Exporting olive oil. The strictest rules Europe has written on a food.
Oil is the Italian food the world already asks for by name. And it is also the one with the strictest labelling rules Europe has written.
You start from three things, not from a country. The EORI number, the technical sheet in English and a label that complies with the European olive oil regulation. Until these three are in place, changing market changes nothing.
Oil has its own rules, and they are in Delegated Regulation (EU) 2022/2104. Packs of no more than five litres with a closure that loses its integrity at first opening, place of origin mandatory on the label for extra virgin and virgin, storage conditions written on the container.
Acidity can't be written on its own. If the label states the maximum acidity, it must also state peroxide index, wax content and ultraviolet absorption, in the same characters and in the same field of vision. It is the most common mistake on labels designed for export markets.
This piece is part of the guide to export operations for the small food producer and covers oil everywhere. The part oil has in common with any food, that is, the documents that travel with the goods, is in the shipment folder 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 discovering at loading time that the first one is missing.
| Step | What you do | How much it weighs |
|---|---|---|
| 1. EORI numberfirst of all | It is requested from the Italian Customs and Monopolies Agency. Without it, no export declaration is lodged in your name. |
A one-off formality. The rest of the sequence is in the codes you really need. |
| 2. The European labelbefore printing the batch | Legal name, place of origin, storage conditions, packing plant identification. The rules are in Reg. (EU) 2022/2104. |
It is where the real money is lost, because the only expensive mistake is the one discovered after printing. |
| 3. The technical sheetin English | It is the first document a buyer asks for, and the one that stalls most negotiations when it is 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 additional market multiplies the same preparation. |
The table below says what each of the seven adds. |
| 5. The price list with the Incotermbefore the first offer | A price without delivery terms and without a place can't be compared, and the buyer chooses the price they can compare. |
The sheet that calculates EXW, FOB and DDP starts from your costs. |
The rules that apply only to oil
Delegated Regulation (EU) 2022/2104, in force since 2022 in place of the old 2568/91, sets the marketing standards for olive oil. They are European obligations: they apply to the product, not the destination, and the label of the market of arrival is built on top of this base.
The container. Article 4 establishes that oils offered to the final consumer are pre-packed in packaging with a maximum capacity of five litres, fitted with a closure system that loses its integrity after first use. The five-litre tin is the limit, not one format among others.
The place of origin. For extra virgin and virgin the place of origin appears on the label, and it isn't optional. It corresponds, says Article 8, to the geographical area in which the olives were harvested and in which the mill that extracted the oil is located. When the two places don't coincide, the wording is written in the regulation word for word:
«(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 formulas, stating whether the origin is inside the Union, outside, or mixed. A trademark or company name registered by 1998 or 2002, the same article specifies, 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 is a line that costs nothing and is missing from many labels designed for export.
The packing plant. Article 9 provides that the label carries, where required, the alphanumeric identification of the packing plant approved under Implementing Regulation (EU) 2022/2105. Whoever bottles through a third party asks the bottler for it, and often doesn't know they have to.
The optional terms, and the acidity trap
The terms that sell are also the most regulated, and Article 10 closes them off 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, with 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 may appear only on virgin and extra virgin oils, only if they are those defined in Annex IX of Regulation (EU) 1308/2013, and only if they rest on an assessment made with the method of Implementing Regulation (EU) 2022/2105. It isn't a formality: without the panel test, those words can't be written on the label.
The real trap is acidity, because it looks like the most harmless figure and almost everyone writes it. The maximum acidity expected by the date of minimum durability may appear only if accompanied by the maximum values of the peroxide index, wax content and ultraviolet absorption expected by the same date, in characters of the same size and in the same field of vision.
In practice: four parameters or none. A label that writes «acidity 0.2%» on its own isn't compliant, and the correction comes after the batch is printed.
Last, and it applies to those who play on the harvest year: the harvest year may appear only 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 adds
The European base is the same everywhere. What changes is the line each country puts on top, and for the common part of each market there is already its own page.
| Market | What it adds for oil | Where the rest is |
|---|---|---|
| United States | Facility registration with the FDA, a US Agent and the Prior Notice for every shipment. Nine major allergens instead of Europe's fourteen, but for pure oil the issue hardly arises. |
|
| Emirates and Dubai | Label in Arabic, product registration with the competent authority, and halal where the channel requires it. It is the market for which the query «exporting olive oil to Dubai» comes up more often than any other. |
|
| Canada | Bilingual French and English label for the mandatory information, and the Safe Food for Canadians licence held by the importer, not by you. |
|
| China | The facility must be registered before selling, and the requirements change by product category. The decree in force is Decree 280, from 1 June 2026. |
|
| Switzerland | A third country with an agreement: proof of preferential origin is worth money to the buyer. Duty calculated on weight, and the three official languages on the label. |
|
| United Kingdom | Agreement in force, with the registered exporter number above €6,000 of consignment value. |
|
| Brazil | Registration with the Brazilian authority and documentation in Portuguese. It is the market with the longest entry path of the seven. |
The line that repeats across all seven: registration and approval at destination are almost always obligations of the buyer, and become your problem only if they don't have them. It is the first question to ask, and it sits with the others in how to qualify a foreign buyer.
