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Food Import Testing: What Gets Food Rejected at the Border, and How to Test Before You Ship

Updated

In April 2024 a food inspector in Hong Kong bought four spice mixes off a shop shelf in Tsim Sha Tsui, and the lab found ethylene oxide in all of them. Three were MDH products and one was Everest Fish Curry Masala, two of the best-known spice brands in India, and the regulator told the trade to stop selling them at once (Centre for Food Safety, 5 April 2024 (opens in a new tab)). These weren't fly-by-night packers. They had labs, certificates and decades of export behind them, and the lots still failed on a question nobody had asked in the right way.

That's what this guide is about. We read about 22,000 official records, every rejection, alert and refusal we could retrieve for Indian-origin goods in the EU, the US and Australia from January 2021 to September 2026, to find out what each border actually tests food for and how to answer that question before the goods leave. India is the worked example because that's where our data is deep. The method works for any origin. One honest caveat - border records show what regulators chose to check, so they're a map of hazards, not a quality score for a country or a supplier.

1. Each Border Asks a Different Question

The first thing the data told us is that "food safety" isn't one standard. Each border has its own habits, and they barely overlap.

The EU is a residue hunter. Of 1,765 RASFF notifications on Indian food, farm pesticide residues came up 584 times and ethylene oxide 334 times, ahead of aflatoxins (154) and Salmonella (125). It also rejects on paperwork far more than buyers expect, which we'll come back to in section 6 (RASFF, our count, to 22 September 2026).

The US polices hygiene and facilities. Salmonella, filth and "manufactured under insanitary conditions" dominate the refusals, and the FDA often acts on the firm rather than the lot. Australia tests its "risk foods" against its own Food Standards Code, which is how cassava chips fail there on hydrocyanic acid (56 records) and fortified cereals on vitamins the Code doesn't permit (DAFF failing food reports, our count, to July 2026).

So the same jar of chilli powder can be clean for one border and a rejection at another. Spices show it best. In the EU, pesticides drive 202 of 453 Indian spice notifications and Salmonella just 19. In the US, Salmonella is the charge on 690 of 1,320 refused spice lines. In Australia it's 77 of 88 failing spice records. A single "export quality" report can't answer all three questions, and it was never going to.

2. The US Mostly Acts on the Firm, Not the Lot

This is the point US buyers most often get wrong. You'd think the FDA opens containers and tests them. It rarely does. It sampled only 87 of the 1,320 refused Indian spice lines itself, and 83 of 1,439 refused snack lines (FDA import refusals, our count, January 2021 to August 2026). Most refusals rest on import-alert status or on a lab result the importer submitted.

An import alert names a firm. Once it's on the list, its shipments are held on arrival without anyone looking inside. On 23 September 2026 the US Salmonella alert (99-19) listed 295 Indian firms among its 1,222 (FDA import alerts, India (opens in a new tab), our count). So the check that matters most happens before you place the order - is my supplier on an alert? The how-to is on verifying Indian suppliers.

The trend is moving too. US refusals of Indian snack foods went from 15 lines in 2021 to 789 in 2025, and most of the 2025 lines carried insanitary-conditions charges rather than a lab result. For a US snack buyer that means a facility check matters as much as a lot test.

3. Start With Your Own Product's Record

Before you ask a lab anything, look at what your border has already caught. It's public and it's free. The RASFF Window (opens in a new tab) covers the EU, the FDA import refusals (opens in a new tab) and import alerts (opens in a new tab) cover the US, and the failing food reports (opens in a new tab) cover Australia. Filter by origin and product and list every hazard named in the last three years. That list is the first draft of your test panel.

Then turn each hazard into an analyte, a matrix and a limit. The limit is often printed in the rejection record itself. In the EU records, chlorpyrifos in spices was judged against 0.01 mg/kg, and the median failing lot came in at 7.5 times that (RASFF, our count). That number puts a condition on the lab. If its limit of quantification for chlorpyrifos is 0.05 mg/kg then its "not detected" can't tell you whether you pass a 0.01 limit. Ask for the quantification limit for each analyte in writing, and check it sits below your border's limit.

