Black Pepper: Write the Grade, the Density and the Treatment Into the Contract

Updated: 5 Oct 2026

In June 2021 a Belgian company's own check found ethylene oxide in a lot of Indian "Black Pepper Malabar" at 11 mg/kg. The EU limit is 0.05 mg/kg, so the lot carried about 220 times the legal level. Belgium raised an EU alert, and the pepper had travelled through France on its way (RASFF Window, notification 2021.3292 (opens in a new tab)).

Nothing about that lot would have looked wrong. The grade name was on the label, and the berries were presumably the right size. What failed was a question nobody had put in writing: how was the pepper made safe to eat? Grade is about how the berry looks and how big it is. Treatment is about where it's going, because a fumigant that's routine for one market is banned in another. And neither is settled by the word "Tellicherry" on an offer sheet. This page goes through the contract clause by clause. The India decision, including the standing US import alert, sits on black pepper from India. Spices in general are on spices.

SourcingFrom Intelligence

"Tellicherry" is a size grade, not a separate pepper. Traders describe Malabar and Tellicherry as the same variety, Karimunda, sorted by berry size. So name the grade and the size in the contract, not the place. (Forum logs, EU trader and a 2025 reply)
The US refuses Indian pepper for dirt and bacteria, not chemistry. 316 refused lines from 2021 to August 2026, with filth on 283 and Salmonella on 262. (Our count of FDA import refusals)
The best whole pepper goes abroad, so a market sample can mislead. An export insider says export berries are denser than domestic ones, and that pepper from other origins is sometimes sold as Indian. (Forum logs, 2022)
The US shipper pool is narrow. Across Indian pepper and chilli shipments to the US, about 44 named exporters were active in an average month from March to August 2026. (Our count of ImportYeti pages)

What we don't know yet

The official Indian grade rules in their own words. We found only trade descriptions.
A bulk-density figure that reliably separates Indian from Vietnamese or Brazilian pepper.

Clause 1: The Grade

Indian black pepper is sold by grade names that combine origin style, cleaning and size. The trade descriptions we found put them like this (De Peperwinkel (opens in a new tab)):

MG-1 (Malabar Garbled, grade 1): 95% of berries at least 3.25 mm, and at least 550 g/l.
TGEB (Tellicherry Garbled Extra Bold): 95% of berries 4.25 mm, at least 530 g/l.
TGSEB (Tellicherry Garbled Special Extra Bold): 95% of berries 4.75 mm, at least 530 g/l.

"Garbled" means cleaned of stalks and light berries. Bigger isn't stronger. It's why an EU trader who supplies jar packers buys Tellicherry: "it looks good in a glass" (r/spices, April 2022 (opens in a new tab)). If you grind, MG-1 at a high density may be the better buy. If you sell whole in a jar, size is what your customer sees. Check these numbers against the grade rules your supplier works to, because we're quoting a trade description, not the official text.

Clause 2: Bulk Density

Bulk density, in grams per litre, is the quickest honest test of whole pepper. Light, hollow berries ("pinheads") pull it down. The export insider's point that "black pepper sold abroad as whole berries have higher density" (r/Kerala, February 2022 (opens in a new tab)) means you should test the lot you're buying, not a sample bought locally. Write a minimum g/l, a maximum for light berries, and the method.

Clause 3: Treatment, by Destination

Raw pepper carries microbes. Exporters reduce them by steam or, for some buyers, by ethylene oxide. The EU sets a very low limit for ethylene oxide residues, and the US approach differs. So the treatment is a destination clause. Write "steam sterilised, no ethylene oxide" if that's what your market needs, and ask for the record for your lot. One US food-safety manager in our logs adds a fair warning that badly done steam leaves moisture behind and shortens shelf life, so ask for moisture after treatment too.

Clause 4: Cleanliness and Microbes

This is where Indian pepper actually fails at the US border, on filth and Salmonella in our count. India's pepper to the US also runs under Import Alert 28-02, in place since 1987. Under it, India's Export Inspection Council samples and tests each US-bound lot for Salmonella, filth, mould and foreign matter and attaches a certificate to those that pass (FDA Import Alert 28-02 (opens in a new tab)). Write that certificate into the US contract. For other markets, ask for Salmonella absence in 25 g, a filth or extraneous-matter result, moisture and mould. The test plan by destination is on destination test plans.

Clause 5: Pesticides and Origin

For the EU and UK, add a multi-residue pesticide panel. Add origin documents too, because of the substitution claim above. A certificate of origin and a lot traced to a named processor protect you better than a variety name.

HS Classification

Whole pepper is 0904.11 and crushed or ground is 0904.12. The split matters in the UK. Whole black pepper is 0%, while ground carries 4%, suspended to 0% until 30 June 2027 (UK Trade Tariff (opens in a new tab)). Indian origin gets 0% either way with proof. One caution for anyone reading shipping data: 0904 also covers dried chillies, so pepper and chilli are counted together in most trade records.

Where It Comes From

Indian pepper is grown in Kerala and Karnataka, and the named US exporters in our count cluster around Kochi. More than a quarter of US-bound bills on this heading (28.4%) list Colombo as the port of loading, not an Indian port, because southern cargo is often transhipped there. Don't read "Sri Lanka" on a bill as the origin.

Back to the Belgian Lot

That Malabar lot was probably the grade it said it was. It failed on a clause nobody had written. That's the lesson. Decide what your customer sees, tastes and tests, and turn each into a clause: grade, density, treatment, cleanliness, residues and origin. Test the sample against the same clauses with our sample evaluation checklist. If you'd like the sample drawn and tested independently at the processor, SourcingSync (opens in a new tab) does that.