Increased official controls are the EU import regime set by Implementing Regulation (EU) 2019/1793. It lists food of non-animal origin by CN code and by country of origin. The annex then fixes how often border control posts must sample and test consignments.
Key takeaways
- Scope follows the CN code and the bracketed wording of the entry, so check both against the exact form you buy.
- An Annex I listing raises your check rate. An Annex II listing changes the documents you collect before the vessel sails.
- Article 9 puts the consignment identification code on every bag, which makes it a printing decision at the origin.
- The Commission reviews both lists at most every six months, and 2026 brought two revisions.
- In 2024 EFSA recorded 5.5 % of samples above EU limits under increased import controls, against 3.3 % in national programmes.
Increased official controls attach to a CN code and a country
Implementing Regulation (EU) 2019/1793 works from two columns. One holds a CN code. The other holds a country of origin. If your consignment matches both, the regime applies. If either misses, it does not.
Read the bracketed text after the product name as well, because it fixes the physical form. Pitahaya from Vietnam sits in Annex II under CN code ex 0810 90 20 10. Its scope note covers fresh or chilled food only. Oranges from Egypt sit in Annex I under CN 0805 10, where the note covers fresh or dried food. Sweet peppers from Türkiye sit in Annex I under CN 0709 60 10 and 0710 80 51, and their note covers fresh, chilled or frozen food.
That wording decides your case. A freeze-dried dragon fruit slice leaves heading 0810 and moves to a prepared-fruit code, so the Vietnamese entry does not reach it. Dried figs from Türkiye work the other way. Their entry runs across 0804 20 90 and a set of 2008 codes for prepared forms.
So the first task looks dull, and it decides everything that follows. Take the CN code on the last customs entry. Then set it against the entry text, line by line, before you sign anything.
Annex I and Annex II split the file into two levels
Article 5 puts Annex I goods under a raised rate of identity and physical checks. Article 6 sets that rate per entry. Nothing else changes. You still lodge a Common Health Entry Document, and customs release the goods once it is finalised under Article 4.
Article 7 opens the second level. Annex II goods carry special entry conditions on top of the higher rate. The table below sets the two levels side by side.
| Duty | Annex I | Annex II |
|---|---|---|
| Raised check rate | yes | yes |
| CHED before arrival | yes | yes |
| Official certificate | no | yes, Article 11 |
| Analysis results from origin | no | yes, Article 10 |
| Code on each bag | no | yes, Article 9 |
The gap between the two columns is where most delays start. A buyer treats an Annex II source like an Annex I source. Then the certificate never leaves the origin, and the container waits.
Article 10 sets what the origin laboratory has to prove
Each Annex II consignment travels with sampling and analysis results from the competent authority of the third country. The authority of the country of dispatch may issue them when that country differs from the origin.
Article 10(2) then tells the border staff what to read in those results. A mycotoxin listing points them to the maximum levels for the relevant mycotoxins. Where the listing rests on pesticides, they check compliance with Regulation (EC) No 396/2005. Salmonella listings need absence in 25 g. The Commission page on aflatoxins links the same instruments together. The import regime and the contaminant limits are separate acts that meet at the border.
Ask for the scope of accreditation with the first sample, well before the first container. A report that covers the wrong analyte pack is worthless at the post, even when the numbers look clean.
Check the sampling plan in the same review. Article 3 requires competent authorities to use defined sampling and analysis methods for mycotoxins, pesticides and microbiological hazards. Therefore a report built on a lighter plan can be rejected on method alone. Regulation (EU) 2017/625 also allows the checks to run at an inland control point under set conditions, so your forwarder has to book that transfer in advance.
The official certificate has two expiry rules at once
Article 11 gives the model in Annex IV and four hard rules. The certificate comes from the competent authority of the third country. It carries the consignment identification code from Article 9(1). It is issued before the goods leave that authority’s control. Two expiry rules then run side by side.
The first allows four months from the date of issue. The second allows six months from the date of the laboratory results in Article 10(1). Whichever date falls first ends the document.
Six months sounds generous until you set it against a real season. Harvest, dry, hold in the origin warehouse, book a vessel, sail, then wait for a slot at the post. A slow shipment consumes the six-month period while the four-month one still looks safe. So put both dates in your purchase order, and treat the analysis date as the start of the validity period.
One identification code has to reach every single bag
Article 9 gives each Annex II consignment an identification code, and each bag or packaging form must carry it. A pallet label is not enough. The code also has to appear on the certificate under Article 11(2)(b) and in the CHED.
This is a printing decision at the origin, so it belongs in the packing specification. An email after loading arrives far too late. Agree the placement, the format and the print method with the supplier before the first commercial run.