Build one panel per destination. A cumin lot for Rotterdam and one for New Jersey need different tests, and the per-product tables on our quality control page show how different.

4. Test Where the Hazard Gets In

Some hazards come from the field and some from the factory, and a test at the wrong point finds them too late. Back to Hong Kong for a second. Ethylene oxide isn't something a spice picks up in the soil. Part of it comes from the packer's own sterilisation, when the gas is used to kill microbes and the lot isn't degassed properly afterwards (buyer and industry voices on forums, 2021 to 2024, founder-confirmed). A pesticide test on the raw chilli would never have caught it.

So match the test to the stage -

  • Pesticide residues enter on the farm. Test the raw-material lot before processing, and for crops like rice work with growers on spray timing, because a test at the mill only detects the problem.
  • Aflatoxins and ochratoxin A grow when produce is dried or stored badly. Test the lot you'll ship, not the harvest.
  • Salmonella, filth and ethylene oxide enter or survive in the factory. Test the finished lot, and ask how each lot was sterilised.
  • Added vitamins, colours and ingredients either are or aren't permitted at your border. That's a recipe check before production, not a lab test after.

The sterilisation question is a contract term, not a chat. European buyers of Indian pepper buy steam-treated lots as standard, and a German trader told a US buyer on a forum to ask specifically whether a lot was treated with ethylene oxide (r/spices, 2022, flagged for spot-check). Write the method into the PO.

5. A Result Describes the Sample, Not the Shipment

Who draws the sample and how matters as much as the lab. Mycotoxins sit in pockets, so a single grab sample of groundnuts or chilli can pass while the lot fails. Four rules we'd hold to every time -

  1. Someone independent of the supplier draws the sample from the packed lot and seals it.
  2. The draw covers many points across the lot, not the top of one bag.
  3. A sealed counter-sample is kept, so a dispute can be retested.
  4. The lot number on the sample, the lab report and the shipping documents is the same number.

This is the step that needs a person standing in the warehouse in India. If you don't have one then SourcingSync (opens in a new tab) can arrange independent sampling and inspection at origin.

Then pick the lab for the question. A lab accredited to ISO/IEC 17025 is competent only for what's on its scope, which lists the analyte, the food and the method. A lab accredited for pesticides in fresh vegetables may not be accredited for pesticides in dried spice. In India, NABL accredits testing labs to 17025 and runs a public lab search, so you can check the scope before the sample goes (NABL (opens in a new tab)).

6. Two Borders Have Their Own Rules on Labs, and One Rejects on Paper

The US and Australia both tell you which lab counts once goods are held.

In the US, when food is tested to support its admission or to get a firm off an import alert, the test must be done by a lab accredited under FDA's LAAF programme for that method. It may only be run after the goods arrive in the US, unless FDA has agreed in writing that an earlier sample is representative (21 CFR 1.1107 (opens in a new tab)). The requirement is being switched on analyte group by analyte group, six months after FDA announces there are enough accredited labs, and for mycotoxins it has applied since 1 December 2024 (FDA, LAAF (opens in a new tab) and mycotoxin notice (opens in a new tab)). Check FDA's LAAF dashboard for your analyte. In plain words, a pre-shipment report from an Indian lab is your own quality check. It isn't the test FDA will use to release a held shipment, and 149 refused spice lines and 113 rice lines had a private lab package on file and were refused anyway (FDA import refusals, our count). The US also expects you, the importer, to run a foreign supplier verification programme for each food (21 CFR 1.502 (opens in a new tab)), and your pre-shipment tests belong in that file.

In Australia, when a food entry is referred for testing, you nominate a lab that is an appointed analyst under the inspection scheme, and the food stays on hold until it's inspected (DAFF (opens in a new tab)).

The EU surprises people differently. 299 of 1,765 Indian notifications (17%) named no contamination at all, only missing or wrong official certificates or lab reports that didn't match the lot. For supplements and botanicals it was 100 of 254 (RASFF, our count). One Indian exporter's first shipment to Germany sat at the port for four days because the phytosanitary certificate didn't match the commercial invoice (exporter on LinkedIn, 2026 (opens in a new tab)). Before loading, check every certificate and report carries the same description, lot number and quantity as the invoice.

