Guide to evaluating fresh produce supplier safety compliance in Europe

Wikifarmer's Guide to Supplier Safety Compliance in Europe

As part of Wikifarmer's mission to empower transparent and sustainable food systems, this guide provides a comprehensive overview of how to evaluate fresh produce suppliers for food safety compliance under EU regulations. Whether you are a buyer, quality manager, or grower-exporter aiming to meet EU standards, this guide outlines best practices, regulatory requirements, and auditing strategies to help you build robust safety systems and ensure traceable, compliant produce supply chains.

EU food safety regulations & frameworks

What to look for in a compliant supplier

To ensure suppliers meet EU requirements, confirm they are aligned with the following key regulations and control systems:

1. General Food Law (Regulation EC 178/2002)

Establishes the overall food safety principles. It mandates one-step-up/one-step-down traceability for all food, so businesses must identify immediate suppliers and customers for each batch. It also requires food businesses to have procedures for product withdrawal/recall of unsafe food.

🔍 Buyers: Ask for traceability documentation and recall simulation records.

👨‍🌾 Producers: Maintain up-to-date traceability logs and test your recall plan regularly to demonstrate preparedness and compliance.

 

2. Hygiene Package (Regulations EC 852/2004 & EC 853/2004)

Key hygiene regulations include Regulation (EC) 852/2004, which sets general hygiene rules for all food businesses, and Regulation (EC) 853/2004, which adds specific rules for food of animal origin (and only partly applies to plant-based products).

Food Business Operators (FBOs) must follow Good Hygiene Practices (GHP) and set up food safety procedures based on HACCP principles, as required by Reg. 852/2004. However, this doesn't apply to primary production (like farming), where Member States are only encouraged to promote the use of HACCP.

For example, Reg. 852/2004 clearly states that food businesses must have systems in place for traceability and product recall as part of their hygiene controls.

🔍 Buyers: Request HACCP plans, hygiene protocols, and results from recent internal or third-party hygiene audits.

👨‍🌾 Producers: Implement and document hygiene protocols and HACCP plans, and schedule regular audits to validate your systems.

 

3. Microbiological Criteria for Foodstuffs (Regulation EC 2073/2005)

This rule sets limits for pathogens in ready-to-eat foods. Under this rule, Salmonella must be absent in 25 g of RTE produce, and Listeria monocytogenes must not exceed 100 CFU/g in RTE products that support its growth. These apply when produce is sold as RTE, e.g., pre-washed salads.

🔍 Buyers: Ask for microbiological testing records, especially for ready-to-eat products.

👨‍🌾 Producers: Establish a microbiological monitoring plan and partner with accredited labs to test regularly—retain records and corrective actions.

 

4. Pesticide Maximum Residue Levels (Regulation EC 396/2005)

This regulation establishes maximum residue limits (MRLs) for pesticides on/in all foods. Growers and exporters must ensure residues meet EU MRLs. Any substance not listed has a default MRL of 0.01 mg/kg. (EFSA's latest EU report shows >75,000 samples/year tested for ~600 pesticides, with ~96% of produce compliant.)

🔍 Buyers: Request recent pesticide residue test reports and inquire about sampling frequency.

👨‍🌾 Producers: Test produce regularly for pesticide residues and ensure compliance before export—record all pesticide use and lab test results.

 

5. Contaminants in Food (Regulation EU 2023/915)

(Revised from 1881/2006) Specifies maximum levels for chemical contaminants like heavy metals (lead, cadmium, mercury, arsenic) and mycotoxins in food. For instance, the EU limits cadmium in leafy vegetables and spinach to protect consumers. 

🔍 Buyers: Ask to see contaminant monitoring data and evidence of compliance, especially for leafy greens, spices, or nuts.

👨‍🌾 Producers: Implement a risk-based contaminant monitoring program and work with labs to test for heavy metals and mycotoxins in relevant crops.

 

6. Additional Considerations

Food-contact materials: Must comply with Reg EU 1935/2004 to ensure packaging and handling materials are safe.