What starting really costs
Chamber of Commerce documents cost a few tens of euros: at the Lecce Chamber of Commerce a certificate of origin with a copy included costs €10, a free sale certificate €3 in secretarial fees. These aren't the items that weigh.
The items that weigh are three and none appears on an invoice: the hours to build label, technical sheet and price list the first time; adapting the label with its minimum print run, which on a small first order weighs in full; and the weeks between the goods leaving and the money coming in. The sheet that does the sums puts them all in a column and separates what is paid once from what comes back with every order.
It is the separation that decides. A first oil order judged on its own almost always loses; it becomes sensible when the compliant label and the technical sheet stay good for the next buyer.
When the label versions multiply
With one product and one market, the label is checked by hand and the check holds up. The breaking point is the combination: three formats, two harvest years, 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 the same one aligned.
That is when the data should be taken out of the files and put where the language versions are generated from the same base, so that correcting a value corrects it everywhere. With a constraint that matters more than the technology, written in Ethics: the system prepares and flags, but no document goes out without a person having read and approved it. On a label that signature is substance, because wrong wording is discovered once the batch is printed.
This page describes the rules. If you send us the draft of the label you are about to print and the country it is destined for, we tell you which wording is missing and which, as written, doesn't comply with the European olive oil regulation. Before printing, not after.
A person replies, the same one who then builds the systems, within 24 hours, with a reading of the situation and not with a quote. You write from here, and one line is enough.
Questions and answers
How do you start exporting olive oil?
With three things that don't depend on the country. The EORI number, without which no export declaration is lodged in your name. A label that complies with the European oil regulation, checked before printing the batch. The technical sheet in English, which is the first document a buyer asks for.
Only then do you choose the market, and you choose one: the one where there is a real contact, not the biggest one. Then the price list with the Incoterm and the place, because a price without delivery terms can't be compared.
Which labelling rules apply only to olive oil?
They are in Delegated Regulation (EU) 2022/2104, which in 2022 replaced 2568/91. Packaging for the final consumer goes up to a maximum of five litres and has a closure that loses its integrity at first opening.
For extra virgin and virgin the place of origin is mandatory on the label, and it corresponds to the area where the olives were harvested and where the mill is. The storage conditions must also be written, away from light and heat, and where required the packing plant identification.
Can you write the acidity on an olive oil label?
Yes, but never on its own. Article 10 of Reg. (EU) 2022/2104 allows it only if accompanied by the maximum values of peroxide index, wax content and ultraviolet absorption expected by the same date, in the same characters and in the same field of vision.
Four parameters or none. A label that writes only «acidity 0.2%» isn't compliant, and the correction comes when the batch is already printed.
What do you need to export olive oil to the United States?
On top of the European base, three things on the American side: facility registration with the FDA, a US Agent as the contact in the United States, and the Prior Notice for every shipment.
The American label is built on top of the European one, not instead of it. Import obligations remain with the importer: if they don't have them, the negotiation stops before it starts. The market-by-market detail is in the export label.
Can you state the harvest year on exported oil?
On two conditions, from Article 11 of Reg. (EU) 2022/2104: only on extra virgin and virgin, and only when 100% of the contents of the container come from that harvest. Two blended harvests, even in a minimal proportion, rule out the indication.
The same logic applies to the other reserved terms. «First cold pressing» and «cold extraction» apply to extra virgin and virgin oils below 27 degrees, by two different processes, and notes of taste and smell require an assessment made with the method provided by Reg. (EU) 2022/2105.
Notes on sources
- Delegated Regulation (EU) 2022/2104, marketing standards for olive oil, repealing Regulation (EEC) 2568/91: Article 4 for maximum capacity and closure, Article 7 for storage conditions, Article 8 for the place of origin and the wording when olives and mill are in different countries, Article 9 for the packing plant, Article 10 for reserved terms and acidity, Article 11 for the harvest year. The quoted wording follows the regulation's English version.
- Implementing Regulation (EU) 2022/2105, conformity checks and methods of analysis for olive oil: it is the regulation 2022/2104 refers to for the approval of packing plants, the organoleptic assessment method and the determination of the parameters that accompany acidity.
- FDA, importing food products into the United States: facility registration, US Agent and Prior Notice.
- Lecce Chamber of Commerce, costs, timing and procedures for issuing export documents. These are the fees of a single Chamber, not national values: each Chamber publishes its own, and the number to use is yours.
- The rows of the seven-market table repeat what has already been checked on the respective country pages of this site, with the sources cited there. This page adds no country requirements that aren't already documented: the final list is decided by the authority of the market of arrival and should be requested in writing from the buyer.
- This page doesn't publish market prices for oil or expected margins, because they depend on harvest year, channel and format and no public source sets them for a small producer.
On oil the expensive mistake is printed, not written.
Between the draft label and the printed batch lies the only moment when correcting costs nothing. With Itria we start from the outside to build custom digital systems for exporters. For you that translates into more requests, fewer losses and less manual work. Write us a line about what weighs on you. We take the first step: what a buyer sees when they look you up, and what we found there. Even if we don't end up working together.