, minimal official enforcement and little, if any, commercial
importance are devoted to these variables. The United States is the next most important
external market for chilies. For that market, there is strong official and commercial attention to
product cleanliness, labeling for allergens, other food safety variables for this commodity.
Australia and the EU are secondary markets for Indian chilies. For the EU, there has been
increased official attention to an array of food safety issues (including pesticide residues,
aflatoxin, and heavy metals), strict attention is given to plant health matters while for Australia
the most and proper fumigation. Very modest attention is given to

Table 4. Process and system requirements for dry chilies

US South East E
A Asia Asia U
Australia
“Quality”
Compliance with physical + chemical parameters D4 D4 D4 D3 D4
Compliance with cleanliness parameters A3 D4 D4 D3 D4
ISO 9000/1 certification D1 D1 D1 D3 D1
“Food Safety”
Compliance with MRLs C2 C2 C2 B2 B3
Compliance with aflatoxin limits C2 C1 C1 B2 C2
Certified absence of additives D2 D1 D2 A4 D2
Compliance heavy metal limits D2 D1 D1 B1 D1
HACCP program requirement D1 D2 D2 D2 D2
Allergen policy C4 D1 D1 C4 D1
“Plant Health”
Fumigation requirements A4 D2 D2 D2 D4

Phytosanitary Certificate D1 D1 D1 D1
A2

Source: Author, based on exporter interviews.

Within the EU, there are apparently significant differences in the regulatory interest and
intensity of oversight for particular issues. For example, Indian exporters report that each and
every consignment of dry or ground chilies entering Spain is subjected to testing for pesticide
residues. For Germany, a sample of such consignments (perhaps one in six) is so tested. In
contrast, in the UK, most pesticide residue testing is done of products at the retail level, and
spices are not generally included in the surveillance program.

With regard to black pepper, there is a somewhat lower level of official requirements and
scrutiny, in part because agrochemicals are much less commonly used in black pepper
production and because there is no aflatoxin risk with this commodity. The United States has
been India’s largest market for black pepper since the collapse of the Soviet Union. Relatively
strict official (and private) attention is given to cleanliness parameters, proper fumigation, and
the submission of documentation of inspection by the Indian Export Inspection Agency. Strong
commercial attention is also given to compliance with microbiological parameters and
measures to prevent contamination by potential allergens. In the EU, official attention centers
on entirely

Some spice seeds are known to be allergens.

The U.S. apparently has given increased attention to the presence of heavy metals in dried
onion and garlic, in part due to past practices in China, which involved drying these spices on
coal different things (heavy metals, additives, and pesticide residues), although commercial.
Within Asia, there are again differences in the focus of regulators, yet more or less similar
concerns on the part of commercial requirements are relatively similar to those in the United
States. partners.

Table 5. Process and system requirements for whole/ground black pepper

US/Canad E Singapor Japa

a U e n
Australia
“Quality”
Compliance with
physical + chemical D4 D4 D4 D4 D4
parameters
Compliance with
cleanliness A4 D4 D4 D4 D4
parameters
ISO 9000/1
D1 D3 D2 D2 D2
certification
Export Inspection
A4 D1 D1 D1 D1
Agency Certificate
“Food Safety”
Compliance with
D2 B2 D1 C2 B3
MRLs
Compliance with
microbiological D4 D4 D4 D4 D4
limits
HACCP program
D2 D2 D2 D2 D2
requirement
Allergen Policy D4 D4 D2 D2 D2
Compliance heavy
D2 C2 C2 C2 D4
metal limits
Plant Health
Phytosanitary
D1 D1 D1 D1 A1
Certificate
Fumigation
A4 D4 D4 D4
requirements
D4

Source: Author, based on exporter interviews

Table 6 provides the summary for spice oils and oleoresins, an increasingly important part of
India’s spice trade and one in which it claims a dominant international position. The primary
legal requirement relates to proper labeling, although in the EU there is also some testing for
pesticide residues. There are very strict commercial requirements with regard to physical
properties, microbiological limits, active ingredient specifications, and cleanliness. The extent of
buyer attention to certified HACCP or ISO 9000 systems varies among regions.

Table 6. Process and system requirements for spice oils/oleoresins

US/Canad European
a Union

Japan
“Quality”

Compliance with physical + chemical parameters D4 D4

D4
ISO 9000/1 certification D1 D3 D1
“Food Safety”
Compliance with MRLs D2 B4 D3
Compliance with microbiological limits D4 D4 D4
Compliance with heavy metal limits D2 D3 D2
Compliance with active ingredient limits D4 D4 D4
Other
Labeling requirements A4 A4 A4
HACCP program requirement D2 D2 D2
Source: Author, based on exporter interviews

Legal Requirement

1. A  Legally mandated and strict enforcement

2. B  Legally mandated and spot/sample enforcement
3. C  Legally mandated yet minimal enforcement
4. D  Not legally mandated

Commercial Requirement

4 Fully required for commercial purposes

3 Mostly required for commercial purposes (relaxed at certain times)

2 Not required yet somewhat beneficial for commercial purposes

1 Not required and unnecessary for commercial purposes.