A practical, pre-shipment testing and documentation checklist to keep Indonesian IQF vegetables compliant with EU MRLs, avoid RASFF alerts, and clear customs smoothly.
If you buy frozen vegetables, you don’t want surprises at the EU border. In our experience, 8 out of 10 compliance headaches come down to one thing: pesticide residues that weren’t tested at the right time, with the right scope, or documented properly. The good news is that Indonesian IQF vegetables can consistently meet EU MRLs if you follow a tight, pre-shipment system.
We export both fresh and frozen produce and run this program daily for SKUs like Premium Frozen Okra, Premium Frozen Sweet Corn, Frozen Mixed Vegetables, Frozen Paprika (Bell Peppers), and Premium Frozen Edamame. Here’s the same framework we use to keep loads clean and out of RASFF.
The 3 pillars of EU MRL compliance for IQF vegetables
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Risk mapping by crop and origin. Spinach, green beans, and leafy items trend higher risk in EU surveillance. Broccoli is mid-risk. Sweet corn and edamame are usually low to mid-risk. Map suppliers, farms, and crop protection histories. Then set test frequency by risk, not by habit.
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Right-scope testing on the finished IQF matrix. Multi-residue by LC-MS/MS and GC-MS/MS is the baseline. Add single-residue tests for chemicals that escape generic screens like dithiocarbamates (CS2 method), glyphosate/AMPA, chlorate/perchlorate, and quats (DDAC/BAC) when relevant. We often see chlorate pop up from processing water, not the field.
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Documentation that matches how the EU actually checks. Your COA must be traceable to the exact lot, show LOQs at or below 0.01 mg/kg where needed, and list methods and analyte scope. If a product falls under increased checks, you’ll also need the right CHED-D and pre-notification in TRACES.
What tests do you really need before shipping to the EU?
We recommend a layered scope:
- Multi-residue screen. LC-MS/MS and GC-MS/MS covering 300–600+ pesticides across organophosphates, carbamates, pyrethroids, triazoles, strobilurins, neonicotinoids, etc. This is your core.
- Add-ons by risk and commodity:
- Dithiocarbamates by CS2 method. Especially for leafy greens and green beans.
- Glyphosate + AMPA. Needed if there’s any chance of use in the supply chain.
- Chlorate and perchlorate. Often linked to water sanitizers and fertilizers.
- Quats (DDAC/BAC). If any contact with quaternary ammonium sanitizers occurred.
We’ve found most RASFF notifications on Indonesian vegetables trace back to either dithiocarbamates, acephate/omethoate, chlorpyrifos (still detected despite EU bans), or chlorate. Build your scope accordingly.
Which Indonesian labs can test for EU MRLs?
Use ISO/IEC 17025 accredited labs with a scope that includes pesticide residues in fruits and vegetables by LC-MS/MS and GC-MS/MS. Examples used by exporters include:
- PT Saraswanti Indo Genetech (SIG), Bogor. Widely used for multi-residue and add-ons.
- SUCOFINDO Laboratories. Multi-site network. Check the specific lab’s scope for pesticides.
- Intertek Indonesia. Food testing including residues. Confirm scope for your matrices.
- Balai Besar Industri Agro (BBIA), Bogor. Government lab with ISO 17025 programs.
Non-exhaustive list. Always request the latest accreditation scope, method LOQs, analyte list, and matrix validation for frozen vegetables/IQF.
How many samples per SKU and lot should you test?
Here’s a practical approach we use:
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Define a “lot” as one continuous production run per SKU per day per facility, using uniform raw material. If you change farms or dates, that’s a new lot.
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One composite laboratory sample per lot per SKU. Build the composite from at least 10–20 incremental grabs taken across pallets and container positions. For IQF, pull from core, top, and edges of cartons to capture worst-case.
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Laboratory sample size. 1 kg net sample is typical for residues. Keep a sealed 1 kg counter-sample retained at -18°C for disputes.
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High-risk items (e.g., IQF spinach, green beans). Test every lot. For very large lots, add one sample per 5–10 metric tons or per 8-hour shift.
We don’t rely on farm-level tests alone. EU checks the finished edible portion. Always test the finished IQF product.
When to sample and how long do tests take?
Turnaround time in Indonesia is typically:
- Standard: 7–10 working days for multi-residue.
- Expedited: 3–5 working days with surcharge.
- Add-ons like glyphosate/AMPA or quats can add 1–3 days.
Work backward from your ETD. We target sampling at T–12 to T–15 working days to allow rework if needed. Use a hold-and-release policy. Don’t load until the COA is reviewed and approved. For consolidated containers with many SKUs, stagger production so you’re not waiting on every result at the last minute.
If you’re planning a multi-SKU load and need a workable sampling calendar, Contact us on whatsapp. We can share templates we use with EU buyers.
What are the EU MRLs for frozen green beans, broccoli, and spinach?
The EU doesn’t publish “one MRL per commodity.” MRLs are set per pesticide and commodity under EU Regulation 396/2005. You must check your analytes against the EU Pesticide Database and apply processing factors if applicable.
