Practical market insights into your product

Fresh Herbs in Germany

Inspired by tv-chefs, health-conscious German consumers increasingly
choose fresh herbs for their dishes. The interest in Mediterranean cooking
and fresh herbal teas is opening the market for basil, rosemary, oregano and
mint, whereas chives are already popular in German cuisines.

PRODUCT DEFINITION

Next to providing information on the German market for fresh herbs in general, this factsheet
focuses on 5 specific herbs (see overview below):

1. Basil (Ocimum basilicum)

2. Mint (Mentha spp)
3. Rosemary (Rosmarinus officinalis)
4. Oregano (Origanum vulgare)
5. Chives (Allium shoenoprasum)

FIGURE 1: FRESH HERBS COVERED IN THIS FACTSHEET

BASIL (Ocimum basilicum) MINT (Mentha spp) ROSEMARY (Rosmarinus officinalis)

Source: Gourmetgarden.com Source: Wondercloud.co.uk Source: Organicfacts.net

OREGANO (Origanum vulgare) CHIVES (Allium schoenoprasum)

Source: Viragcorporation.com Source: Gourmetgarden.com

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Fresh Herbs | Product specification

Ocimum basilicum, commonly known basil, or sweet basil, is native to areas in Asia and Africa.
Ocimum basilicum is an aromatic, annual herb, reaching 0.3-0.5 metres tall, but some cultivars
can reach up to 1 m. In Germany, Basil is mostly used to flavour Italian and Thai dishes and is the
main ingredient of pesto sauce.

Mentha, also known as mint, is a genus in the family Lamiaceae (mint family). The plant consists
of many different species, and is native to Europe, Asia, Africa, Australia and North America. The
most common and popular mints are peppermint (Mentha × piperita) and spearmint (Mentha
spicata). However, since the taste of peppermint is considered strong for most culinary uses,
spearmint is most often used as a flavouring in cooking for its relatively mild taste.

Rosmarinus officinalis, commonly known as rosemary, is a herb native to various countries in

the Mediterranean, such as Tunisia, Turkey, France, Spain and Morocco. In Morocco and Tunisia,
the plant is wild harvested. Next to the use of rosemary as a herb in dried or fresh form for culi-
nary purposes, it is used as a decorative plant in gardens as well, where it may have pest control
effects.

Origanum vulgare is the scientific name of oregano, which is a common species of Origanum, a
genus of the family Lamiaceae. It is native to warm-temperate western and southwestern Eurasia
and the Mediterranean region. It is widely used in Greek and Italian cuisine, where the herb is
used for the flavour of its leaves, which can be more flavourful when dried than fresh. Together
with basil (Ocimum basilicum), it is one of the main flavouring ingredients of Italian food.

Allium schoenoprasum, commonly known as chives, is used as a culinary herb to impart mild
onion flavour to many foods, including salads, soups, vegetables and sauces. The plant is wide-
spread in nature across much of Europe, Asia and North America. Chives can be found fresh at
most markets year-round, making them readily available for German consumers.

No known specific harmonised system (HS) codes are assigned for the fresh herbs covered in
this document. Fresh herbs are included in HS codes for fresh vegetables: 0709 ‘other vegeta-
bles, fresh or chilled’.

PRODUCT SPECIFICATIONS

QUALITY
GENERAL REQUIREMENTS
The quality requirements for fresh herbs are covered by marketing standards for fresh fruits and
vegetables in the European Union, including Germany. These are defined under the Marketing
Standards for Fruit & Vegetables according to Commission Implementing Regulation (EU) No.
543/2011. This General Marketing Standard (GMS) applies to fresh herbs. It covers the follow-
ing:

1. Minimum quality requirements

Subject to the tolerances allowed, the products shall be:
■■ Intact,
■■ Sound; products affected by rotting or deterioration such as to make
them unfit for consumption are excluded,
■■ Clean, practically free of any visible foreign matter,
■■ Practically free from pests,
■■ Practically free from damage caused by pests,
■■ Free of abnormal external moisture,
■■ Free of any foreign smell and/or taste.

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Fresh Herbs | Product specification

The condition of the products must be such as to enable them:

■■ To withstand transport and handling,
■■ To arrive in satisfactory condition at the place of destination.

2. Minimum maturity requirements

The products must be sufficiently developed, but not over-developed.
The development and state of maturity of the products must be such as to enable them to
continue their ripening process and to reach a satisfactory degree of ripeness.

3. Tolerance
A tolerance of 10% by number or weight of product not satisfying the minimum quality require-
ments shall be permitted in each lot. Within this tolerance, not more than 2% in total may consist
of produce affected by decay.

4. Marking of origin of produce

Full name of the country of origin. For products originating in a Member State [of the European
Union], this shall be in the language of the country of origin or any other language understand-
able by the consumers of the country of destination. For other products, this shall be in any lan-
guage understandable by the consumers of the country of destination. If you package products
for the consumer market, you will need a label in German. However, if you work with suppliers of
retailers it is common that the buyer provides the labels. For more information, please refer to the
section on labelling below.

PRODUCT-SPECIFIC REQUIREMENTS
Fresh fruits and vegetables without a specific marketing standard, should follow the guidelines of
the UNECE Standards for Fresh Fruit and Vegetables. However, these also do not list product-
specific requirements for fresh herbs. Therefore, quality standards are based on alternative
sources, such as the Codex Alimentarius. Here, fresh herbs are covered in standards on fresh
fruits and vegetables, such as Code of Hygienic Practice for Fresh Fruits and Vegetables (CAC/
RCP 53-2003, available at the List of Standards).

Since no organisational quality reference is available at the international level, each retailer usually
defines their own standards, normally in close cooperation with the supplier. An important prin-
ciple in developing and applying standards at the retailers’ level is consistency. For an example,
have a look at an UNECE document on the Quality Inspection of Fresh Herbs for Export from
Israel. Although this is not a specific requirement, it can give you an indication what aspects are
important in quality of fresh herbs.

LABELLING
GENERAL REQUIREMENTS
The labelling requirements for fresh herbs in Germany follow the general European Union require-
ments for fresh vegetables. These requirements are described under the Marketing Standards
for Fruit & Vegetables according to Commission Implementing Regulation (EU) No. 543/2011.

