Testing and Documents for Herbal Tea Ingredients by Destination Market: EU, GB, NI and US

There is no universal test panel or document package for every dried herbal tea ingredient, and herbal tea ingredient testing requirements differ between the EU, Great Britain, Northern Ireland and the United States.

Legal maximum levels apply to specific commodities, contaminants and food categories. A legal limit does not by itself mean that every supplier must run a complete panel on every batch.

Buyers should define testing and documentation based on the destination market, the botanical’s legal classification, hazard risk and contract requirements.

What Is the Difference Between a Legal Limit and Batch Testing?

A legal maximum residue level (MRL) or contaminant maximum level defines a compliance outcome. Food placed on the market must not exceed the applicable limit.

That obligation does not automatically create a rule that every batch must be fully tested, every shipment must carry a COA, or every supplier must provide the same laboratory panel.

Testing frequency and scope are usually shaped by risk.

Factors can include:

• hazard analysis
• supplier history
• botanical species and plant part
• country or region of origin
• previous test failures
• importer verification
• HACCP or food-safety controls
• retailer requirements
• customer specifications
• high-risk import controls

Less testing is not automatically better.

The point is that the testing plan should be designed around the product, destination and risk rather than copied from a generic checklist.

How Do EU Pesticide Limits Apply to Dried Botanicals?

In the EU, pesticide MRLs are set under Regulation (EC) No 396/2005.

Each MRL applies to a combination of a pesticide active substance and a commodity or product category defined in the Regulation’s Annex I.

There is no single pesticide limit for “herbal tea ingredients”.

The botanical first needs to be matched to the applicable Annex I commodity or category. The relevant MRL can then be checked for each pesticide.

Where no specific MRL is set for a pesticide and commodity combination, a default of 0.01 mg/kg generally applies. That default should only be used after confirming the commodity classification and any specific rules or footnotes.

Drying and processing can also change residue concentration. Values for a fresh commodity should therefore not be applied automatically to a dried botanical without checking how the rules treat the processed product.

When reviewing a pesticide report, buyers should ask:

• Which commodity or category was the botanical matched to?
• Which pesticide list was tested?
• Does the test plan cover the destination-market and customer requirements?

For more detail, see our guide on how to read pesticide and heavy metal test reports.

Are EU Heavy-Metal Limits the Same for Every Herb?

No.

EU contaminant maximum levels are set in Regulation (EU) 2023/915, which replaced Regulation (EC) No 1881/2006.

The Regulation establishes maximum levels for listed contaminants in listed food categories.

It does not create one lead, cadmium, mercury and arsenic limit for every dried botanical ingredient.

Some botanical products may fall within a category that has a maximum level for a particular metal. Others may not.

Tea, herbs, spices, food supplements and ingredients used for herbal infusions should not automatically be treated as the same legal category.

Before assigning a heavy-metal specification, first identify which legal food category the botanical falls into.

Limits written for food supplements, pharmaceuticals or another food category should not simply be transferred to a conventional food ingredient.

Is There One EU Aflatoxin Limit for Herbal Tea Ingredients?

No.

EU mycotoxin limits in Regulation (EU) 2023/915 are also category-specific.

For example, dried herbs have an ochratoxin A (OTA) maximum level of 10.0 μg/kg.

That does not mean all dried herbal tea ingredients share one common aflatoxin B1 or total-aflatoxin limit.

Nuts, oilseeds, dried fruits, spices and other named commodities have their own entries.

Before asking a supplier for “EU aflatoxin compliant” material, clarify:

• Which botanical is being supplied?
• Which plant part is used?
• Which legal food category applies?
• Which mycotoxin actually has an applicable legal maximum level for that category?

Why Do Pyrrolizidine Alkaloid Rules Matter for Herbal Tea?

Pyrrolizidine alkaloids (PAs) are one of the more important botanical-specific contaminant rules for herbal infusions in the EU.

Under Regulation (EU) 2023/915, which carries forward limits first applied from 1 July 2022, maximum levels apply to defined herbal infusion categories.