Organic certification: If sourcing organic produce, ensure the supplier follows Reg 2018/848 and can show valid organic certification.

Plant health compliance: For imported products, phytosanitary certificates and pest control measures must meet EU requirements.

🔍 Buyers: Verify that packaging complies with food safety laws; confirm organic or phytosanitary certification is current and valid.

👨‍🌾 Producers: Source compliant packaging, renew certifications on time, and maintain documentation readily available for buyers and inspectors.

Table: Key EU Food Safety Regulations (Fresh Produce)

Regulation (EU)	Scope / Key Requirement	Example / Notes
178/2002 (Food Law)	General principles (safety, risk analysis, traceability). Mandates traceability ("one step" identification) and recall procedures.	Must identify each lot's immediate supplier/customer; enables fast withdrawal.
852/2004 (Hygiene)	General hygiene rules for all food businesses. It requires HACCP (except for some primary production) and strong PRPs (cleaning, personnel, etc.).	Farms are encouraged to apply HACCP/HACCP-like checks. Audits verify compliance.
853/2004 (Hygiene, animal)	Specific hygiene for animal products (not directly for plant produce).	May apply if the produce is handled in mixed facilities.
2073/2005 (Micro criteria)	Sets microbiological limits for RTE foods. e.g. Salmonella absent in 25g of RTE produce; Listeria monocytogenes ≤100 CFU/g in RTE produce during shelf life.	Pre-cut/washed vegetables must be tested for these pathogens.
396/2005 (Pesticides MRLs)	Harmonized pesticide MRLs in/on foods (plant & animal origin). Default 0.01 mg/kg if no MRL. Requires residue control on imports and domestic crops.	Labels and certificates often note pesticides used; testing ensures compliance.
2023/915 (Contaminants)	Sets max levels for contaminants (heavy metals, mycotoxins, PAHs, etc.) in food.	E.g., cadmium limits in leafy vegetables/nuts; chlorate limit 0.05 mg/kg in most fruit/veg.

Third-Party Certifications for Produce

Third-party schemes provide independent assurance. Important certifications for fresh produce include:

Certification	Scope/Focus	GFSI-recognized?	Notes / Comments
GLOBALG.A.P. (IFA – Fruit & Vegetables)	Farm-level Good Agricultural Practices cover food safety, traceability, worker health, and the environment.	Yes	De facto minimum for EU buyers of fresh produce. Includes modules on soil, crop management, water, records.
GRASP (GLOBALG.A.P. module)	Social risk assessment (labor conditions) for farms.	No	Voluntary add-on to GLOBALG.A.P.; addresses worker welfare (child labor, etc.). Increasingly expected by EU retailers for social compliance.
BRCGS Food Safety	Facility (packing/processing) audit; hygiene, HACCP, traceability, food defense, quality.	Yes	Widely used by EU retailers (especially UK); GFSI-benchmarked. Requires documented supplier approval program.
IFS Food	Facility audit (food manufacturing/packing); focus on food safety, quality, and legality.	Yes	Popular in continental Europe (Germany, France, Italy). Like BRCGS, includes requirements for GMP, HACCP, and supplier approval.
FSSC 22000	Food Safety Management (ISO 22000 + PRPs); applicable to any stage.	Yes	ISO-based system, recognized by GFSI. Covers farm (ISO/TS 22002-5 for farming) through processing.
PrimusGFS	Produce-specific GFSI standard (originally US-centric).	Yes	Used by many global growers/exporters. Covers farm and packinghouse operations (HACCP, GAP).

Documentation & Traceability Requirements

Have you ever been notified that a batch of fresh produce you purchased might be contaminated, and you had just 24 hours to trace its origin and pull it from shelves?

This is not a hypothetical scenario. Across Europe, food recalls linked to pesticide residues, bacterial contamination, or mislabeling happen regularly. In many cases, the problem isn't just the contamination—it's the inability to track and remove affected batches quickly, exposing businesses to serious financial, legal, and reputational risks.

