Importing food into the EU: border controls
Which food imports stop at an EU border control post, what the CHED and TRACES do, and how other food is checked under Regulation (EU) 2017/625.
Food entering the EU falls under the Official Controls Regulation, Regulation (EU) 2017/625. Products of animal origin, certain plants and plant products, and food named in specific EU lists must pass through a border control post at their first point of arrival, with documentary, identity and physical checks. The operator gives prior notice through a Common Health Entry Document, the CHED, in the Commission’s TRACES system. Customs will not release those goods until the CHED is finalised. Other food is checked on a risk basis.
The first question for any food importer is therefore which group each product falls into.
Which food imports must pass through an EU border control post?
Article 47(1) of Regulation (EU) 2017/625 lists the consignments that competent authorities control at the border control post of first arrival. In summary:
| Category | What it covers |
|---|---|
| Animals | live animals entering the Union |
| Products of animal origin | including germinal products and animal by-products |
| Plants and plant products | those named in lists under the plant health rules of Regulation (EU) 2016/2031 |
| Goods under temporary increased controls | goods from certain third countries, where the Commission has found a known or emerging risk |
| Goods under emergency measures | goods identified by their Combined Nomenclature codes in emergency acts |
| Goods with entry conditions | goods for which EU rules set conditions to be checked at entry |
For most processed foods of plant origin, the fourth row is the one to watch. Commission Implementing Regulation (EU) 2019/1793 lists food and feed of non-animal origin from certain third countries that face a temporary increase of official controls, in Annex I, and special conditions such as certificates and test results, in Annex II. The listed risks include mycotoxins, pesticide residues, dioxins and microbiological contamination.
What checks happen at the border control post?
Article 49 requires three kinds of check on the consignments listed in Article 47(1): documentary checks, identity checks and physical checks.
The regulation also sets who carries out physical checks. For meat and edible offal, for example, it is an official veterinarian, who may be assisted by trained staff. For plants and plant products, it is an official plant health officer.
What is a CHED and who completes it?
The CHED is the Common Health Entry Document. Under Article 56(1), “the operator responsible for the consignment shall complete the relevant part of the CHED” for each consignment in the Article 47(1) categories, with the information needed to identify the goods and their destination.
Article 56(3) sets its first use: prior notification to the border control post of arrival, before the goods get there. The authorities then use the same document to record the checks and their decision.
The CHED is issued in TRACES, the Commission’s online platform for health certification of imports of animals, animal products, food and feed. The Commission reports more than 113,000 users in over 90 countries, and more than 5.4 million official documents a year.
Can food be released for free circulation before border checks are finished?
No. Article 57(1) makes placing these consignments under any customs procedure subject to the presentation of the CHED to customs. That includes entry into customs warehouses and free zones. Release for free circulation depends on a finalised CHED showing the consignment complies with the applicable rules.
Two consequences follow for an importer.
- The border control post comes before the warehouse. Goods in the Article 47(1) categories are checked at their first point of arrival, not at their final destination.
- A bonded warehouse is no way around the checks. Customs warehousing also requires the CHED. Duty deferral does not defer official controls. Bonded warehouse: deferral, not exemption explains what bonded storage does change.
How is food that does not need a border control post checked?
Article 44 covers everything else. Competent authorities perform official controls “regularly, on a risk basis and with appropriate frequency” on animals and goods entering the Union to which the border control post articles do not apply.
The regulation lists what drives the frequency:
- The risks to health and safety linked to the type of product.
- Any indication that consumers may be misled about the nature, identity, composition, origin or production method.
- The compliance record of the third country, the exporter and the operator responsible for the consignment.
- The controls already performed.
- Guarantees given by the third country.
Food outside the Article 47(1) categories is therefore not unchecked. It is simply not routed through a border control post by default.
How often does the EU high-risk food list change?
Often. Article 12 of Implementing Regulation (EU) 2019/1793 requires the Commission to review Annexes I and II “on a regular basis not exceeding a period of six months.” Product and country pairs are added, removed and adjusted.
An importer does not rely on last year’s list. It checks the version in force for each product, origin and tariff code before each new flow, and again when the regulation is amended.
The regulation also sets exemptions, for example for small consignments of up to 30 kg that are trade samples or for scientific purposes, among others. Whether an exemption fits is checked case by case.
A worked example
Suppose a food brand from outside the EU plans three products for the European market, landed in Portugal. The details are hypothetical, for the mechanics only.
A hard cheese. It is a product of animal origin, so it falls under Article 47(1)(b). The brand’s customs broker lodges the CHED in TRACES before arrival. The consignment is checked at the border control post of first arrival, with the documents EU rules require for that product and origin. Customs releases it only after the CHED is finalised.
A dried spice. The brand checks Annex I and Annex II of Implementing Regulation (EU) 2019/1793 for the spice’s code and country of origin. Suppose the pair is listed in Annex II with a certificate and laboratory results. The consignment then goes to a border control post with those documents.
A tomato sauce with no animal ingredients. Suppose it appears in none of the lists. It is not presented at a border control post. It is still subject to the risk-based controls of Article 44, and to EU food labelling and composition rules on the market.
The brand writes down, per product, which group it falls into and which document proves it. That note is reviewed each time the lists change.
This is general information, not regulatory or customs advice. The border control position of a specific product is confirmed with a customs broker and the competent authority.
Where does EFC come in for food brands?
EFC’s part begins once food has cleared official controls and customs. Goods released for free circulation are received in Portugal, stored with batch and expiry data, and dispatched to buyers, as outlined on food. EFC does not arrange border control post inspections, does not complete CHEDs and gives no regulatory advice. For the customs step itself, see release for free circulation, and for how batches are tracked afterwards, see lot, batch and expiry control in an EU warehouse.
Sources
| Label | Value | Source |
|---|---|---|
| Border control post categories | animals, products of animal origin, listed plants, increased controls, emergency measures, entry conditions | Regulation (EU) 2017/625, Article 47, EU text on legislation.gov.uk, opened 2026-08-28 |
| Checks at the border control post | documentary, identity and physical checks; who performs physical checks | Regulation (EU) 2017/625, Article 49, EU text on legislation.gov.uk, opened 2026-08-28 |
| CHED | completed by the operator responsible; prior notification to the border control post | Regulation (EU) 2017/625, Article 56, EU text on legislation.gov.uk, opened 2026-08-28 |
| Customs and the CHED | CHED presented for any customs procedure, including customs warehouses and free zones; release after finalised CHED | Regulation (EU) 2017/625, Article 57, EU text on legislation.gov.uk, opened 2026-08-28 |
| Other goods | risk-based official controls and the factors that set their frequency | Regulation (EU) 2017/625, Article 44, EU text on legislation.gov.uk, opened 2026-08-28 |
| High-risk food of non-animal origin | Annex I increased controls; Annex II special conditions; exemptions including consignments up to 30 kg | Implementing Regulation (EU) 2019/1793, Article 1, EU text on legislation.gov.uk, opened 2026-08-28 |
| Review of the lists | at intervals not exceeding six months | Implementing Regulation (EU) 2019/1793, Article 12, EU text on legislation.gov.uk, opened 2026-08-28 |
| TRACES | Commission platform for health certification; more than 113,000 users in over 90 countries; more than 5.4 million documents a year | European Commission, TRACES, opened 2026-08-28 |