The definition of dried herbal infusions covers dried plant material such as flowers, leaves, stems and roots, in sachets or in bulk, when used to prepare herbal infusions.

This can include B2B ingredients intended for herbal infusion production, not only finished consumer tea bags.

The limits apply to the sum of a legally defined set of PAs and their N-oxides.

A laboratory report should therefore be checked for whether its analytical method covers the legally relevant analytes rather than being accepted only because it says “PA test: pass”.

These figures describe the relevant EU and Northern Ireland categories covered here.

The same botanical supplied for a different food use may fall into another category.

Is Microbiological Testing Required by Law for Dried Herbs?

EU microbiological criteria are set in Regulation (EC) No 2073/2005.

The Regulation establishes criteria for specified microorganisms in listed food categories.

There is no single statutory specification for all dried herbs covering:

• total plate count
• yeast and mould
• E. coli
• Enterobacteriaceae
• Salmonella
• Bacillus cereus

Unless a product matches a listed legal category, these should not be presented as universal EU numerical limits.

Buyers can still require microbiological specifications by contract, and many do.

Requirements such as Salmonella absence in 25 g, or limits for aerobic plate count and yeast and mould, can be commercially important buyer specifications.

They should not be described as universal EU law unless a specific legal criterion actually applies.

How Are Sulphites, Allergens and Gluten Handled?

Sulphites in the EU and Northern Ireland

Sulphur dioxide and sulphites above 10 mg/kg or 10 mg/L, expressed as total SO₂, trigger labeling requirements under Regulation (EU) No 1169/2011.

The calculation is based on the final food as consumed or, where relevant, after reconstitution according to the manufacturer’s instructions.

Sulphites in Great Britain

The same threshold applies under the GB allergen-labeling framework described in the current guidance.

Sulfites in the United States

Under 21 CFR 101.100, sulfiting agents at 10 ppm or more in the finished food are considered detectable.

Whether they need to be declared depends on the applicable regulatory conditions, including whether the sulfiting agent has a technical or functional effect.

Sulfites are not classified as a US federal “major food allergen”.

These rules concern the finished-food labeling outcome.

They do not create a universal rule that every herbal ingredient supplier must issue a standalone sulphite certificate. Other packaging wording, such as health or benefit statements, is covered in herbal tea packaging health claims.

For sourcing issues related to sulphur treatment, see our guide to sulfur-free Chinese herbal slices.

Gluten

In the EU, Northern Ireland and Great Britain, “gluten-free” is a regulated voluntary claim.

A food sold to the final consumer may use the claim only when gluten does not exceed 20 mg/kg.

Ordinary herbal ingredients do not automatically require a gluten-free certificate.

A gluten statement or laboratory test may be requested where:

• the finished product will carry a gluten-free claim
• cross-contact risk exists
• the buyer’s specification requires supporting evidence

Is Traceability the Same as a COA?

No.

In the EU and Great Britain, food businesses must be able to identify the business that supplied them and the businesses they supplied — commonly described as one step back and one step forward.

Useful traceability records can include:

• batch number
• supplier details
• customer details
• dates
• quantities
• invoices
• specifications
• COAs
• warehouse or production records

Traceability is a legal obligation in the relevant markets.

A document specifically titled “Certificate of Analysis” is not universally mandated.

A COA is a common way to connect laboratory or specification results to a particular batch.

See our guide to what a COA for Chinese herbs should include and our article on herbal ingredient batch traceability.

What Does the US FSVP Actually Require?

The Foreign Supplier Verification Program (FSVP), under 21 CFR Part 1, Subpart L, places its core obligations on the US FSVP importer.

It does not establish one fixed document package that every overseas supplier must provide.

The importer must establish a risk-based program that can include:

• hazard analysis
• evaluation of food risk
• evaluation of supplier performance
• supplier approval
• supplier-verification activities
• recordkeeping

Verification activities may include:

• onsite audits
• sampling and testing
• review of supplier food-safety records
• other appropriate verification activities

FSVP does not universally require every foreign supplier to provide a COA, pesticide report, HACCP plan and third-party certificate for every shipment.