EU law mandates robust traceability systems and accessible documentation throughout the supply chain to avoid such costly disruptions. Whether you're a buyer or a producer, aligning on these requirements is critical to ensuring safe, transparent trade in fresh produce.

• Traceability: EU law requires that every batch of produce be fully traceable. Records must link each product lot to its immediate supplier and subsequent customer (one step back/forward). This means keeping documents (e.g., invoices, delivery notes, waybills) with lot codes and supplier IDs for each shipment.
• Key Documents: Suppliers should maintain and provide on request: certificates (e.g. phytosanitary, organic, food safety certification), product specifications (variety, grade), lab test reports (pesticide residues, pathogen tests), HACCP plans, pesticide usage and water testing logs, cleaning and maintenance records, and details of any post-harvest treatments. Documentation must be in English (or an agreed language) and easily reviewable.
• Lot Coding: Every case/pallet should have a lot or batch code tied to the harvest or packing date. This code is used in traceability records. For example, EU regulations mandate that trade packaging show a "lot number for traceability". The label must also list the country of origin, fruit/variety name, class (quality grade), size or calibre, packer ID, and any treatments (e.g., wax, fungicide).

Figure: Example of trade packaging label on a bag of oranges, showing variety, origin (Spain), packer code, and lot number – key data for EU traceability.

Wikifarmer, traceability is a core part of our quality assurance process. We record and retain critical data for every batch we handle — from the producer and product origin to transport conditions and delivery details. 

As our quality expert often says, “Put the lot number everywhere possible." This principle ensures that we can trace products quickly and accurately across the supply chain in the event of a recall or issue.

Lot numbers should be included in documentation, labels, delivery notes, and internal systems wherever possible, allowing buyers and internal teams to verify each product's full journey.

Supplier Audits & Remote Assessments

Relying on certificates alone can lead to missed risks and missed opportunities.

A well-planned audit strategy is essential whether you’re a buyer seeking assurance or a supplier aiming to prove compliance. Combining on-site visits, remote reviews, and trusted third-party certifications helps both sides build transparency, trust, and long-term collaboration.

Audit Program

Establishing a documented supplier approval and monitoring system is often viewed as a foundational element of supply chain management, particularly under certification schemes such as BRCGS or IFS. Prior to commencing procurement, many organizations choose to conduct an initial qualification, which may involve reviewing completed supplier questionnaires, third-party certifications, and historical compliance data. Suppliers are commonly classified based on risk, with factors such as product type, past performance, and supplier history informing the risk level. This classification can then guide the frequency of audits. For instance, high-risk suppliers may be subject to annual reviews, while those considered low-risk might be assessed every two to three years.

On-Site Audits 

Where feasible, on-site audits tend to provide the most comprehensive insight into supplier operations. These audits typically include inspections of farms and packing facilities, with attention given to hygiene practices, agrochemical usage, worker welfare, structural conditions (such as water and sanitation infrastructure), and recordkeeping systems. A structured audit checklist aligned with applicable regulatory frameworks (e.g. the EU Hygiene Package) and buyer-specific requirements is often used to ensure consistency. It is also common practice to verify the implementation of a functional HACCP system and to assess whether previous corrective and preventive actions (CAPAs) have been completed effectively. Audit findings are generally documented, and suppliers may be asked to submit written CAPAs in response to non-conformities.

Remote/Virtual Audits

In cases where in-person visits are not practical, due to travel restrictions or when dealing with lower-risk suppliers, remote or virtual audits may serve as an interim measure. These typically involve reviewing documentation (such as certifications, training logs, and hygiene procedures), conducting virtual facility tours, and holding interviews with relevant personnel. While such audits can confirm key elements of compliance, they may not provide a full picture of physical conditions, particularly regarding cleanliness and equipment maintenance. A hybrid approach, combining remote assessments with periodic on-site audits when conditions permit, may offer a more balanced view of supplier performance over time.

