What Changed and What to Do
1. EU: an official certificate for every food-supplement consignment
Food supplements containing botanicals from India, including the raw materials intended for them (CN ex 1302 and ex 2106), sit in Annex II of Implementing Regulation (EU) 2019/1793 for pesticide residues, specifically ethylene oxide. In practice every consignment of a botanical sold for supplement use into the EU needs an official certificate from India's Export Inspection Council, based on ethylene oxide results from an approved laboratory, and 10% of consignments are checked at the EU border. India made the certificate a condition of export in DGFT Notification 22/2023.
What to do: tell your supplier at the quotation stage that the material is for food-supplement use in the EU, so the testing and certificate are planned in, not discovered at the port.
2. Senna: the EU decision window has closed
Hydroxyanthracene-containing senna preparations sit in Part C (under scrutiny) of Annex III to Regulation (EC) 1925/2006. Draft Regulation SANTE/1196/2024 Rev.3 would move them to Part A, which bans them in EU foods and supplements. The scrutiny period for the European Parliament and Council ran from 15 July to 15 October 2026. What to do: before contracting senna for an EU food product, check whether the regulation has been adopted and from what date it applies. Senna for other markets and non-food uses is unaffected.
3. CITES permits take time
Two botanicals in our range need a CITES export permit from India for every shipment: kutki (Picrorhiza kurrooa, Appendix II since 1997, with the listing covering bulk extracts) and Rhodiola rosea (Appendix II since 2023). EU buyers also need an import permit. What to do: treat the permit as part of the lead time and confirm the species on the specification.
4. Plan around the January to March harvest
The main Indian root and rhizome harvests (ashwagandha, turmeric, ginger) and the chilli and black pepper seasons fall between December and April, with seed spices following from February. Extracts are produced year-round, but raw-material availability and cost are set in these months. Our view: buyers who know their 2027 volumes can plan contracts as the new crop arrives rather than in the months before the next harvest, when the old crop runs thin. See the supply calendar.
Also worth knowing
- Mexico prohibits ashwagandha in food supplements under the Acuerdo published in the DOF on 15 December 1999. Check any Mexican project in the market access checker.
- Most of what is in this note can be checked product by product in the market access checker.
Facts as at 25 October 2026. This note is general information for B2B buyers, not legal advice; confirm the position in force before acting on it.