Importing olive oil from Tunisia to the EU
Tunisia is one of the largest olive oil suppliers in the world and ships both bulk oil for blending and bottled oil to the EU. A workable import deal turns on four things: which grade you are buying, whether you can use the preferential quota under the EU-Tunisia agreement, which EU food law and contaminant rules apply, and how the oil is shipped and documented. This is a practical overview with pointers to the sources you should check before each contract.
By Hiram Trade Editorial Desk
- Published
8 min read
Olive oil grades
The EU defines olive oil categories by law, not by marketing claims. The categories in Regulation (EU) No 1308/2013 (Annex VII, Part VIII) are:
| Category | What it is | Can be sold to consumers as |
|---|---|---|
| Extra virgin olive oil | mechanical extraction, free acidity <= 0.8%, no sensory defects | yes |
| Virgin olive oil | mechanical extraction, free acidity <= 2.0%, limited defects | yes |
| Lampante olive oil | virgin oil not fit for consumption as is | no, must be refined first |
| Refined olive oil | refined from lampante | not on its own |
| Olive oil (blend) | refined olive oil plus virgin | yes |
| Crude/refined olive-pomace oil | from pomace, solvent-extracted | pomace-oil blend only |
Buying "virgin for blending" is in practice buying input for a bottler. Define the category precisely in the contract, because the category drives both the EU marketing standard and the tariff line.
Tariff code and the Tunisia preference
Olive oil falls under HS heading 1509; oils obtained only from olives that are not 1509 (for example pomace oil) fall under 1510. The CN and TARIC split these by category (virgin vs other) and packaging. Confirm the duty rate and the exact 10-digit code in the European Commission's Access2Markets tool before you contract. See our guide to HS and CN codes.
Under the EU-Tunisia Association Agreement a preferential tariff-rate quota (TRQ order number 09.4032) lets 56,700 tonnes of Tunisian virgin olive oil per year enter the EU at zero duty, and an import licence is required to use the reduced rate. The quota is first-come and in recent seasons has been exhausted early (the ninth year running by 2025/26), so check its remaining balance in TARIC before you rely on it. Outside the quota the full specific duty applies - of the order of EUR 124.50 per 100 kg; confirm the current rate in TARIC/Access2Markets. Bulk oil for re-export can also enter under the inward processing procedure. The EU has in the past opened temporary extra quotas (for example 35,000 tonnes for 2016-2017 under Regulation (EU) 2016/605).
EU marketing standard and quality parameters
Marketing standards and conformity checks for olive oil are set by Commission Delegated Regulation (EU) 2022/2104 and Commission Implementing Regulation (EU) 2022/2105 (which replaced the old Regulation (EEC) No 2568/91). Virgin grades are judged on both chemical and organoleptic criteria. Contracts usually specify:
- free acidity (% expressed as oleic acid);
- peroxide value;
- UV absorbance (K232, K270 and delta-K);
- organoleptic assessment by an approved panel (median of defects and fruitiness) for virgin grades;
- fatty acid composition and, for extra virgin, ethyl esters;
- sterol and wax content (used to detect pomace oil or other-oil adulteration).
Write the test methods and the umpire laboratory into the contract. The International Olive Council (IOC) trade standard is a common reference alongside the EU standard. Olive oil is one of the most adulteration-prone commodities, so authenticity testing (fatty acids, sterols, waxes) and a clear chain of custody matter as much as price.
EU food law and contaminants
An EU importer placing food on the market is a food business operator and carries the compliance duty. Key acts:
- Regulation (EC) No 178/2002 (General Food Law): food safety, "one step back, one step forward" traceability, duty to withdraw unsafe food.
- Regulation (EC) No 852/2004 (food hygiene): hygiene rules and HACCP-based procedures.
- Commission Regulation (EU) 2023/915 (contaminants): maximum levels relevant to olive oil include polycyclic aromatic hydrocarbons (PAHs) and 3-MCPD and glycidyl fatty acid esters in oils; work from the current consolidated text.
- Regulation (EC) No 396/2005: pesticide maximum residue levels.
- Regulation (EU) 2017/625 (official controls): the framework for checks on imported food.
Mineral oil hydrocarbons (MOSH/MOAH) are an active EU concern for vegetable oils; follow the latest Commission guidance. Organic oil falls under Regulation (EU) 2018/848 and needs an electronic certificate of inspection in TRACES. Check the requirements for your CN code and origin in Access2Markets. Oil for cosmetic or technical use falls under other rules this article does not cover.
Documents
A typical set for a sea shipment from Tunisia:
- commercial invoice and packing list;
- bill of lading or other transport document;
- certificate of analysis for the lot from an independent or accredited laboratory, covering the EU marketing-standard parameters;
- proof of preferential origin to claim the quota: a movement certificate EUR.1, or an origin declaration where the agreement and the PEM rules of origin allow it;
- insurance certificate if the seller insures;
- pre-shipment inspection or panel-test report if agreed;
- for organic oil: the TRACES certificate of inspection.