All fresh vegetables subject to European Union’s marketing standards must be labelled with:
■■ Nature of produce
■■ Country of origin
■■ Standard/class
■■ Variety (if stated so in the standard)

If the produce is sold pre-packaged, the following additional information has to be stated on the
product label:
■■ Name and address of packer
■■ Weight or number of items in the package
■■ Lot number
■■ Size (if stated so in the standard)

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Fresh Herbs | Product specification

If the product is sold in retail packaging, all information above will have to be in German. In ad-
dition, any certification logo, or retailer logo in the case of private label products, should be dis-
played on the label.

Organic: In order for fresh herbs to be marketed as organic-certified in Germany and generally
in the European Union, they must contain the European Union’s organic logo. In order to include
the organic logo, the product has to comply with the European Union regulation for organic farm-
ing & marketing. Read more about the EU organic logo here. The regulation is explained more
extensively on the section “What are the niche requirements?” of this document. In addition to
the European Union logo, Germany has its own organic logo, the Biosiegel. This logo is less
commonly used than the European organic logo, but may be demanded by some retailers. Dis-
cuss these options with your buyers.

PACKAGING AND TRANSPORT

Harvested fresh herbs are perishable and need to be packaged and transported in a way to
maintain the integrity of the herbs. Producers need to minimise time between harvesting and
packaging to ensure maximum freshness and quality.

The Codex Alimentarius Code of Hygienic Practice for Fresh Fruits and Vegetables includes an
Annex on fresh leafy vegetables, which includes fresh herbs (Annex III). This Annex provides
more information on the storage, packaging and transport of fresh herbs. Moreover, the Codex
Alimentarius Code of Practice for Packaging and Transport of Fresh Fruit and Vegetables gives
several recommendations to maintain quality of produce during transportation and marketing.

Product-specific requirements
Fresh herbs need to be cooled during transport (UCDavis Postharvest Technology). Optimum
temperature is commonly around 0 ˚C, but depends on the specific species. Of the species
covered in this study, basil is frost sensitive and should be kept at higher temperatures to prevent
quality deterioration (around 10 ˚C).

Bulk packaging
Packaging of fresh herbs often depends on the customer’s demand. Herbs are commonly
packed in Styrofoam boxes or waxed cartons, covered with plastic, in 1-3 kg portions. Growers
can also choose to pack herbs in perforated polyethylene or poly propylene bags inside waxed
cartons. Packaging in plastic bags or films is mainly done to reduce water loss.

Herbs should not be packed in wooden containers, because the potential for contamination is
too high and the containers are difficult to clean and sanitise.

Retail packaging
Common retail packaging in supermarkets include plastic bags or packs, usually at 15, 30 or
40 gram.

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Fresh Herbs | Market analysis

WHAT IS THE DEMAND FOR FRESH HERBS IN GERMANY?

IMPORTS
German consumers are price-sensitive in their purchases of fruits and vegetables, but their coun-
try is still Europe’s largest importer (FreshPlaza, 2014). The main suppliers of fresh vegetables
(including, but not limited, to fresh herbs) to Germany include Mediterranean EU countries (Italy,
France and Spain) and the Netherlands (ITC Trademap). Of these, Mediterranean countries are
the largest European producers of fresh vegetables and herbs, whereas the Netherlands is an
important trader.

In general, demand for fresh herbs is rising in Europe, including Germany. There are several
European suppliers of these herbs, such as Italy and Spain. Moreover, Germany is a consider-
able producer of herbs as well, both for the fresh market and for dried applications (e.g. in health
products).

Product-specific
The main suppliers to Germany of basil, rosemary and oregano are Mediterranean countries,
both in and outside of Europe. They include Spain, Italy, Morocco, Tunisia, Egypt, Turkey and
Israel. Although cultivation of these herbs may be more productive in Mediterranean climates, the
fresh herbs covered in this study can be produced in a wide range of countries.

To illustrate, suppliers to Europe and Germany also include African countries such as Kenya and
Ethiopia, Asian countries such as Vietnam and Thailand and South American countries such
as Colombia. The latter country produces several fresh herbs, such as basil, chives and mint
(FreshPlaza, 2015). In Colombia, production is stable year-round and exports increase during the
winter off-season of the Northern Hemisphere. Exports from suppliers in Africa, Asia and South
America are mainly transported by air freight.

TIPS:
■■ If you can produce fresh herbs during the Northern Hemisphere’s off-season, target the Eu-
ropean and German markets. Ensure that you are able to deliver these products fresh to the
market, for which you need logistical and planning skills. For more information, refer to the
Competition section of this factsheet.
■■ In your marketing materials, include which different fresh herbs you can export at the same
time. Buyers often buy various herbs from the same suppliers.
■■ Be aware that you can expect competition from a wide range of suppliers, in the Mediterra-
nean, Africa, Asia and South America.
■■ Have a look at the the CBI Product Factsheet on Culinary Dried herbs. Although this factsheet
focuses on dried herbs, it also includes relevant information on production and potential com-
petitors of various herbs.

GERMAN PRODUCTION
Suppliers of herbs find both competition and additional opportunities in the wide range of ap-
plications for herbs. The main opportunity for suppliers of fresh herbs lies outside the German
production season (see Competition).

Herbs have several uses; they can be used as fresh culinary herbs, but a large part of the pro-
duction is dried and further processed for animal feed, health and cosmetic applications, such
as herbal medicinal products, food supplements, cosmetics and aromatherapy. Not all the herbs
covered in this study are used in all forms. Chives, for example, is mostly used for culinary pur-
poses, whereas mint and rosemary have strong applications in medicinal tea, herbal medicine
and aromatherapy.

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Fresh Herbs | Market analysis

You may find strong competition from production in Germany during production season. The cul-
tivation of herbs and other medicinal and aromatic plants (MAPs) has a long tradition in Germany,
particularly in the Eastern part of the country. Other production areas include Bavaria, Hesse and
Lower Saxony. Around 75 species of MAPs are grown commercially in Germany on acreage of
13,000 ha (IVA, 2014). The German government aims to expand the area under cultivation to
20,000 ha by 2020.