- Frozen state. For most IQF vegetables, the processing factor is 1 unless the EU database lists a specific factor. Freezing generally doesn’t reduce residues in a way regulators credit.
- Default MRL. If no specific MRL exists, the default is 0.01 mg/kg.
- Practical tip. Build buyer specs at 30–50% of the strictest applicable MRL among your target markets. It gives you room for test uncertainty and lab-to-lab variation.
Use the EU database search, select the active substance and commodity group (e.g., beans with pods, broccoli, spinach), and confirm the current value. Re-check before every new crop cycle because quarterly updates can shift limits.
Do frozen vegetables need a phytosanitary certificate for the EU?
Generally, no. HS 0710 IQF vegetables don’t require phytosanitary certificates because they’re considered processed enough to eliminate plant health risks. Exceptions can exist for specific items or destinations, so confirm with your EU importer and Indonesia’s NPPO for edge cases. If your product is listed under increased controls, you may instead need a lab report and CHED-D pre-notification under the Official Controls Regulation.
What documents prove MRL compliance at EU customs?
Have these ready and consistent:
- ISO 17025 COA/test report. Includes sample ID, lot/batch, production date, matrix, methods, analyte list, LOQs, results with units, and lab accreditation mark.
- Supplier pesticide declaration. Statement of non-use for banned EU pesticides and adherence to EU MRLs.
- Full traceability. Farm origin, harvest dates, processing date, lot mapping. For mixed SKUs like Frozen Mixed Vegetables, show component origins.
- If listed in EU Implementing Regulation 2019/1793. Importer pre-notification in TRACES and any required official sampling documents or lab reports.
We verify that the COA’s sample description matches the export carton labels exactly. Mismatches trigger needless delays.
A week-by-week playbook you can actually run
Week 1–2. Risk and scope
- Map SKUs by risk. Spinach, green beans high. Broccoli mid. Edamame and sweet corn low to mid.
- Lock your lab’s analyte list and LOQs. Add glyphosate, dithiocarbamates, and chlorate if your history suggests risk.
Week 3–4. Sampling plan and buyer specs
- Define lot size rules. Write down “per day, per SKU, per continuous run.”
- Agree testing frequency with the buyer. High-risk every lot. Low-risk per lot or per 25 MT.
- Set internal action limits at 30–50% of MRL.
Week 5–6. Pre-harvest to production
- Pilot test first lots and validate the lab turnaround time. Build buffers.
- Train QA on composite sampling and duplicate retention.
Week 7–8. Shipments go live
- Hold-and-release with COA verification.
- Cross-check COA to labels and packing list. Save everything in one dossier per shipment.
How to read a COA without missing red flags
- Scan LOQs. They should be ≤ 0.01 mg/kg for most analytes. If LOQ > MRL, that’s a problem.
- Confirm matrices and methods. LC-MS/MS and GC-MS/MS listed for multi-residue. CS2 method for dithiocarbamates. Specific method for glyphosate.
- Watch qualifiers. “<LOQ” is fine. But “detected” without a value needs clarity.
- Check uncertainty values when results are close to MRL. If your spec is 50% of MRL, you’ll sleep better.
Common mistakes that trigger RASFF (and how to avoid them)
- Testing raw material only. EU checks the finished edible portion. Always test IQF product.
- Narrow analyte lists. Missing dithiocarbamates, glyphosate, or chlorate is a classic failure.
- Sloppy sampling. One grab from the front pallet isn’t representative. Build composites across the lot.
- COA mismatch. Wrong lot number or matrix description gets flagged at intake.
- Shipping before results. “We’ll send the COA later” is how avoidable detentions happen.
Costs, timelines, and when to pay for speed
- Costs in Indonesia. Roughly USD 120–250 per multi-residue sample. Add-ons push it up. Expediting can add 30–50%.
- When to expedite. New suppliers. First-of-season lots. Any product previously flagged by the buyer or the 2019/1793 list.
Where this advice applies (and doesn’t)
- Applies. IQF vegetables for the EU under HS 0710, including beans, spinach, broccoli, okra, paprikas, edamame, and mixes.
- Doesn’t cover. Farm agronomy, non-EU markets, or microbiology. Different rules apply to fresh produce like Carrots (Fresh Export Grade), Tomatoes, and Red Radish.
Quick resources and next steps
- EU Pesticide Database. Search current MRLs and processing factors.
- EU Regulation 396/2005. Core legal text on MRLs.
- EU Official Controls Regulation 2017/625 and Implementing Regulation 2019/1793. For increased checks and CHED-D.
- RASFF Portal. Check trending alerts by commodity and country.
If you need a ready-to-use pre-shipment checklist mapped to your SKUs, we’re happy to share what we use for our IQF range. Or if you want to explore SKUs with strong EU track records, View our products.
We’ve learned that consistency beats heroics. A clear sampling plan, right-scope testing, and tidy paperwork is what keeps containers moving and buyers confident. That’s how we run our program for our frozen line and for fresh items like Purple Eggplant and Baby Romaine. If you get the system right once, you’ll use it for every season after.