Leveraging Third-Party Audits

Utilizing third-party certification reports is a common way to streamline supplier oversight, especially when the certifying body is recognized and trusted. For example, BRCGS- or IFS-certified facilities have typically undergone rigorous assessment and may not require a full additional audit. In these cases, buyers might opt for a targeted evaluation focusing on product-specific or buyer-specific requirements. Similarly, GLOBALG.A.P. certification is often seen as an indicator of good agricultural practices (GAP) at the farm level. While third-party audits can reduce the frequency or scope of direct audits, some buyers choose to conduct occasional spot checks or supplemental reviews to verify consistency and address any emerging risks.

At Wikifarmer, we take product quality and safety seriously. That's why we request and verify all third-party quality certifications from our suppliers — including ISO, HACCP, GlobalG.A.P., organic, and others, depending on the product type. Upon request, these certifications are shared with buyers, ensuring transparency and traceability throughout the supply chain. Our commitment to quality assurance helps buyers make informed decisions and builds trust across every transaction.

Testing Protocols: Contaminants, Pesticides, Pathogens

How confident are you in the safety of the produce you buy or export?

Testing isn't just a regulatory checkbox—it's a shared responsibility that protects consumers, builds trust, and prevents costly recalls. Whether you're a buyer validating product safety or a supplier demonstrating compliance, implementing clear, risk-based testing protocols is key to a resilient and transparent supply chain.

Pesticide Residue Testing

A risk-based pesticide residue testing plan may be advisable for incoming produce. Such a plan typically accounts for the likelihood of certain pesticide applications per crop, which can be informed by the EU Maximum Residue Limits (MRLs) and national spray recommendations. Testing is generally conducted using multi-residue methods, most often GC-MS/MS and LC-MS/MS, in laboratories accredited to ISO/IEC 17025 standards. Sampling could occur either upon arrival or at the packhouse, ideally following a statistical approach (e.g. a defined number of samples per tonnage). Any exceedance of the EU MRL or a stricter importer-specific limit would usually warrant immediate investigation. Certificates of analysis are commonly retained as evidence of compliance and due diligence.

Pathogen Testing (Microbiological)

Testing for microbiological hazards is essential for ready-to-eat (RTE) produce such as pre-washed salads and fresh-cut fruit. EU Regulation 2073/2005 specifies the absence of Salmonella in 25 g samples and allows up to 100 CFU/g of Listeria monocytogenes in RTE products. Many operators opt to test finished product batches using validated methods such as ISO 6579 for Salmonella and ISO 11290 for Listeria. Testing for generic E. coli as a hygiene indicator may also be beneficial, depending on the product type and risk profile. Environmental monitoring, particularly for Listeria on food contact surfaces and equipment, is often integrated into routine hygiene verification. Additionally, irrigation and wash water are generally tested for microbial indicators; a commonly used benchmark is <10 CFU E. coli/100 ml.

Chemical Contaminants

Certain commodities might require screening for chemical contaminants beyond pesticides. Chlorates and perchlorates, which can originate from disinfectants, are regulated in the EU with a common reference limit of approximately 0.05 mg/kg for most vegetables. Heavy metals such as lead and cadmium are covered under EU contaminants legislation and may be relevant depending on the growing region and crop type. While mycotoxins are more often associated with nuts and cereals, some dried or stored produce might also be affected. Testing for persistent unauthorized substances (e.g. legacy herbicide residues) could be considered in response to specific alerts or historical issues, though such cases are typically rare in fresh produce. Organic pollutants like dioxins and PCBs are not commonly a concern unless flagged through official notifications.

Testing Protocols

It is generally recommended that all testing activities rely on accredited laboratories using validated analytical methods. Clear sampling protocols, such as composite samples from various points in a batch, help enhance representativeness. Identity verification of samples and a well-documented chain of custody also support traceability. Any result found to be outside specification usually triggers a documented corrective action process. Maintaining comprehensive testing records may be useful for demonstrating due diligence during audits or regulatory inspections, as well as in the event of a product recall.