Product-specific
The most important culinary herbs produced in Germany are parsley, chives, marjoram, dill,
chervil, sweet basil, celery, mustard, coriander and caraway. The main medicinal herbs pro-
duced in Germany are chamomile, mint, thyme, lemon balm, St. John’s wort, purple cone-
flowers, valerian, narrow leaf plantain, sage, milk thistle and sea buckthorn (Europam).

German production of both potted and cut fresh herbs is highest for basil (38% of production in
2010), parsley (21%) and chives (15%) (University of Bonn, 2014). In 2013, Germany produced
around 12,000 tonnes of chives (BMEL, 2014).

German production of fresh herbs usually slows down in the winter months, when the gap in
supply is picked up by Italian and African/Middle Eastern producers (e.g. from North Africa, Ken-
ya and Israel) (Freshplaza, 2015). This offers opportunities for you to supply the German market.

TIPS:
■■ If you can produce fresh herbs in Germany’s off-season, you can make use of the gap in local
production in Germany, especially when you produce varieties grown (and popular) in Ger-
many (e.g. chives, basil and mint).
■■ Be aware that you will face competition from countries such as Kenya, Ethiopia and Israel,
who already supply fresh herbs to Germany and other European countries.
■■ For opportunities in different applications for herbs, please refer to CBI Product Factsheets
and Modules on dried herbs and spices, natural ingredients for health products and natural
ingredients for cosmetics.

GERMAN CONSUMPTION OF FRESH HERBS CONTINUES TO GROW

About a third of herbs consumed in Germany stems from domestic production (Gemüse Servi-
ceportal). In 2013, German households spent 13% more on fresh herbs than in the previous year
(FreshPlaza, 2014). This growth was the result of both an increase in the volume purchased as
well as slight price increases for herbs. A growing German market for fresh herbs opens opportu-
nities for new suppliers.

Fresh herbs are among the top 10 of fresh vegetables in German consumer spending (AMI,
2014). In 2013, German households spent an average of € 4.25 on fresh herbs. In total, Ger-
man households spent around € 150 million on herbs, of which € 31 million are spent on basil,
the most popular herb in the country (IVA, 2014).

Product-specific
Growing consumption for the fresh herbs in this study indicate that the German market offers
opportunities. From 2004 to 2013, sales of basil were among the fastest growing herbs and
vegetables. In this time frame, consumption by German households increased by 3% annually,
only topped by fennel (+ 3.4% annually). Basil is one of the most popular herbs in Germany,
after parsley and followed by chives and dill.

In the German herbal tea market, fresh peppermint tea is the most popular mono herbal tea.
Although mint is mostly supplied dried for this market, it does demonstrate the interest of con-
sumers in the herb. Moreover, consumers also use fresh mint for mint tea. Of the total herbal tea
market in Germany, mint tea accounted for 14.8% (around 5,600 tonnes) of total sales in 2014
(WKF, 2015).

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Fresh Herbs | Market analysis

At the same time, sales of potted herbs are rising steadily in Germany as well. From 2005
to 2012, sales almost doubled, reaching € 50.3 million in 2012 (University of Bonn, 2014).
Again, basil is the most popular herb in this market (50% market share), followed by chives
(Aid, 2015). Most popular fresh herbs sold in bunches are parsley, chives and dill.

WHAT TRENDS OFFER OPPORTUNITIES

ON THE GERMAN MARKET FOR FRESH HERBS?

In Germany, as in other European countries, home cooking is increasingly popular. In 2013,

65% of German consumers cooked at home to save money (Allrecipes), although many other
drivers for this trend exist as well. Main drivers are described below: convenience, healthier living
and “clean eating”.

Moreover, consumer interest is growing to cook like the professional chefs they see on TV. Ger-
man companies such as Hello Fresh and Marley Spoon have responded to this trend by deliver-
ing fresh ingredients, including recipes, to consumers’ doorsteps. Sales of these companies are
growing rapidly (LMK, 2015). Fresh herbs are an important ingredient in these meals.

Convenience in eating is still an important trend in Germany, as time-pressed consumers do

not have the time to make a home-cooked meal. Convenience products include frozen or chilled
ready meals or on-the-go breakfasts (Frozen Food Europe, Mintel).

For herbs specifically, convenience can take several forms, which can offer opportunities for sup-
pliers who can accommodate these different forms. The most common form of convenience
products are herb mixtures, although these are mostly limited to dried or frozen herbs. Conveni-
ence in fresh herbs focuses on ease of use and increasing shelf life, for example with frozen
herbs or fresh herb pastes. In Germany, the popularity of frozen herbs is increasing consumption
to around a third of the expenditure on fresh herbs (Gemüse Serviceportal). Fresh herb pastes
keep fresh for several weeks while having the same look, taste and aroma of fresh herbs.

TIPS:
■■ If you want to supply pre-cut fresh herbs for the German market, be aware that these prod-
ucts may need to follow additional microbiological criteria. See the section on buyer require-
ments for more information.

However, the trend towards healthier living is changing the demand for convenience and ready
meals (Agriculture and Agri-Food Canada, 2012). The German population is ageing; in 2015 the
country will have the highest mean age in Europe. This ageing population is expected to have a
stronger focus on health in their food, which supports growth for products with a healthy image
(Euromonitor, 2015). There are increased opportunities for organic-certified foods and healthy
foodservice meals. Although total volume is likely to be stable for the coming years, an increase
in spending on fresh food will lead to higher consumption in terms of value. This also indicates a
growing potential for fresh herbs: since fresh herbs are seen as healthy ingredients their sales are
estimated to increase as well (Krueger).

TIPS:
■■ Ensure freshness of your herbs by using correct transportation and packaging. For more infor-
mation see the section on product specifications.

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Fresh Herbs | Market analysis

In addition, the growing trend for healthy (home) cooking is pushed by a trend for “clean eat-
ing”: eating foods free from additives (Deutschlandfunk.de). Consumers increasingly see pro-
cessed ingredients and additives as unhealthy additions to their foods and rather go for pure,
natural food products. Fresh herbs fit this trend very well, especially as they are seen as healthy
ingredients with a natural flavour (Krueger). Fresh herbs can also reduce the intake of salt, which
is another goal of healthy cooking. Related to this trend is the increased consumer concern over
food safety, ensuring safe herbs which follow European legislation is key.