Some certificates are entry conditions set by the other side. Black pepper from India to the US needs an Export Inspection Council certificate under Import Alert 28-02, and the EU requires official certificates with lab results for some Indian products under its increased-checks regulation (EU Implementing Regulation 2019/1793, reported, as we couldn't read EUR-Lex directly). They don't replace your own plan.

7. What a Failed Lot Really Costs

We won't put a number on it, because charges depend on the port, the product and the provider, and they change. Check current charges with your customs broker and the lab. What we can tell you is where the money goes.

There are the goods themselves. In Australia a failed food can't be released, and the options are relabelling where that fixes the fault, or supervised disposal or re-export (DAFF (opens in a new tab)). There's the wait, with storage, container detention and demurrage running while the goods sit. And there's the testing and inspection you book and pay for.

The cost buyers miss is the next shipment. In Australia a failure puts a holding order on the same product from the same producer and country, and every later consignment is inspected until five in a row pass (DAFF holding orders (opens in a new tab)). In the US an import alert holds a firm's goods until it earns its way off with consecutive LAAF tests. In the EU the notification is public. So a single failed lot is rarely a single cost, and once you add the supplier change you'd make after it, the test nearly always turns out the cheaper decision.

8. Worked Example: Basmati for Rotterdam and New Jersey

Say you're buying basmati from a mill in Punjab or Haryana, half for a Dutch importer and half for a US distributor. Here's how the method plays out.

The record comes first. In the EU, pesticides appear in 167 of 227 Indian rice notifications, and 108 of them name basmati. In the US, 416 of 428 refused rice lines are pesticide charges, peaking at 204 lines in 2024, and on 23 September 2026 the pesticide alert (99-08) listed 241 Indian firms (our counts). So the question at both borders is residues, but the limits differ.

For the EU panel, the recurring residues are tricyclazole (in 115 notifications) and thiamethoxam (in 90), both judged against 0.01 mg/kg, with failing lots at a median of 6.9 and 6.2 times that. Ochratoxin A is the newcomer, with 11 notifications in 2025 after no more than 8 a year before. Add aflatoxin B1. For the US panel, run the residues against US tolerances, which we haven't re-read for this page, so confirm them with your lab.

The residues come from the field, so the useful test is on paddy or brown rice at the mill before the lot is made up, and the real fix is a spray programme with the growers. Ochratoxin is a drying and storage problem, so it's tested on the finished lot. An inspector draws and seals samples, keeps a counter-sample and records the lot number, and a 17025 lab with pesticides in cereals on its scope and a quantification limit at or below 0.01 mg/kg runs the panel. For the US half, check the mill isn't on alert 99-08 before you sign, and know that if FDA holds the shipment, the release test happens in a LAAF lab in the US. The same lot number goes on the report, the certificate and the invoice.

9. Back to Hong Kong

What should an importer take from the MDH and Everest episode two years on? Not "avoid Indian spices". The EU data says ethylene oxide has faded fast since then (43% of Indian spice notifications in 2021, 6% in 2025), and the neonicotinoid pesticides have climbed in its place, with thiamethoxam going from 2 notifications in 2021 to 30 in 2024 (RASFF, our count). The hazard moved. A buyer who learnt "test for ethylene oxide" in 2024 and stopped there is testing for last year's problem.

The real lesson is the one serious US spice buyers already live by. They test every lot they buy, pathogens included, and set their own heavy-metal limits because the FDA sets none for spices (a US spice-company food safety manager on r/Cooking, 2024, flagged for spot-check). They don't outsource the question to the supplier's certificate, however big the brand.

So pull your border's record, test where the hazard gets in, control the sample and make the paper match. None of it is glamorous, and all of it is cheaper than a holding order. If you'd like someone on the ground in India to draw and seal your samples, SourcingSync (opens in a new tab) does exactly that.

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