For ordinary dried Camellia sinensis tea placed on the EU market, start the contaminant plan with two tea-specific entries: pyrrolizidine alkaloids (PAs) at 150 µg/kg and perchlorate at 0.75 mg/kg. Then confirm whether the product is plain tea, flavoured or mixed tea, instant tea, a powdered extract, a liquid product, or food intended for infants and young children. A generic contaminants panel cannot replace product classification, correct analyte definitions, representative sampling and a written release rule.
Freeze the product before choosing the tests
Importers often request a familiar laboratory package before fixing how the tea will be sold. Reverse that order. Record the legal entity placing the food on the market, destination Member State, botanical identity, physical form, ingredients, intended consumer, label claims and end use. The current consolidated EU contaminant regulation applies maximum levels to food as placed on the market unless its Annex says otherwise.
| Decision field | Question to answer | Why it changes the plan |
|---|---|---|
| Food identity | Plain Camellia sinensis, flavoured tea, or a mixture with fruit or herbs? | Mixed products can require ingredient proportions and Article 3 calculations rather than copying the plain-tea line. |
| Physical form | Loose leaf, tea bag, instant tea, powdered extract or ready-to-drink liquid? | The Annex defines the relevant tea entry and, for PA in powdered tea extracts, states a concentration factor of four. |
| Consumer | General population or specifically infants and young children? | The PA entries for infant and young-child products are different and stricter. |
| Destination | Which EU country and which customer programme? | EU law is the floor; national enforcement priorities and customer specifications may add checks. |
| Decision point | Supplier approval, pre-shipment release, import hold or retail release? | The sample owner, timing, laboratory, decision rule and remedy must fit the commercial control point. |
The current EU legal snapshot
Pyrrolizidine alkaloids: check the defined sum, not one marker
Section 2.4 of the consolidated Regulation (EU) 2023/915 sets a maximum of 150 µg/kg for ordinary tea and flavoured tea as dried product. The definition covers dried leaves, stalks and flowers, in sachets or bulk, used to prepare liquid tea, and includes instant teas. For powdered tea extracts, the Annex requires a concentration factor of four. Dried products intended for infants and young children have a 75 µg/kg entry; the corresponding liquid-product entry is 1.0 µg/kg.
The 150 µg/kg result is not “total PA” under any laboratory's private definition. The Regulation defines a lower-bound sum of 21 named PAs, with 14 additional substances recognised for possible co-elution. Individually resolved PAs must be quantified and included; values below the LOQ are treated as zero. Name the EU regulatory sum, require the analyte list and show the calculation.
Commission Implementing Regulation (EU) 2023/2783 supplies the official-control sampling and analytical framework for plant toxins. For PAs in dried product it requires an LOQ no higher than 10 µg/kg for each individual PA. A report with a low-looking sum can still be unusable if the panel omits regulated analytes, the matrix is not dried tea, or individual LOQs are too high.
Perchlorate: keep the units and matrix explicit
Section 6.3.2 of Regulation (EU) 2023/915 sets 0.75 mg/kg for dried Camellia sinensis tea. That is 750 µg/kg, but the contract and report should use one agreed unit to avoid a thousand-fold transcription error. Regulation (EC) No 333/2007, in its current consolidated version, provides the official-control sampling and analysis framework for perchlorate and other listed trace elements or processing contaminants.
Do not infer a dry-tea lead or cadmium maximum by copying a line for vegetables, herbs or spices. Absence of a tea-specific line does not mean “no risk” or “no obligation”: general food-safety law, another destination rule or a buyer specification can still justify testing. Record that basis instead of labelling every requested parameter an EU legal limit.
Separate six sources of requirements
- Legal requirement: the binding maximum level, product definition and other rules applicable in the destination on the release date.
- Official-control method: the sampling, analytical performance and result interpretation used by authorities. A private pre-shipment test is not an official-control result merely because it cites the same regulation.
- Voluntary standard: for example, laboratory accreditation or a standardised method used to demonstrate competence. It is not automatically law.
- Trade reference: a common panel, historical customer limit or market practice used for comparison. It must not be presented as a current legal threshold without verification.
- Buyer specification: the importer's risk-based analytes, action limits, frequencies and evidence requirements. It may be tighter or broader than law.