TIPS:
■■ To stress the safety aspect of your fresh herbs, make sure that they comply with food safety
legislation. Make sure to browse through various border rejections and alerts for specific fresh
herbs under the product category ‘herbs and spices’ after accessing the RASFF Portal. In this
manner, you can learn about common problems faced by suppliers during border controls
and adopt appropriate measures to avoid them.
■■ Develop an Identity Preservation (IP) system for your products (i.e. maintaining their segrega-
tion and documenting their identity), focusing on their origin and on transparency along the
chain.
■■ In the RASFF Portal, it is possible to trace all cases of notifications and border rejections in
Germany and in the European Union, mostly based on contamination.

Not only is home cooking making a comeback, the type of food that German consumers make is
changing as well, which raises the potential for the herbs in this study. Italian and other Mediter-
ranean cuisines are growing in popularity among German consumers (FreshPlaza, 2015). Basil
and oregano are traditional herbs in these cuisines. The increase in these cooking styles is lead-
ing to a growing popularity of these fresh herbs. Moreover, Southern EU countries traditionally
have a preference for fresh herbs over dried ones, which is likely reflected in the recipes for these
cuisines (CBI, 2015). The increased popularity of fresh herbs in Germany extends to other herbs
as well, such as mint, rosemary, sage and thyme.

TIPS:
■■ Differentiate your fresh herbs on the market by adding recipes that use these herbs as ingredi-
ents.

Consumers’ increased need for “clean eating”, traceability, sustainability and local sourcing has
also led to another trend: home gardening. Consumers are keen on growing their own herbs
and vegetables, which can be a source of competition or an additional opportunity if you can
supply potted herbs. Herbs fit especially well with this trend. They only take up a small part of a
garden, home or balcony. Moreover, especially when grown indoors, potter herbs give consum-
ers good access for fresh herbs all year long, whenever they want to add it to their food. As a
result, the interest in potted plants is likely to expand in the future, especially for popular plants
such as basil, mint, chives and parsley (FreshPlaza, 2013). Additionally, rosemary and oreg-
ano are marketed for gardening on balconies, since these perennial herbs grow best in sunny
places (Krueger). Potted herbs are still mostly supplied by European growers and form a source
of competition for your supply of fresh herbs.

TIPS:
■■ Find out if you are able to supply potted herbs to the German market. Be aware that this mar-
ket has different requirements than for fresh cut herbs (FreshPlaza, 2014):
– There is an interest in compact herbs, which can easily be packaged and transported
at minimal damage to the plant itself.
– Potted herbs with a short spacing of leaves are popular as well, as these are easier to
manage and harvest.

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Fresh Herbs | Market requirements

The growing demand for sustainability has an impact on consumption of fresh herbs. More spe-
cifically, German consumers are interested in local sourcing of fresh products, to reduce emis-
sions from transportation. This trend can be a disadvantage for developing country suppliers who
are located further away. Moreover, retailers highlight the local source of fresh produce to high-
light the freshness and environmental sustainability. However, buying local in Germany does not
necessarily refer to produce grown in Germany, but rather to those from a designated origin, or
even specific territory/region (Agriculture and Agri-Food). Around 75% of German consumers do
prefer to buy regional products. But, at the same time consumers also want a year-round supply
of fresh herbs. Therefore, this threat is strongest during the European production season.

TIPS:
■■ Employ social and environmental sustainability practices in the production of your fresh herbs.
Show these in your marketing materials. Examples include reduction of water and energy used
in production, minimising energy emissions in transportation or certifying your fresh herbs (see
next paragraph on organic certification).

The interest in and supply of organic fresh herbs and other vegetables is growing (Fruit Logis-
tica), offering opportunities on the German market. Strongest growth of organic foods is in
the fresh produce segment (Boelw). Consumer food safety concerns, especially over pesticide
residues, is driving the interest in organic fresh foods, such as herbs, to ensure food safety.
The organic market in Germany is the largest in Europe. From 2013 to 2014, this market grew
by 4.8%, reaching a market of € 7.9 billion, which represents 3.8-4.0% of the total food market
(AMI, 2015).

TIPS:
■■ In order to market a product as “organic” in Germany (or in any other country in the Euro-
pean Union), this product has to comply with the EU Regulation (Council Regulation (EC) No
834/2007 and Commission Regulation (EC) No 889/2008 (OJ L-250 18/09/2008) for organic
production and labelling. Claims of “Natural”, “Pesticide free” or “Organic by default” are not
valid without organic certification.
■■ Learn more about the requirements for organic certification and refer to other Tips under the
“What are the requirements for niche markets?” section.

WHAT REQUIREMENTS SHOULD FRESH HERBS COMPLY WITH

TO BE ALLOWED ON THE EUROPEAN MARKET?
MARKETING STANDARDS IN THE EUROPEAN UNION
The quality requirements for fresh produce in general, and fresh herbs specifically, are described
under the section on product specifications.

FOOD SAFETY: TRACEABILITY, HYGIENE AND CONTROL

Food safety is a key issue in EU food legislation. All food products in the European Union, includ-
ing fresh herbs, must comply with the General Food Law (Regulation (EC) 178/2002), laying
down the general principles and requirements of food legislation, establishing the European Food
Safety Authority and laying down procedures in matters of food safety. It also includes provisions
on the traceability of food; the ability to track food products through the stages of production. For
exporters to the EU, your buyers (minimally) expect you to know and document your buyers and
suppliers, which products are used during your production process and to label final products for
traceability in case of a food safety problem.

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Fresh Herbs | Market requirements

Control of food imported to the EU

In the event of repeated non-compliance of specific products originating from particular countries,
such products can only be imported under stricter conditions such as having to be accompa-
nied with a health certificate and analytical test report. Products from countries that have shown
repeated non-compliance are put on a list included in the Annex of Regulation (EC) 669/2009.
Regarding fresh herbs, have a look at relevant cases to find out for what specific non-compliance
hazards products from your country are checked extra strictly. For example:
■■ Mint (Food – fresh or chilled herb) [CN code ex121190 86]. Origin: Morocco. Hazard: Pesti-
cide residues analysed with multi-residue methods based on GC-MS and LC-MS or with sin-
gle residue methods. Frequency of physical and identity checks: 10%.
■■ Basil (holy, sweet) [CN code ex121190 86]. Origin: Thailand. Hazard: Salmonella. Frequency
of physical and identity checks: 10%.

