Food certification for export

Exporters routinely conflate two obligations. The first is regulatory: whatever the destination government requires before the goods clear customs. In the United States that is FDA facility registration and prior notice, with preventive controls under 21 CFR Part 117. In the European Union it is the hygiene rules of Regulation (EC) 852/2004, third-country establishment listing under Regulation (EC) 853/2004 for products of animal origin, and labelling under Regulation (EU) 1169/2011. The second is commercial: whatever the retailer or importer writes into the supply agreement, which for a large retailer is a GFSI-benchmarked scheme.

A plant can hold a flawless BRCGS certificate and still be unable to ship, because the destination requires an establishment listing it does not have. The reverse also happens: fully registered, legally able to export, and refused by the buyer for lacking a certificate no government asked for.

In the Eurasian Economic Union food is regulated by TR CU 021/2011 on food safety, which applies to every product and every process. Most food is placed on the market on an EAC declaration of conformity registered in the unified register, and Article 10 of the same regulation obliges the producer to run HACCP-based procedures. Specialised food, novel food and food for infants take state registration (SGR) from a member state's health authority instead of a declaration, and that certificate has to exist before the first consignment is placed on the market.

Two more regulations sit on almost every file. TR CU 022/2011 sets the label: Russian-language name, composition, allergens, dates and the EAC mark. TR CU 029/2012 covers additives, flavourings and processing aids, and a colourant or sweetener missing from its permitted lists blocks the declaration. Sector regulations add a layer for juices (TR CU 023/2011), fats and oils (TR CU 024/2011), milk (TR CU 033/2013), meat (TR CU 034/2013) and fish (TR EAEU 040/2016).

Hazard Analysis and Critical Control Points is a method, and it is the foundation almost every other requirement builds on. GFSI schemes assume it. The EU requires it through Article 5 of Regulation (EC) 852/2004, the EAEU through Article 10 of TR CU 021/2011, and the United States through the preventive-controls rule in 21 CFR Part 117, which is HACCP with a wider hazard list.

Where HACCP plans fail audit is rarely the hazard analysis itself. It is the monitoring records: critical limits set but never measured, corrective actions described but not evidenced, verification scheduled and not performed. An auditor reads the records first.

Halal is a separate scheme with its own audit and its own recognition rules, and the destination decides whether a certificate works, whoever issued it. It is covered in full on halal certification, including which authority accredits whom and the Indonesian deadline.

Several markets require the producing establishment to be registered before any consignment moves. China runs overseas producer registration under GACC Decree 248, in force since 1 January 2022, through the CIFER system, and an unregistered facility cannot export the listed categories at all. Brazil requires product registration or notification through ANVISA depending on category. The EU lists third-country establishments for products of animal origin on the nomination of the exporting country's competent authority, so the exporter cannot file that one directly.

These are lead-time items measured in months, and they are the most common reason a food export programme slips. They cannot be started once the goods are made, because the registration attaches to the facility and the product; a finished consignment does not speed it up.

Requirements vary sharply by product category within each market; a shelf-stable ambient product and a chilled product of animal origin are different regimes. Treat this as the shape of the problem and check the specification for your category.