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Here's your Germany expansion

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Juggernaut Intelligence
Seabuckthorn fruit is not Novel Food in the EU, but a concentrated *extract* likely is unless you can prove a pre-1997 EU consumption history for that exact extraction method and ratio โ€” get this settled before shipping, since German customs and the
AI insight ยท Updated today

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  • Obtain HACCP/GMP certificate from the Indian manufacturing facility
  • Appoint an EU-established Food Business Operator (importer of record) in Germany
  • Redesign product label to meet EU FIC Regulation 1169/2011 and Food Supplements Directive 2002/46/EC

Needs attention

  • Document the exact extraction process, solvent, plant part and ratio, then obtain a written novel food status opinion from BVL (or a consultant-prepared history-of-consumption dossier)
  • Collect current FSSC 22000 / ISO 22000 / BRCGS certificate, HACCP plan and CCP records for the manufacturing site in English
  • Redesign German-language label artwork to Reg. 1169/2011 and Directive 2002/46/EC, strip all unauthorised health claims
  • Commission accredited batch testing (heavy metals, pesticide multi-residue incl. ethylene oxide, aflatoxins, microbiology) against EU limits
  • Rewrite the ICS2/ENS and invoice goods description with botanical name, plant part, processing state and extract ratio; confirm CN code with the German customs broker
  • File the German ยง54 LFGB food supplement notification with BVL once artwork is final
  • Build the traceability and technical file (specs, COAs, stability data, allergen declaration, shelf-life justification) and hand a copy to the EU FBO
  • Confirm Indian export documentation set: FSSAI licence, Certificate of Origin, phytosanitary/health certificate if requested, and DGFT export compliance
  • Model final landed cost with confirmed freight, 2106 duty rate and 7% German VAT, then lock RRP and distributor margin split
  • Appoint an EU-established Food Business Operator / importer of record for Germany and execute a written responsibility agreement