TIPS:
■■ Read more about sanitary and phytosanitary requirements at the EU Export Helpdesk and pay
special attention to the following documents from the European Commission:
– Import requirements and the new rules on food hygiene and official food controls
– Implementation of certain provisions of Regulation (EC) No 852/2004 of the European
Parliament and of the Council on the hygiene of foodstuffs
■■ Check if there are any increased levels of controls for your product and country. The list is up-
dated regularly. Check the Regulation periodically for the most recent list.

Plant Health
Fruit and vegetables exported to European Union must comply with the legislation on plant
health. The EU has laid down phytosanitary requirements to prevent introduction and spread of
organisms harmful to plants and plant products in the EU. The requirements mainly imply that:
■■ Certain listed organisms are not allowed to be imported into the EU, unless specific circum-
stances apply.
■■ Plants or plant products specified in Part B, Annex V of Directive 2000/29/EC must be ac-
companied by a plant health certificate. Of the five herbs discussed in this factsheet, you need
a plant health certificate for basil. Chives are also listed in this annex, but you only need a
plant health certificate when you export this plant and/or seeds intended for planting. If you
want to check other herbs not included in this factsheet, make sure to search by using the
Botanical name of your product.

TIPS:
■■ Check with the relevant Plant Protection Organisation (NPPO) in Germany or with your importer
what the requirements are applying to your product. This is especially important if you export
basil.
■■ If a phytosanitary certificate is needed to be allowed entry into Germany/the EU, refer to the
model phytosanitary certificate on Annex VII (p.170) of Directive 2000/29/EC and/or ask your
importer for assistance.
■■ Read more about plant health on the website of the European Commission: Plant Health.
■■ The European Union’s legislation on Plant Health has been subjected to recent modifications.
The final decision on such changes, which affect issues such as impact assessment, stake-
holder consultations and evaluation will take several years, but the website of European Com-
mission: Plant Health: New EU Plant Rules contains useful information which will help you plan
ahead.

Maximum Residue Levels (MRLs)

The European Union has set maximum residue levels (MRLs) for pesticides in and on food prod-
ucts, which is especially relevant for fresh herbs. Products containing more pesticides than al-
lowed will be withdrawn from the EU market.
Note that Germany, together with the UK, uses MRLs which are stricter than the MRLs laid down
in EU legislation. In fact, Germany applies the strictest MRLs at the retail level in Europe! As a
general rule, German retailers apply an MRL rule which is 3 times stricter than the EU legislation –
but some German retail chains can set the MRL limit even higher.

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Fresh Herbs | Market requirements

TIPS:
■■ Find out which MRLs are relevant for your products, use the EU MRL database in which all
harmonised MRLs can be found. You can search on your product or pesticide used and the
database shows the list of the MRLs associated to your product or pesticide.
■■ Consult your German buyer on their specific MRL requirements and on their expectations for
compliance. As mentioned above, company policies might limit the MRLs to 30%, 50%, 70%
or even higher parameters in relation to the EU legislation.

Contamination sources and maximum levels

Contaminants are substances that may be present as a result of the various stages of pre-
harvest, harvest or post-harvest (incl. packaging) of fresh herbs. One of the most common
problems faced by exporters of fresh herbs and other fresh produce is contamination derived
from external sources. For this reason, it is crucial for exporters to learn and comply with the
maximum contamination levels allowed by the European legislation. The different sources of
contamination in fresh herbs, and the respective legislation addressing them, are:

■■ Heavy metals (see section 3 of Annex of Regulation (EC) No 1881/2006):

– The maximum limit of cadmium allowed for fresh herbs and other leaf vegetables is 0.20
mg/kg wet weight.
■■ Microbiological: In the current EU legislation (Commission Regulation (EC) No 2073/2005),
microbiological criteria have been set specifically for fresh vegetables. Although there is no
specific legislation for microbiological contamination for fresh herbs, food safety authorities can
withdraw imported fresh herbs from the market or prevent them from entering the EU when
Salmonella, E. coli or other microbes are found. Criteria for fresh pre-cut vegetables (ready-to-
eat) are:
– Salmonella – Absence in 25 g (Analytical reference method: EN/ISO 6579).
– E. coli – Limit value m of 100 cfu/g; limit value M of 1,000 cfu/g (Analytical reference meth-
od: ISO 16649-1 or 2).
■■ Foreign matter: Contamination by foreign matter like excessive filth, soil or other materials is
a threat for the quality of fresh herbs.

General requirements on packaging and liability

Note that there is also non product specific legislation on packaging and liability that apply to all
goods marketed in the European Union.

Full overview of requirements for fresh vegetables, including fresh herbs:

For a list of requirements consult the EU Export Helpdesk where you can select your specific
product code under Chapter 07 (Edible vegetables and certain tubers); you can select your re-
spective origin and export destination (e.g. Germany).

WHAT ADDITIONAL REQUIREMENTS DO BUYERS OFTEN HAVE?

GLOBALG.A.P., QS and other quality management standards

The most commonly requested food safety certification scheme, essential for exporting fresh
herbs and other produce to the European Union, and Germany specifically, is GLOBALG.A.P.
Even though GLOBALG.A.P. is not a legislative requirement per se, it is requested by practically
all retailers in the European Union.

GLOBALG.A.P. is a pre-farm-gate standard which covers the whole agricultural production pro-
cess from farm inputs such as seedling, until the product leaves the farm, i.e. only primary in-field
processing is covered. So as to cover further steps in the value chain, GLOBALG.A.P. is often
supplemented by quality management systems which relate to post-harvest handling, packaging
and other processes out of the farm.

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Fresh Herbs | Market requirements

Implementing a quality management system according to HACCP is a minimum requirement

regarding handling and processing steps in the value chain. This system is thus additional to
GLOBALG.A.P., which only covers processing steps until products leave the farm. HACCP is
specified in both the Codex Alimentarius standard on General principles of Food Hygiene and
mentioned under General Food Law Regulation (EC) 178/2002. Social practices are increasingly
part of the agenda of German retailers and their audit processes. Therefore, German retailers will
most probably ask for additional Quality Management System certificates such as International
Featured Standards (IFS): Food, which is a quality and safety standard published by the union of
German supermarket chains, HDE (Hauptverband des Deutschen Einzelhandels).