Do not assume a document is or is not needed: list the documents in the contract and confirm them with your customs broker. For the preference, the origin rules (wholly obtained / sufficient processing under the PEM Convention) must actually be met - a Tunisian invoice is not proof of Tunisian origin.
Logistics: bulk tank, flexitank or packed
| Option | When | Watch out for |
|---|---|---|
| Ship's tanks (bulk) | large lots for bottlers | previous-cargo rules, tank cleanliness, temperature |
| Flexitank in a 20' container | medium bulk lots | single-use food-grade bag, previous-cargo history |
| ISO tank container | smaller high-quality lots | cost of returning the empty tank |
| Bottled / cans / BIB | retail-ready, small lots | higher unit cost, labelling to EU standard |
For edible oils carried by sea in tanks not reserved for food, Commission Regulation (EU) No 579/2014 allows this provided the previous cargo is on the list of acceptable substances and the master keeps records of the three previous cargoes and the cleaning carried out. Ask for these records in the contract. Olive oil quality is sensitive to heat, light and oxygen; agree temperature control and nitrogen blanketing for bulk where relevant.
Incoterms for olive oil
- Containers (flexitank, ISO tank): FCA terminal at the port of loading, or CPT or CIP to the destination port. Avoid FOB and CIF for containers.
- Bulk on a vessel: FOB, CFR or CIF are appropriate.
- Delivered to plant: DAP or DPU if the supplier has an EU logistics partner.
Under CIF, the minimum insurance is Institute Cargo Clauses (C). See our guide to Incoterms 2020.
Checklist before signing
- Category defined by the EU legal name, not a marketing term.
- Specification with EU marketing-standard parameters, test methods and umpire laboratory.
- Authenticity testing (fatty acids, sterols, waxes) agreed.
- TARIC code, duty rate and the current Tunisia quota balance confirmed.
- Preferential origin proof (EUR.1 or origin declaration) and that the origin rules are met.
- Current contaminant and MRL limits for your use checked.
- Previous-cargo history, temperature control and packing agreed.
On Hiram you can post an olive oil request with a full specification and compare quotes from Tunisian and other Mediterranean suppliers by total landed cost. Go to the market.
Sources
- Regulation (EU) No 1308/2013 (CMO, olive oil categories, Annex VII Part VIII): https://eur-lex.europa.eu/eli/reg/2013/1308/oj (opens in a new tab)
- Commission Delegated Regulation (EU) 2022/2104 (olive oil marketing standards): https://eur-lex.europa.eu/eli/reg_del/2022/2104/oj (opens in a new tab)
- Commission Implementing Regulation (EU) 2022/2105 (conformity checks and characteristics of olive oil): https://eur-lex.europa.eu/eli/reg_impl/2022/2105/oj (opens in a new tab)
- Regulation (EC) No 178/2002 (General Food Law): https://eur-lex.europa.eu/eli/reg/2002/178/oj (opens in a new tab)
- Regulation (EC) No 852/2004 on the hygiene of foodstuffs: https://eur-lex.europa.eu/eli/reg/2004/852/oj (opens in a new tab)
- Commission Regulation (EU) 2023/915 on maximum levels for certain contaminants in food: https://eur-lex.europa.eu/eli/reg/2023/915/oj (opens in a new tab)
- Regulation (EC) No 396/2005 on pesticide maximum residue levels: https://eur-lex.europa.eu/eli/reg/2005/396/oj (opens in a new tab)
- Commission Regulation (EU) No 579/2014 (transport of liquid oils and fats by sea): https://eur-lex.europa.eu/eli/reg/2014/579/oj/eng (opens in a new tab)
- Regulation (EU) 2017/625 on official controls: https://eur-lex.europa.eu/eli/reg/2017/625/oj (opens in a new tab)
- Regulation (EU) 2018/848 on organic production: https://eur-lex.europa.eu/eli/reg/2018/848/oj (opens in a new tab)
- European Commission, Access2Markets - Guide for import of goods: https://trade.ec.europa.eu/access-to-markets/en/content/guide-import-goods (opens in a new tab)
- EU-Tunisia Association Agreement (trade relations overview): https://policy.trade.ec.europa.eu/eu-trade-relationships-country-and-region/countries-and-regions/tunisia_en (opens in a new tab)
- Commission Implementing Regulation (EU) 2016/605 (temporary additional olive oil quota 2016-2017): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016R0605 (opens in a new tab)
- CBI (Netherlands Ministry of Foreign Affairs), Entering the European market for olive oil: https://www.cbi.eu/market-information/processed-fruit-vegetables-edible-nuts/olive-oil/market-entry (opens in a new tab)
- International Olive Council, trade standard on olive oils: https://www.internationaloliveoil.org/ (opens in a new tab)
This article is for information only and is not legal, tax or customs advice. Rules and rates change: check the current official sources or consult an adviser before you decide.