- Contract requirement: the agreed responsibility, sampling point, laboratory, decision rule, notice duty, retest route and remedy. It becomes enforceable through the signed deal, not through a generic COA heading.
Build a test-to-decision matrix
| Control | Write into the matrix | Release evidence | Stop condition |
|---|---|---|---|
| Product scope | Botanical identity, ingredients, form, consumer group and destination | Approved label/specification and current legal citation | Product does not match the cited legal entry |
| PA panel | Current EU-defined sum, individual analytes, lower-bound calculation and units | Individual results, LOQs and reported regulatory sum | Missing analyte, unsuitable LOQ or unexplained sum |
| Perchlorate | Dried-tea matrix, mg/kg unit, legal maximum and buyer action limit | Quantitative result with method, LOQ and uncertainty information | Unit, matrix or decision basis is unclear |
| Sampling | Defined lot, increments, aggregate sample, laboratory sample, seals and custody | Sampling record linked to the tested lot | Single convenience scoop or broken lot identity |
| Decision rule | How uncertainty, recovery, rounding and results near the limit are handled | Pass, clarify or fail signed by the authorised reviewer | No prewritten rule or conflicting supplier/buyer rules |
| Change control | Retest triggers for origin, field, blend, process, season, lab or packaging changes | Change notice and completed reapproval | Affected lot shipped before review |
An eight-step buyer method
- Classify the food. Freeze the identity, form, ingredients, consumer group, destination and intended sale format.
- Capture the legal snapshot. Save the current consolidated regulation, exact Annex points, effective date and check date. Recheck before each new programme or after a regulatory change.
- Map analytes to definitions. For PA, attach the regulated analyte/sum definition and lower-bound rule. For perchlorate, fix the dried-tea matrix and unit.
- Qualify the laboratory. Verify that the accredited scope and method cover dried tea and the required analytes, and that the LOQs support the decision. Use the detailed guide to choosing a laboratory for bulk tea.
- Design the sample. Define the commercial lot and take distributed increments under a documented representative sampling plan. A precise instrument cannot repair a biased sample.
- Prewrite the release rule. State the action limit, treatment of uncertainty and recovery, authority to release, retest conditions and whether the stricter legal or buyer limit controls.
- Review the complete report. Match the lab, method, matrix, sample ID, lot, units, LOQs, analyte coverage and result calculation. A polished certificate of analysis proves only what its evidence chain supports.
- Hold, investigate and control change. Keep unclear or failing lots on hold; investigate source and scope; document corrective action; and trigger reapproval after a material change.
Common buyer mistakes
- Ordering a “full contaminants panel” without recording the legal basis for each item.
- Confusing pesticide MRLs with contaminant maximum levels; the EU pesticide workflow uses a different legal system.
- Testing plain leaf tea while the marketed product is a flavoured mixture, instant product, extract or infant-use product.
- Accepting a PA total without checking analyte coverage, co-elution, lower-bound calculation and individual LOQs.
- Mixing mg/kg and µg/kg in specifications or result comparisons.
- Copying limits from spices, herbs or leafy vegetables onto tea.
- Testing a single top-of-bag scoop and calling the result representative of a container lot.
- Treating “not detected” as zero without reading the LOQ and calculation rule.
- Waiting for a failure before agreeing who pays for confirmation, delay, rework, rejection or disposal.
Practical conclusion
The usable sequence is classify - verify the current law - define analytes and units - qualify the lab - sample the lot - prewrite the decision - review - hold or release. Put that matrix into the bulk green tea purchase specification, not into an informal email after production. For a proposed shipment, send the product form, ingredients, destination, consumer group and required release point before sampling so the evidence plan can be agreed without implying unsupported compliance.
Sources checked 1 September 2026: the current consolidated Commission Regulation (EU) 2023/915, version of 8 October 2025, especially Article 3 and Annex I points 2.4.4-2.4.6 and 6.3.2; Commission Implementing Regulation (EU) 2023/2783 on sampling and analysis for plant toxins; the current consolidated Regulation (EC) No 333/2007, version of 30 April 2024, covering perchlorate sampling and analysis; and the European Commission's current food contaminants overview. Importers should recheck the current destination rule and competent-authority guidance before each programme.