An alternative requirement often used by German retailers is the GLOBALG.A.P.-equivalent stan-

dard QS. Whereas QS is equivalent to GLOBALG.A.P. at the farm level (QS-GAP), it also covers
further food safety steps along the value chain, from the farm gate to wholesalers and retailers.
As such, QS is a 3-tier system which involves every stakeholder in the value chain. A combined
certification for both QS and GLOBALG.A.P at the same time is possible at the producer level.
Apart from QS you will also need a specific HACCP based system for quality management, such
as IFS.

TIPS:
■■ Refer to the European Commission’s document on the Implementation of procedures based
on the HACCP principles
■■ When you plan to target one or more markets, check which specific food safety management
systems are most commonly requested. In any case choose for a management system that is
GFSI approved.
■■ Read more on the different Food Safety Management Systems at the Standards Map.
■■ Contact your buyers to find out which (additional) requirements they have and which quality
management system they prefer.

GRASP, a GLOBALG.A.P./QS(GAP) add-on

GRASP stands for GLOBALG.A.P. Risk Assessment on Social Practice, and is a voluntary ready-
to-use module developed to assess social practices on the farm, addressing specific aspects of
workers’ health, safety and welfare. Operators certified against GLOBALG.A.P. and/or QS(GAP)
can get certified according to this additional module so as to substantiate their social practices
at the farm level. This module is increasingly important to retailers in Germany, since it addresses
social risks intrinsic to the value chain of fresh products and can strengthen their Corporate So-
cial Responsibility (CSR) policies.

TIPS:
■■ Have a look at the quality management systems mentioned above, in addition to compulsory
HACCP systems. Third-party certification of such systems can strengthen your competitive-
ness. Discuss these options with your buyer.

Packaging and Waste Avoidance

The Packaging and Waste Avoidance Law/Green Dot, the German Packaging and Waste
Avoidance Law (Verordnung über die Vermeidung und Verwertung von Verpackungsabfällen, or
VerpackV) establishes recyclability requirements for packaging material in the framework of the
European Parliament and Council Directive 94/62/EC (and amendments), on packaging and
packaging waste.

The Green Dot (Der Grüne Punkt) system was developed to assure that product materials will be
recycled in a controlled facility. The Green Dot symbol is found on the packaging material of virtually
all retail products in Germany.

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Fresh Herbs | Requirements for niche markets

The use of the Green Dot is not a legal requirement for all products but, in practice, it will be very
difficult to market a (pre-packaged) product in Germany without it. Typically, the producer or the
importer pays a fee and enters into a licensing agreement with Der Grüne Punkt – Duales Sys-
tem Deutschland, and provides the licensing company necessary product information in order to
use the Green Dot (GAIN REPORT, 2015).

TIPS:
■■ Read more about the Green Dot in Germany and the EU legislation on packaging and pack-
aging waste.

WHAT ARE THE REQUIREMENTS FOR NICHE MARKETS?

Organic
Organic certification is a non-legislative requirement for fresh herbs but, in order for a company
to market their product as ‘organic’ in Germany and in the European market, it must comply with
the EU Regulation (Council Regulation (EC) No 834/2007 and Commission Regulation (EC) No
889/2008 (OJ L-250 18/09/2008) for organic production and labelling – which is in itself a legal
requirement. Organic products must be grown using organic production methods which are laid
down in legislation and growing and processing facilities must be audited by an accredited certi-
fier, before you may put the EU and the German organic logo on your products.

One of the factors which exporters have to pay special attention to is whether their organic cer-
tification is de facto recognised by the EU legislation. Therefore, producers/exporters should
search for a certifier whose standards are recognised by the EU. The European Commission’s
Agriculture and Rural Development website provides a thorough explanation of import regulations
and other related issues.

Commission Regulation (EC) No 1235/2008 of 8 December 2008 laying down detailed rules for
implementation of Council Regulation (EC) No 834/2007 and its latest amendments, as regards
the arrangements for imports of organic products from third countries, can be found on the EUR-
Lex website. If you want to target niche markets in Germany, you can also try to gain a competi-
tive advantage if you comply with Demeter, Naturland or Bioland organic certification.

TIPS:
■■ For market information on organic certified foods, please refer to Market Trends.
■■ Investigate the possibilities for organic certification, including the opportunities and costs in-
volved in the process. Always discuss these options with your buyers before complying with
the certification.
■■ For information on organic certification in Europe, visit the website of Organic Farming in the
European Union, which also contains guidelines concerning imports of organic products. Also
consult the International Federation of Organic Agriculture Movements (IFOAM) website for
information on certification standards.
■■ Check the Bio-Siegel website to acquainted with Germany’s national organic label.

Fair Trade
Fairtrade International is the leading standard-setting and certification organisation for Fairtrade. In
2014, sales of German Fairtrade products amounted to € 850 billion, an increase of 27% since
2013 (Fairtrade FLO). In general, herbs make up a small part of Fairtrade products, and are
mostly focused on dried herbs. Therefore, potential in Germany for Fairtrade certified fresh herbs
is deemed smaller than potential for organic certification. However, this may change in the future,
as Fairtrade has now set a premium for fresh herbs specifically.

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Fresh Herbs | Market analysis

Products which carry the Fairtrade label indicate that producers are paid a Fairtrade Minimum
Price or Premium. Regarding fresh herbs, Fairtrade International has set a Fairtrade premium on
top of the commercial price for mint specifically (premium of € 0.50 per kg) and fresh herbs in
general (premium of 15% of commercial price). The latter covers all five herbs included in this
study. These Fairtrade premiums apply to worldwide production and both conventional and or-
ganic.

Other fair trade standards available in the European market are Fair Trade Ecocert and IMO’s Fair
for Life. Fair Trade Ecocert provides for guaranteed minimum prices, producer support and good
agricultural practices; this standard requires an organic certification. IMO’s Fair for Life has a simi-
lar proposition, and is a standard for companies which demonstrate decent working conditions
and commit to fair sourcing and responsibilities towards their primary producers. Organic certifi-
cation is not compulsory for Fair for Life holders.