Those documents can still be useful, and a particular importer may require them under its own verification program.

But they are not one universal FDA supplier checklist.

How Do US Rules Treat Pesticides, Metals, Mycotoxins and Microbiology?

Pesticides

US food pesticide compliance relies on EPA tolerances for specific pesticide and commodity combinations, with FDA involved in food enforcement.

There is no universal FDA rule requiring every dried herb lot to undergo a complete pesticide panel.

Heavy Metals

There is no single federal lead, cadmium, arsenic or mercury numerical maximum level that applies to every dried herbal tea ingredient.

California Proposition 65 is a California state law and should not be described as the national FDA food heavy-metal standard.

Mycotoxins

FDA action levels and enforcement policies are specific to particular foods and toxins.

There is no single federal aflatoxin number that can be safely applied to every dried botanical ingredient.

Microbiology

There is no single FDA numerical specification covering APC, yeast and mould, E. coli, Salmonella and other organisms for all dried herbal ingredients.

As in other markets, buyers may set their own microbiological specifications based on product risk and intended use.

Is Great Britain the Same as the EU?

Not automatically.

Great Britain — England, Scotland and Wales — retained or assimilated many former EU food-law instruments, including a pesticide framework based on Regulation (EC) No 396/2005.

GB rules can diverge from EU rules over time.

Contaminant limits, PA rules and other requirements should therefore be checked against the current GB rules rather than assumed permanently identical to the EU.

GB also operates its own high-risk import controls.

Some tea from China under the relevant Camellia sinensis classification has been subject to increased official controls for pesticide residues.

That measure is specific to the listed product and should not automatically be extended to every herbal infusion ingredient.

Treat Great Britain as a separate regulatory destination when preparing procurement specifications.

Does Northern Ireland Follow GB or EU Rules?

Northern Ireland remains closely aligned with the relevant EU food-law framework for food placed on the NI market.

Applicable EU requirements should therefore be checked for Northern Ireland.

Do not merge Great Britain and Northern Ireland into one undifferentiated “UK” compliance column.

Does Every Dried Herb Need a Phytosanitary Certificate?

No universal rule applies.

Plant-health requirements can depend on:

• botanical species
• plant-health classification
• degree of processing
• whether viable plant material remains
• origin
• destination
• current emergency or high-risk measures

For Great Britain, official plant-health guidance indicates that dried or freeze-dried plant material without viable plant parts may fall outside certain plant-health controls, subject to relevant pest and disease conditions.

This GB position should not automatically be generalized to the EU or United States.

Check plant-health requirements for the exact species, processing status and destination.

Which Documents Are Legal Requirements and Which Are Buyer Requirements?

The document package should be agreed according to the product, market and buyer’s quality system.

The important distinction is that a document can be commercially required by a buyer without being universally required by food law.

Are BRCGS and Retailer Requirements the Same as Food Law?

No.

BRCGS certification, retailer onboarding and customer contracts may require:

• annual supplier reviews
• third-party certification
• microbiological specifications
• batch COAs
• pesticide panels
• allergen matrices
• gluten statements
• GMO statements
• approved laboratory requirements

These requirements can be commercially mandatory for a particular customer.

They should not automatically be described as universal EU, GB or US statutory requirements.

When Should Testing and Documents Be Requested?

The following sequence reflects typical B2B practice unless a specific legal requirement applies.

Supplier Qualification

Common documents include:

• product specification
• botanical identity
• country or region of origin
• food-safety system information
• historical test results
• allergen and cross-contact information

Sample Evaluation

A buyer may request:

• sample COA
• pesticide testing where relevant
• PA testing where relevant
• microbiological testing where relevant
• other risk-specific contaminant testing

See paid samples for lab testing for how a tested sample can be linked to a later commercial lot.

