Exporting olive oil. The strictest rules the EU has ever written for a food.

Olive oil is the Italian food the world already asks for by name. It's also the one with the strictest labelling rules the EU has ever written.

This piece is part of the guide to export operations for small food producers and covers olive oil in general. What olive oil has in common with any other food, meaning the documents that travel with the goods, is in the shipping paperwork and who does what.

Where to start, in order

Five steps, and the first three don't depend on the country. Doing them in order takes a few weeks; doing them the other way round means finding out on loading day that the first one is missing.

Step	What you do	How much it matters
1. EORI numberbefore anything else	You request it from the Italian Customs and Monopolies Agency. Without it, no export declaration can be lodged in your name.	A one-off formality. The rest of the sequence is in the codes you actually need.
2. The EU labelbefore printing the batch	Legal name, place of origin, storage conditions, packing plant code. The rules are in Reg. (EU) 2022/2104.	This is where the real money is lost, because the only expensive mistake is the one you find after printing.
3. The spec sheetin English	It's the first document a buyer asks for, and the one that stalls the most deals when it's incomplete.	The template to fill in is ready in Italian and English.
4. The marketone, not five	You choose where you have a real contact, not where the market is biggest. Every extra market multiplies the same preparation.	The table below shows what each of the seven adds.
5. The price list with the Incotermbefore the first offer	A price without delivery terms and a named place can't be compared, and the buyer chooses the price they can compare.	The sheet that works out EXW, FOB and DDP starts from your own costs.

The rules that apply only to olive oil

Delegated Regulation (EU) 2022/2104, in force since 2022 in place of the old 2568/91, sets the marketing standards for olive oil. These are EU obligations: they apply to the product, not the destination, and the destination market's label is built on top of this base.

The container. Article 4 states that oils sold to the final consumer must be prepacked in containers with a maximum capacity of five litres, fitted with a closure that loses its integrity after first use. The five-litre tin is the limit, not just one size among others.

The place of origin. For extra virgin and virgin oil, the place of origin appears on the label, and it isn't optional. It corresponds, Article 8 says, to the geographical area where the olives were harvested and where the mill that extracted the oil is located. When the two places differ, the regulation spells out the wording exactly:

“(extra) virgin olive oil obtained in [the Union or (name of the Member State concerned)] from olives harvested in [the Union or (name of the Member State concerned)]”

For blends of oils from several countries there are three permitted wordings, stating whether the origin is inside the EU, outside it, or mixed. A trade mark or company name registered by 1998 or 2002, the same article adds, doesn't count as an indication of origin.

Storage. Article 7 requires information on special storage conditions, away from light and heat, to appear on the container or the labels. It's a line that costs nothing, and it's missing from many labels designed for export.

The packing plant. Article 9 requires the label to show, where applicable, the alphanumeric identification code of the packing plant approved under Implementing Regulation (EU) 2022/2105. If someone else bottles for you, you have to ask them for it, and people often don't know they need to.

The optional terms, and the acidity trap

The terms that sell are also the most tightly regulated, and Article 10 pins them down one by one. “First cold pressing” is reserved for extra virgin and virgin oils obtained below 27 degrees by a first mechanical pressing of the olive paste, using traditional hydraulic presses. “Cold extraction” applies to the same oils below 27 degrees, but obtained by percolation or centrifugation.

Organoleptic characteristics of taste and smell can only appear on virgin and extra virgin oils, only if they're the ones defined in Annex IX of Regulation (EU) 1308/2013, and only if they're backed by an assessment carried out with the method in Implementing Regulation (EU) 2022/2105. It isn't a formality: without the panel test, you can't put those words on the label.

The real trap is acidity, because it looks like the most harmless figure and nearly everyone includes it. The maximum acidity expected by the minimum durability date may be shown only if it's accompanied by the maximum values for peroxide value, wax content and ultraviolet absorption expected by the same date, in the same size of type and in the same field of vision.

In practice: all four parameters or none. A label that says “acidity 0.2%” on its own doesn't comply, and the correction comes after the batch has been printed.

One last point, for anyone playing on the harvest year: it can only appear on extra virgin and virgin oils, and only when 100% of the contents of the container come from that harvest.

Seven markets, and what each one adds

The EU base is the same everywhere. What changes is the line each country adds on top, and each market's common requirements already have their own page.

Market	What it adds for olive oil	Where the rest is
United States	FDA registration of the facility, a US Agent and Prior Notice for every shipment. Nine major allergens instead of the EU's fourteen, though for pure olive oil the issue hardly arises.	Labelling market by market
Emirates and Dubai	Label in Arabic, product registration with the relevant authority, and halal where the channel requires it. It's the market that “exporting olive oil to Dubai” searches point to more than any other.	Exporting food to the Emirates
Canada	Bilingual French and English label for mandatory information, and the Safe Food for Canadians licence, which is the importer's responsibility, not yours.	Exporting food to Canada
China	The facility has to be registered before you sell, and requirements vary by product category. The decree in force is Decree 280, since 1 June 2026.	Exporting food to China
Switzerland	A non-EU country with an agreement: proof of preferential origin is worth money to the buyer. Duty is charged by weight, and the label carries the three official languages.	Exporting food to Switzerland
United Kingdom	Agreement in force, with a registered exporter number above €6,000 of shipment value.	Exporting food to the United Kingdom
Brazil	Registration with the Brazilian authority and paperwork in Portuguese. It's the market with the longest route in of the seven.	Exporting food to Brazil

An eighth market has its own page. In Japan the duty on olive oil is zero for everyone, and what matters is the Japanese label, as explained in exporting olive oil to Japan.

The line that repeats across all seven: registration and approval at destination are almost always the buyer's obligations, and they only become your problem if the buyer doesn't have them. It's the first question to ask, and it sits alongside the others in how to qualify a foreign buyer.

What it really costs to get started

Chamber of Commerce documents cost a few tens of euros: at the Lecce Chamber of Commerce, a certificate of origin with a copy costs €10, and a certificate of free sale €3 in administrative fees. These aren't the items that weigh.

The items that weigh are three, and none of them appears on an invoice: the hours spent building the label, spec sheet and price list the first time; adapting the label, with its minimum print run, which on a small first order counts in full; and the weeks between the goods leaving and the money arriving. The sheet that does the sums lines them all up and separates what you pay once from what comes back with every order.

That separation is what decides it. A first olive oil order judged on its own almost always loses money; it makes sense when the compliant label and the spec sheet stay usable for the next buyer.

When the label versions multiply

With one product and one market, you check the label by hand and the check holds. It breaks down with combinations: three pack sizes, two harvests, four markets, and each market with its own language and wording. At that point the problem stops being writing the label and becomes keeping twelve versions of it in line.

That's when the data needs to come out of the files and into a place where the language versions are generated from the same source, so that correcting a value corrects it everywhere. With one rule that matters more than the technology, set out in Ethics: the system prepares and flags, but no document goes out until a person has read and approved it. On a label, that sign-off is substance, because a wrong wording is only discovered once the batch is printed.

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