TIPS:
■■ Before engaging in a Fair Trade certification programme, make sure to check (in consulta-
tion with your potential buyer) that this label has sufficient demand in your target market and
whether it will be cost beneficial for your product.
■■ Consult the Standards Map database for more information on Fair Trade and other voluntary
standards relevant for fresh herbs.

WHAT COMPETITION DO I FACE ON THE GERMAN MARKET

FOR FRESH HERBS?

Market entry
Requirements to enter the fresh produce market in Germany are (increasingly) strict, which com-
plicate market entry.

TIPS:
■■ Comply with market access requirements on food safety, quality and traceability.
■■ If you want to comply with specific certifications, discuss these options with your buyers.
■■ For more information on German and European buyer requirements, including those on con-
tamination and certifications, refer to the section on buyer requirements of this factsheet.

Product competition
Substitution for fresh herbs depends on two main factors: the specific product and its price. For
fresh herbs, the threat of substitution with other herbs/spices is limited. To illustrate, if consumers
are looking for rosemary to flavour a specific dish, they are less likely to opt for other herbs be-
cause these have a different flavour.

Price is a strong factor in deciding for fresh or processed (e.g. frozen/dried) herbs. Dried herbs
are the most common form of consumption in Germany, but fresh herbs are increasingly taking
over their position as healthy living becomes more important among consumers.

For fresh herbs, the main substitute products include:

■■ Dried or frozen herbs, both as single-herb products or mixtures
■■ Potted fresh herbs
■■ Other flavouring products, such as ready-to-cook meal packages (e.g. Knorr)

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Fresh Herbs | Market analysis

Company competition
Your competitive advantage on the fresh herbs market also depends on the geographical mar-
ket, sales channel and segment. Various suppliers exist for fresh herbs, including in Europe and
Germany:
■■ For rosemary: Spain, France and Italy (Southern Europe, mostly from cultivation); Egypt, Mo-
rocco and Tunisia (mostly wild-collected)
■■ For basil: the Mediterranean (Italy, Egypt, Israel), Kenya, Ethiopia
■■ For chives: Europe (including Germany), Israel, Kenya, Ethiopia
■■ For mint: Europe, Africa (e.g. Egypt and Kenya), Latin America (year-round production)
■■ For oregano: Mediterranean (Turkey, Italy, Spain, North Africa) and Middle East

In Africa, Kenya and Ethiopia are strong suppliers of fresh herbs to Germany and Europe in
general (Freshplaza, 2015); in addition to other consolidated suppliers such as Egypt and Tuni-
sia. Several of the growers in Kenya and Ethiopia are from Israel, another large supplier of fresh
herbs. They moved to East Africa because of more favourable conditions than in Israel. The pric-
es of these African countries are lower than in Israel, which makes them a preferred supplier to
some European buyers. However, at the same time product quality is higher in Israel, especially
in the production of basil, where African producers are experiencing some problems.

If you can differentiate your product on the market, you can improve your competitive position.
As a fresh herbs supplier, you have several options to do so. Examples include complying with
organic certification, adding recipes for your products, as well as marketing communication in
general. You can also improve your competitive position if you can accommodate the interest of
German consumers in good social and environmental practices by adding information to your
product (see tips).

TIPS:
■■ Try to differentiate your product on the market and compete on added value, such as herbs
with organic certifications, sustainably produced or which are ready-to-cook (pre-cut).
■■ Ensure freshness and quality of your products to compete with European suppliers of fresh
herbs. Employ good post-harvest processes: store your products in clean containers in a
clean warehouse, ensure hygienic grading and sorting conditions and apply strict sorting and
grading standards. Store herbs at the right temperature. Refer to the sections on transporta-
tion and buyer requirements for more info. You also need logistical and planning skills to en-
sure that your products arrive fresh in Germany.
■■ Focus your exports of fresh herbs to Germany during European’s off-season. In those
months, imports commonly increase considerably as buyers seek to source year round.
■■ Add value to your fresh herbs by complying with organic certification, adding recipes, investing
in storytelling and marketing communication, showing the final consumer where and how your
herbs have been produced (label, website, social media) or by compensating for the emis-
sions during the long transportation of your fresh produce.

In general, German retailers, particularly supermarkets, have a strong position in the supply
chain. As a result, they have very strict requirements and conditions for products. Moreover,
competition between supermarkets is mainly on price, which makes price an issue for importers/
wholesalers who supply these retailers as well. They will put pressure on you as a supplier as
well to meet competitive prices.

TIPS:
■■ Try to develop long-term partnerships with European buyers, for example in a long-term buying
programme with a European retailer. Make sure that your company is ready for that commit-
ment.
■■ Contact an experienced importer/distributor before you enter the German market for more
information on requirements and expectations from supermarkets. Be aware that delivering to
supermarkets is very demanding in buyer requirements and price.
■■ Make sure that you are a reliable and accessible partner. Adhere to your agreements and

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Fresh Herbs | Market analysis

make sure you are easy to contact.

■■ Always be available for communication! Be open and honest in your communications and
promptly answer questions and requests from your (potential) buyers.
■■ Make sure that you can trace your fresh herbs back to the farm that produced them and com-
municate this to your buyers. Increasing this transparency builds trust with your buyers.

WHAT DO THE TRADE CHANNELS AND INTERESTING MARKET

SEGMENTS LOOK LIKE IN GERMANY FOR FRESH HERBS?

MARKET CHANNELS
The structure of the market channels for fresh herbs in Germany follow the general structure,
and contain similar players, as described in CBI’s Fresh Fruit and Vegetables: Channels and Seg-
ments. Nonetheless, the particularities of the German market are highlighted below.

FIGURE 1: CHANNELS AND SEGMENTS FOR FRESH HERBS IN EUROPE AND GERMANY

Source: ProFound

MARKET CHANNELS
Production and exports
Fresh herbs for exports are grown by large-scale farming as well as small-scale, traditional farm-
ing and small to medium-scale contract farming. Producers can grow herbs for the fresh and
dried herbs market, as well as to process them into essential oils. Both applications (fresh and
processed) require different investments in terms of equipment and skills.