Increased official controls change at every six-month review
Article 12 requires the Commission to review both annexes on a regular basis not exceeding six months. New RASFF data, new border results and new audit findings all feed that review. As a result, the list you checked in March may not be the list that applies in October.
Two acts moved the lists in 2026. Regulation (EU) 2026/194 of 28 January 2026 amended the annexes. Regulation (EU) 2026/1206 of 9 June 2026 amended them again. Both enter into force on the twentieth day after publication, which leaves a short window between the change and the first affected vessel.
Put the check in a calendar. Two dates a year, one owner, one line in the raw material file.
The June 2026 revision added six entries and eased three
Regulation 2026/1206 shows how the review reads evidence in both directions. Groundnuts from Argentina entered on aflatoxin risk after RASFF notifications. Aubergines from Burkina Faso, sugar apple from Egypt, cumin seeds from India and yardlong beans from Sri Lanka entered on pesticide residues. Tahini and halva from Syria entered on Salmonella.
The same act cut duties in three places. Peppers from India left the aflatoxin listing, since the controls showed “an overall satisfactory degree of compliance”. Cinnamon from India moved to a lower frequency after evidence of improvement. Xanthan gum from China moved below its 20 % rate, and nutmeg from Indonesia moved below 50 %.
Read those recitals when you plan a new origin. They say what evidence the Commission accepts. A supplier that wants a rate cut has to produce the same evidence across two or three review cycles.
Increased official controls raise your detention odds measurably
The EFSA figures published on 5 May 2026 cover 2024 and separate the streams. Under increased import controls, member states analysed 39,433 samples. Of those, 5.5 % exceeded EU limits and 3.6 % counted as non-compliant after accounting for measurement uncertainty. National control programmes ran 86,449 samples, where 3.3 % exceeded limits and 1.8 % were non-compliant.
The listed streams therefore show roughly twice the non-compliance rate of the national programmes, which is what a targeted list is designed to do. For a buyer the number is a planning input. On an Annex II origin at 30 %, roughly one container in three gets sampled. So the tail risk of a detention sits well above the rate for unlisted origins.
National rules can add a further layer. In January 2026 France announced a decree banning imports that contain pesticides prohibited in the EU. The named substances are mancozeb, glufosinate, thiophanate-methyl and carbendazim. FoodNavigator reported that “enhanced checks” will follow on arriving produce. A file that clears one member state can still meet a stricter national screen in another.
What to put in the specification and the supply contract
Start with the CN code and the origin. Write both into the raw material specification as data fields. Add the annex status, the current frequency and the date you last verified it. Our freeze-dried dragon fruit specification is the kind of document where those fields belong.
Four clauses to add to the purchase contract
Then add four contractual clauses. First, the supplier notifies you within five working days when its commodity or origin enters either annex. Second, for Annex II goods the certificate and the analysis report reach you before the vessel sails. Third, the analysis date sits no earlier than an agreed number of days before shipment, which protects the six-month limit. Fourth, the identification code is printed to your packing specification.
Add a detention procedure while you are there. Name the person who answers the post, the laboratory that runs a counter-analysis, and the deadline for a decision on re-dispatch or destruction. Because storage at the border runs on demurrage, a decision taken in three days costs far less than the same decision taken in three weeks.
Keep the evidence trail with the rest of your supplier certification and audit documentation. An auditor who sees CN codes, annex status and review dates in one file stops asking. The same file answers customers who ship onward into the UK market, where the assimilated regime has begun to diverge from the EU lists.
TRACES handles the operational side. The Commission platform has issued the CHED for goods entering the Union since 14 December 2019. Regulation (EU) 2017/625 then makes that document the vehicle for prior notification under Article 56. Article 57 turns the same document into the customs decision. The official controls pages and the import control Q&As hold the current procedural detail. A guide to the EU monitoring programme explains how sampling volumes are set across member states.
We confirm certificates, annex status and lead times for a specific batch, once the documentation scope is agreed at the specification stage.
Frequently asked questions
It depends on the CN code and the wording of the entry. An entry limited to fresh or chilled goods does not reach a freeze-dried powder. An entry that lists 2008 codes can.
Article 5 puts Annex I goods under a raised rate of identity and physical checks. Article 7 adds special entry conditions for Annex II goods, so the paperwork you collect before shipment changes.
Four months run from the date of issue. Article 11 also caps validity at six months from the date of the laboratory results.
Article 12 requires a review at most every six months. In 2026 the Commission issued Regulation 2026/194 in January and Regulation 2026/1206 in June.
The competent authority of the third country of origin, or of the country of dispatch when that differs, before the consignment leaves its control.