Before the Purchase Order

Agree:

• approved specification
• testing plan
• contractual limits
• labeling information
• allergen information
• responsibility for additional third-party testing

Batch Release

Typical records can include:

• lot number
• release records
• COA
• risk-based test results according to the agreed plan

Before Shipment

Typical documents can include:

• shipment batch records
• traceability information
• contractually required test reports
• agreed COA

Customs and Border Entry

Depending on the product and destination, this may include:

• commercial invoice
• packing list
• Certificate of Origin
• phytosanitary documents
• high-risk-food documents
• other official import documentation

Buyer Decision Matrix by Market

How Does Aile Herb Approach Testing?

For private-label and botanical-ingredient projects, the testing plan should be agreed according to the botanical, destination market and buyer specification before the order is finalized.

Depending on the product and project scope, testing can cover pesticide residues and heavy metals for raw materials, and moisture and heavy metals for finished products.

Microbiology, aflatoxins and broader EU-specific panels may require third-party testing depending on the project.

COAs and batch documentation are provided according to the agreed order and testing scope.

The exact document and test package should be confirmed before production rather than assumed to be identical for every destination. More on how batch testing is organized is available on our in-house laboratory page.

Buyer Checklist Before Placing an Order

Before placing an order, confirm:

• exact botanical species
• plant part
• intended food use
• destination market or markets
• applicable legal food category
• legally relevant tests
• buyer-specific tests
• testing frequency
• agreed COA and document package
• allergen requirements
• sulphite requirements
• gluten-related claims
• plant-health documents
• customs documents
• responsibility for importer verification

FAQ

Does every herbal tea ingredient need a COA?

No universal legal rule requires every shipment to carry a document specifically titled “Certificate of Analysis”.

COAs are commonly requested by buyers and are useful for connecting specifications or test results to a batch.

EU/GB/NI traceability obligations and applicable US importer or FSVP recordkeeping requirements should be considered separately from whether a COA is provided.

Does the EU require pesticide testing on every batch?

Applicable pesticide MRLs must be met.

EU law does not set a universal rule requiring every dried botanical supplier to run a complete pesticide panel on every batch solely because MRLs exist.

Testing frequency is normally determined by risk, supplier controls, importer requirements and contractual specifications.

Are EU heavy-metal limits the same for every herb?

No.

Maximum levels under Regulation (EU) 2023/915 are contaminant- and food-category-specific.

A specification should be based on the applicable legal category rather than a generic “herbal ingredient” limit.

Do all herbal tea ingredients have an EU aflatoxin limit?

No.

Mycotoxin maximum levels must be checked against the exact Annex I food category.

For example, dried herbs have an OTA maximum level, but that should not be interpreted as a universal aflatoxin limit for all herbal infusion ingredients.

Are pyrrolizidine alkaloid limits relevant to herbal tea ingredients?

Yes, for defined EU and Northern Ireland herbal-infusion categories.

Those categories can include dried ingredients intended for preparing herbal infusions, not only finished consumer tea bags.

Does FSVP require a Chinese supplier to provide a COA for every shipment?

No universal fixed COA requirement applies to every foreign supplier.

The US FSVP importer must operate a risk-based supplier-verification program. Depending on the hazard analysis and verification approach, the importer may use COAs, laboratory testing, audits, food-safety records or other appropriate evidence.

Is microbiological testing legally required for every dried herb?

No universal numerical specification was identified for all dried herbs.

Specific legal criteria can apply to particular food categories, while buyers may also impose their own microbiological specifications contractually.

Does every dried herb need a phytosanitary certificate?

No.

The requirement depends on the species, degree of processing, plant-health classification, origin and destination.

It should be checked for the specific shipment rather than assumed.

Are BRCGS requirements the same as food law?

No.

BRCGS, retailer and customer requirements may be commercially mandatory for a particular supply relationship, but they are not automatically statutory EU, GB or US food-law requirements.

To source tea ingredients with the test panel and documents matched to your market, see our page for herbal tea and beverage companies and send the ingredient list and destination.