Wikifarmer adds an extra layer of assurance for buyers by requiring all suppliers to provide recent laboratory analysis for pesticide residues and other necessary analyses depending on the product. This gives our buyers confidence that the produce they receive meets EU regulatory thresholds and food safety standards.

Risk Assessment & Recall Readiness

What would happen if a safety issue were discovered in one of your shipments today?

Risk is a daily reality in fresh produce supply chains. Both buyers and suppliers must work together to identify potential hazards, monitor key indicators, and prepare for swift, coordinated recalls when needed. A proactive approach to risk assessment and recall planning is essential to protect consumer health and maintain trust across the value chain.

Supplier Risk Assessment

A hazard analysis for each produce supplier may help identify potential food safety risks. This typically includes biological, chemical, and physical hazards, alongside contextual supply factors such as country of origin, climate conditions, and seasonal influences. For instance, leafy greens from warmer climates may carry elevated microbiological risks, while root crops can be more prone to soil-related contaminants. HACCP principles or a structured risk matrix are commonly used to evaluate hazards based on likelihood and severity. Non-food fraud risks, such as pesticide misuse or falsified certifications, may also warrant consideration. Risk assessments are generally updated when new commodities or sourcing regions are introduced.

Ongoing Monitoring

Tracking supplier performance over time tends to support proactive risk management. This often includes monitoring non-conformances, audit results, testing outcomes, and alerts such as those issued through the EU Rapid Alert System for Food and Feed (RASFF). When indicators suggest elevated risk, it may be appropriate to increase the frequency of audits or testing. In the case of consistently high-risk suppliers, additional controls, such as batch-by-batch testing or more frequent site visits, are sometimes put in place.

Recall / Withdrawal Plan

A documented product recall and withdrawal procedure is typically required under EU law. Such a plan usually assigns roles to a designated recall team and includes a centralized list of all product codes, batches, and distribution records to enable rapid identification of affected goods. Maintaining up-to-date contact details for buyers, transporters, and competent authorities supports timely communication. Standardized templates for notifications may help streamline the response. Periodic mock recalls—such as tracing a batch code through distribution records—are often conducted to verify system effectiveness and readiness.

Regulatory Notification 

In the event of a confirmed food safety incident, rapid internal action is typically expected. Where risks extend beyond national borders, notification through the EU RASFF system may be legally required. Accurate and well-maintained documentation, including traceability data and laboratory results, can facilitate efficient incident management and help safeguard public health.

Supplier Scorecards & Performance Tracking

Use a supplier scorecard to track performance over time and drive improvements quantitatively. Key metrics can include:

• Certification & Audit Status: Presence and currency of key certificates (e.g., GLOBALG.A.P., BRC, IFS) and latest audit scores. Flag lapses or overdue audits.
• Food Safety Incidents: Number of non-conforming lots (test failures, consumer complaints, rejections) per period. % of batches passing all required tests.
• Quality & Compliance: Product defect rate (e.g., % of shipments with quality issues). Completeness/accuracy of documentation (e.g. quality of certificates and delivery papers). Number of corrective actions opened vs. closed on time.
• Logistics: On-time delivery rate and order accuracy (correct quantities/grades). These affect freshness but also reflect reliability.
• Corrective Actions: Timeliness of the supplier's response to audit findings or test failures.

Scorecards condense these KPIs into an overall rating for each supplier, enabling side-by-side comparisons. 

To maintain high standards, Wikifarmer evaluates each supplier based on a structured scorecard system. This includes product compliance, consistency of supply, responsiveness, and document quality (such as lab analyses). Suppliers who consistently meet our criteria and deliver high-quality batches are prioritized for future orders.

References

What requirements must fresh fruit or vegetables comply with to be allowed on the European market?

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52022XC0916(01)

EFSA | Pesticides

Maximum levels for certain contaminants in food