There are many “touch-points” for fresh herbs in the beginning of the supply chain, such as
harvesting by hand, quality sorting, bunching and packing herbs, which are potential sources of
contamination. Producers and processors need to take measures to prevent contamination in
these steps.

Growers of fresh herbs deliver their produce to exporting companies, which usually carry out
post-harvest treatments such as sorting, cleaning or washing, trimming (and sometimes cutting)
and packaging & labelling. Large-scale farmers often export fresh herbs themselves. The post-
harvest steps carried out at the producing country will depend on the requirements of the cus-
tomers down the supply chain. Usually, sorting and cleaning is done in the country of origin, as
well as packaging in wholesale containers or retail packs.

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Fresh Herbs | Market analysis

Exporting companies then sell the produce to the export markets via import agents or directly to
wholesalers or supermarkets. Fresh herbs can be transported by air or sea freight, depending on
the distance the produce needs to travel. In general, air freight is most common, due to the per-
ishable nature of fresh herbs.

Imports and distribution

The most interesting trade channels for exporters of fresh herbs are importers. As described
under Market Demand, fresh herbs imported into Germany are often sourced through the Neth-
erlands. Here, the main players, facilities and logistical networks for fresh produce in Europe are
located. Thus, the degree of contact between a developing country supplier and the German
market will depend on whether the product is supplied directly or indirectly to this market.

Importers purchase fresh herbs from various producing countries and resell to domestic retail-
ers, or re-export to other countries. Some importers/wholesalers use agents to facilitate trans-
actions. The wholesale/distribution activities might be integrated into the importer’s service
portfolio or outsourced to a separate company.

Importers of fresh herbs are usually specialised in fresh produce like fruits and vegetables at
large (for example Bud Holland in the Netherlands, also supplying the German market). Special-
ised companies in herbs and spices commonly import dried herbs, although there are some
specialised Dutch importers for fresh herbs, for example Greenfresh and Van Vugt, who also
export to Germany. An important German importer for fresh herbs is Gartenbauzentrale, this pro-
cessor imports herbs in the European off-season. Importers take care of necessary administra-
tive formalities and often provide services such as (re-)packaging (e.g. in retail-sized packaging),
transportation and logistics to then sell the produce to the retail market. These specialised whole-
salers increasingly by-pass traditional importers as they handle direct import and distribution of
produce.

Other important actors are wholesalers like FrischeParadies which were traditionally solely
supplying to catering, restaurants, hotels but are increasingly open to end consumers as well.

MARKET SEGMENTS

Fresh herbs are sold through two main channels:

■■ Retail, sub-divided into:
– supermarkets
– specialised shops
■■ Food service/catering, sub-divided into mainly:
– Restaurants
– Hotels

Retail
For fresh herbs, supermarkets, street markets and specialised vegetable shops are the most
important market channels. Fresh herbs are sold in supermarkets, discounters and more spe-
cialised vegetable shops. Around 90% of fresh vegetables are sold by these retail shops, with
the supermarket chains Edeka, Rewe, Aldi, Lidl and Kaufland covering around 85% of the food
market (CIR, 2014). These retailers have a strong competitive position (see Competition). Fresh
herbs are put on the German market in different forms, as: potted herbs, bunches and in plastic
sheets or containers, which are often used in the hospitality industry (Aid, 2015).

Moreover, special retailers/wholesalers such as FrischeParadies, which were traditionally supply-

ing to catering, restaurants, hotels, are increasingly open to end consumers as well.

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Fresh Herbs | Market analysis

Food service
The food service industry is an increasingly important player for fresh herbs. Here, fresh herbs
are used extensively as well. They are used as flavouring and as garnish. The food services sec-
tor is actually one of the drivers of the use of fresh herbs at home.

WHAT ARE THE END MARKET PRICES FOR FRESH HERBS?

TABLE 1: INDICATIVE END MARKET PRICES FOR FRESH HERBS IN GERMANY, IN € PER 100 GRAM

Source: Supermarktcheck, Frische Paradies

The table above gives an indication of prices for fresh herbs in German retailers. Please note that
these prices are end-market prices for German consumers and are much higher than your ex-
port prices. Both importers and retailers add a considerable margin to FOB prices of fresh herbs.

As for most fresh produce, prices for fresh herbs will vary throughout the year, depending on
European production of specific herbs. In general, prices are higher in the winter months, when
European production slows down.

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Fresh Herbs | Useful sources

USEFUL SOURCES

Press and associations

■■ European Fresh Produce Association (Freshfel) – www.freshfel.org
■■ Fresh Plaza – www.freshplaza.com – news and information portal covering fresh produce
■■ Fresh Info – www.freshinfo.com – weekly journal for the fresh fruit and vegetables business
which includes industry news and market data
■■ German Fresh Fruit and Vegetable Association (DFHV) – www.dfhv.de
■■ Bundesvereinigung der Erzeugerorganisationen Obst und Gemüse e.V. (BVEO – Confedera-
tion of producer organisations for fruit and vegetables) – www.bveo.de
■■ Fruchthandel Online magazine – www.fruchthandel.de

GERMAN IMPORTERS AND WHOLESALERS INCLUDE:

■■ Gartenbauzentrale: www.gartenbauzentrale.de
■■ Univeg: www.univeg.de
■■ Dreesen: http://dreesen.de/

RELEVANT TRADE FAIRS

Visiting or even participating in trade fairs is highly recommended as one of the most efficient
methods of testing market receptivity, obtaining market information and finding prospective busi-
ness partners. The most relevant trade fairs for exporters of fresh herbs are:
■■ Fruit Logistica (www.fruitlogistica.de) in Berlin, Germany, is an international trade fair for fresh
produce trade
■■ Biofach (www.biofach.de) in Nuremberg, Germany (for organic producers)

MORE INFORMATION

CBI market information: Promising EU export markets.

EU Expanding Exports Helpdesk http://exporthelp.europa.eu – go to ‘trade statistics’.
Eurostat, http://epp.eurostat.ec.europa.eu/newxtweb – statistical database of the EU.
Several queries are possible. For trade, choose ‘EU27 Trade Since 1995 By CN8’.
International Trade Statistics – www.trademap.org you have to register.

This survey was compiled for CBI by ProFound – Advisers In Development

in collaboration with CBI sector expert Jos Leeters. November 2015.

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