# How to Write a Product Spec Sheet for Your Botanicals — A Practical Guide for EU B2B Suppliers

Why This Document Is Deal-Critical in EU Botanical Procurement

EU botanical importers face a specific and costly set of problems at the border and in the QA lab. Shipments are held at customs when Certificates of Analysis (CoA) are missing, incomplete, or reference non-accredited laboratories. Pesticide MRL exceedances under Regulation (EC) No 396/2005 trigger automatic rejection and RASFF notifications. Heavy metal contamination above the maximum levels set in Regulation (EC) No 1881/2006, as amended by Regulation (EU) 2023/915, results in destruction orders or costly re-export. For QA managers at European importers, a well-structured product specification sheet is the first filter that determines whether a supplier conversation continues or ends.

This guide is written for producers, cooperatives, and regional aggregators in Romania, Bulgaria, Türkiye, Serbia, and the broader Balkan and Eastern European supply zone who want to supply the EU market professionally. It tells you exactly what to put in a spec sheet — with concrete benchmark figures, regulatory references, and the certification language that EU procurement teams actually look for.

---

What Is a Product Specification Sheet?

A product specification sheet — sometimes called a technical data sheet or product dossier — is a structured document of one to three pages that gives a potential buyer all material facts about your botanical before they commit to a purchase or request a sample. It functions simultaneously as:

A pre-qualification document for a buyer's QA team
A customs-ready summary of product classification and origin
A baseline for contract negotiation on quality parameters
Evidence of regulatory readiness for the EU market

Without it, buyers cannot share your offer internally, cannot begin their QA review, and cannot obtain an import licence or phytosanitary clearance. A missing or vague spec sheet is the single most common reason early-stage supplier conversations stall.

---

The 9 Sections Every Botanical Spec Sheet Needs

1. Product Identity

Be precise. Vague descriptions delay or kill deals.

Common name: e.g. Rosehip
Botanical Latin name and authority: *Rosa canina* L.
Plant part used: Whole dried fruit (hips), seeds removed / with seeds — state clearly
Country of origin: e.g. Bulgaria
Region of harvest: e.g. Rhodope Mountains, Southern Bulgaria
Harvest year and season: e.g. September–October 2024
Production method: Wild-harvested / organically cultivated / conventionally cultivated — mandatory distinction for EU customs and QA
Processing method: Naturally dried / hot-air dried at ≤ 45°C / freeze-dried — directly affects CoA parameters

---

2. Physical and Organoleptic Characteristics

| Parameter | Specification |

|---|---|

| Appearance | Whole or cut-and-sifted dried hips; orange-red to dark red |

| Odour | Characteristic, faintly fruity; free from mould or off-odours |

| Taste | Mildly tart and sweet; free from bitterness or rancidity |

| Moisture content | ≤ 10.0% w/w (Ph. Eur. 2.2.32 loss on drying method) |

| Foreign matter | ≤ 2.0% (Ph. Eur. 2.8.2) |

| Broken / damaged pieces | ≤ 5.0% |

| Particle size (cut material) | 2–5 mm sieve fraction |

These figures are aligned with European Pharmacopoeia (Ph. Eur.) general monograph standards and ESCOP monograph guidance where applicable. Buyers using Ph. Eur. 01/2023:1510 (*Rosae pseudofructus*) will test against exactly these parameters.

---

3. Microbiological and Chemical Quality Parameters

This section must reference the testing method and limit for each parameter. All testing should be carried out by an ISO/IEC 17025-accredited laboratory.

#### Microbiological Limits (aligned with Ph. Eur. 5.1.8 — non-sterile herbal products)

| Parameter | Acceptance Criterion | Test Standard |

|---|---|---|

| Total Plate Count (TPC / TAMC) | ≤ 100,000 CFU/g | ISO 4833-1 |

| Total Yeast and Mould Count (TYMC) | ≤ 1,000 CFU/g | ISO 21527-1 |

| *Escherichia coli* | Absent / 1g | EN ISO 16649-2 |

| *Salmonella* spp. | Absent / 25g | EN ISO 6579-1 |

| *Staphylococcus aureus* | ≤ 100 CFU/g | EN ISO 6888-1 |

#### Heavy Metal Maximum Levels

Specify compliance with Regulation (EC) No 1881/2006 as amended by Regulation (EU) 2023/915, which sets binding maximum levels for lead, cadmium, and inorganic arsenic in herbs and herbal infusions:

| Metal | Maximum Level | Regulation Reference |

|---|---|---|

| Lead (Pb) | ≤ 3.0 mg/kg (dried herb) | EU 2023/915 amending EC 1881/2006 |

| Cadmium (Cd) | ≤ 1.0 mg/kg | EU 2023/915 amending EC 1881/2006 |

| Inorganic Arsenic | ≤ 1.0 mg/kg | EU 2023/915 amending EC 1881/2006 |

| Mercury (Hg) | ≤ 0.1 mg/kg (good practice limit) | EC 1881/2006 general provisions |

Test method: ICP-MS per EN 15763 or equivalent accredited method.

#### Pesticide Residues

All plant material entering the EU must comply with Regulation (EC) No 396/2005 on maximum residue levels (MRLs) for pesticides. For dried herbs, a concentration factor applies — buyers will calculate MRLs on a fresh-weight basis and then apply the processing factor. Your CoA must report pesticide screening results from an ISO/IEC 17025 lab using multi-residue GC-MS/MS and LC-MS/MS methods covering at minimum 300+ active substances.

State clearly: *"Multi-residue pesticide screening carried out per [laboratory name, accreditation number]. Results available on request / attached."*
If certified organic: pesticide CoA is still required. Organic status under Regulation (EU) 2018/848 does not exempt from MRL verification at the border.

---

4. Certifications and Regulatory Status

#### Organic Certification

If applicable, state:

Certifying body (e.g. Ecocert, CERES, Lacon, ICEA, Control Union)
Certificate number and validity period
Compliance standard: Regulation (EU) 2018/848 on organic production and labelling

> Example: *"Certified organic, certificate no. [XX-ORG-XXXXXX], issued by CERES GmbH, valid through 31.12.2025, compliant with Regulation (EU) 2018/848."*

Without a valid certificate issued by an EU-recognised control body, organic claims have no legal standing in the EU and may constitute fraud.

#### Food Safety Management

HACCP compliance (mandatory under EC 852/2004 for all food business operators)
ISO 22000:2018 / FSSC 22000 / BRC Global Standard Issue 9 — state which applies
Country of origin certificate (EUR.1 or Form A / GSP certificate depending on trade agreement)

---

5. Regulatory Status — Novel Food, CITES, Nagoya, and Phytosanitary Requirements

This section is deal-critical and is routinely omitted by smaller suppliers. EU importers cannot legally place a product on the market without confirming each of the following.

#### Novel Food Screening (EFSA)

Before any botanical is sold in the EU as a food ingredient, it must be verified against the EFSA Union list of novel foods and the EFSA compendium of botanicals. If the species or plant part has no documented history of food use in the EU prior to 15 May 1997, it is classified as a Novel Food under Regulation (EU) 2015/2283 and requires pre-market authorisation.

Include a statement confirming the species is not a Novel Food, or state that a Novel Food dossier has been filed, with reference number.
Common species such as *Rosa canina*, *Aronia melanocarpa*, and *Sambucus nigra* flower are established in the EFSA compendium with documented EU food use history.

#### CITES and Nagoya Protocol

CITES (Convention on International Trade in Endangered Species): If your species is listed on CITES Appendix I, II, or III (check UNEP-WCMC CITES database), an export permit is required from your country's national authority. Failure to provide this results in seizure at EU border inspection posts.
Nagoya Protocol (CBD/ABS): Wild-harvested botanical material may trigger obligations under the Nagoya Protocol on Access and Benefit-Sharing, implemented in the EU via Regulation (EU) No 511/2014. Suppliers must declare whether genetic resources and associated traditional knowledge were accessed lawfully in the provider country and be able to provide an internationally recognised certificate of compliance (IRCC) if required.

#### Phytosanitary Documentation and TRACES NT

All consignments of plant material entering the EU must be accompanied by:

A phytosanitary certificate issued by the national plant protection organisation (NPPO) of the country of export, confirming freedom from regulated pests
Pre-notification via TRACES NT (Trade Control and Expert System — New Technology) before the consignment arrives at the EU border inspection post (BIP)
Physical inspection is carried out by EU official control authorities under Regulation (EU) 2017/625 on official controls along the food chain

Importers are responsible for ensuring all documentation is in order before the goods ship. Suppliers who can confirm phytosanitary certificate availability and who understand the TRACES NT pre-notification requirement significantly reduce importer risk and are preferred vendors.

---

6. Packaging, Labelling, and Storage

Primary packaging: Double food-grade low-density polyethylene (LDPE) inner bag, heat-sealed
Secondary packaging: Woven polypropylene (PP) outer sack or kraft paper sack
Net weight per unit: State in kg (e.g. 10 kg, 20 kg, 25 kg bags)
Minimum Order Quantity (MOQ): State clearly (e.g. 500 kg per order; 1 full pallet minimum for international shipment)
Labelling per unit: Product name, botanical name, plant part, country of origin, lot number, production date, best-before date, net weight, storage conditions, supplier name and address
Storage conditions: Cool, dry, well-ventilated warehouse; temperature ≤ 20°C; relative humidity ≤ 60%; away from direct light and strong odours
Shelf life: State from production date (e.g. 24 months for dried rosehip at specified storage conditions)

---

7. Logistics and Trade Classification

| Field | Details |

|---|---|

| HS Code | 0813.40.95 (dried rosehip, other) — verify with your customs broker |

| Available Incoterms | EXW, FCA, DAP — state which you can offer |

| Typical lead time | State in working days from order confirmation to loading |

| Seasonal availability | State harvest period and forward-contract availability window |

| Transport modes | Road (FTL/LTL), sea (FCL/LCL), courier (samples ≤ 5 kg) |

| Phytosanitary cert | Available from [national NPPO]; typical issue time [X] working days |

---

8. Company Information and Traceability

Legal entity name and registration number
Physical address, country
EU Food Business Operator registration number (

How to Write a Product Spec Sheet for Your Botanicals