Dried herbs and spices arrive with a microbiological load that reflects where they were grown. They are field crops, harvested from soil, dried in contact with air and often handled several times before they reach a processing plant. Total plate counts in the millions per gram are normal on untreated leaf, and spore-forming organisms survive conditions that kill most vegetative bacteria. If the spice goes into a product that is subsequently cooked, that load is a specification question. If it goes into a product with no kill step – a seasoning sprinkled on a finished snack, a dry rub, a supplement capsule – it is a safety question.
Three answers exist: accept the load and control it downstream, treat with saturated steam, or irradiate. This guide is about the third, because it is the one surrounded by the most confusion and the one with the clearest legal framework.
The two directives
EU food irradiation rests on two instruments adopted on the same day.
Directive 1999/2/EC is the framework. It sets the general and technical rules: the conditions under which treatment may be authorised, the requirement that irradiation facilities be approved and listed, the record-keeping obligations, the rule that treatment may not be used as a substitute for hygiene or good manufacturing practice, and – the provision most relevant to a buyer – the labelling requirement.
Directive 1999/3/EC establishes the Community positive list, meaning the list of foods that may be irradiated and marketed freely throughout the Union. That list contains exactly one entry: dried aromatic herbs, spices and vegetable seasonings, at a maximum overall average absorbed dose of 10 kGy.
That is the whole EU-wide permission. Not dried mushrooms, not dried fruit, not nuts, not grains, not poultry. One category.
The complication: national authorisations
Harmonisation was intended to go further and stopped. Directive 1999/2/EC allowed Member States that had national authorisations in place for other foods before harmonisation to maintain them, subject to conditions, pending completion of the positive list that was never completed. The result is a two-layer picture:
- the single harmonised category, which may be irradiated and traded anywhere in the Union;
- a set of additional foods authorised in individual Member States, which may lawfully be irradiated and marketed in those states.
The Commission publishes the list of authorised facilities and of national authorisations, and Member States report annually on the quantities treated. For a buyer, the practical rule is straightforward: do not assume that a treatment lawful in one Member State is lawful in your market, and do not assume that a product category outside the harmonised entry can be irradiated at all. Check the current position for your specific product and destination before it becomes a customs conversation.
Imports from third countries are permitted only where the treatment was carried out in a facility approved by the Union for that purpose, which means an approved facility list check is part of supplier approval, not an afterthought.
Labelling is not optional
Where a food or a food ingredient has been treated with ionising radiation, Directive 1999/2/EC requires the fact to be declared. The wording is “irradiated” or “treated with ionising radiation”.
Three points are routinely misunderstood.
It applies to ingredients. An irradiated spice used in a compound food has to be indicated in the ingredient list, even though the quantity is small and the treatment was applied upstream. There is no threshold below which the declaration disappears.
It applies to bulk trade. Products sold to a processor rather than to a consumer carry the declaration on the accompanying documents.
The Radura symbol is not the EU requirement. The international logo used in several jurisdictions may appear, but the EU obligation is the wording. A buyer relying on the absence of a symbol to conclude that a lot was untreated is relying on the wrong thing. The Radura symbol and what it means covers the point in short form.
Detection is possible. Standardised analytical methods exist for identifying irradiated foods, and official control laboratories use them. A false declaration is therefore a detectable fraud rather than an unverifiable one, which matters when you are assessing supplier risk.
What irradiation does and does not do
It reduces microbial load, including spore formers at the higher end of the permitted dose range, without raising the product temperature significantly. That is the entire commercial attraction: the aroma penalty is small compared with a thermal process.
It does not make the product sterile, and it does not compensate for poor hygiene. Directive 1999/2/EC says so explicitly, which is worth quoting to a supplier who treats it as a rescue for a bad lot.
It does not eliminate mycotoxins. Aflatoxins and ochratoxin A are chemically stable and are not destroyed at food irradiation doses. A treated lot with a mycotoxin problem still has a mycotoxin problem, and the maximum levels in Commission Regulation (EU) 2023/915 still apply. Aflatoxin risk in spices explains where the exposure sits.
It does affect the product, at the margin. Some loss of volatile oil and some colour change are reported depending on the species and the dose, though the effect is smaller than that of a thermal treatment delivering an equivalent reduction.
The alternative: saturated steam
Steam treatment is the mainstream alternative in the European market and the reason most EU-supplied spices are not irradiated at all.
The process exposes the product to saturated steam under controlled pressure for a short, precisely defined period, then removes the added moisture by immediate drying. It is a thermal process, so it costs more volatile oil and more colour than irradiation at an equivalent log reduction, and it adds a re-drying step that has to be controlled or the product leaves with a moisture problem it did not arrive with. In exchange it carries no declaration obligation and no consumer-facing question.
| Irradiation | Saturated steam | |
|---|---|---|
| EU legal basis | Directives 1999/2/EC and 1999/3/EC, one harmonised category, 10 kGy overall average maximum | No specific authorisation regime; a process step under general food hygiene law |
| Label declaration | Mandatory wording, including for ingredients | None |
| Aroma impact | Lower | Higher, and species-dependent |
| Moisture impact | None | Adds moisture that has to be removed again |
| Organic compatibility | Not permitted under the EU organic regulation | Permitted |
| Retailer acceptance in the EU | Frequently excluded by private specification | Standard practice |
The organic row deserves emphasis. Irradiation is not compatible with organic production under the EU organic regulation, so an organic programme removes the option entirely. How steam sterilisation works sets out the process, and irradiated against non-irradiated spices works through the commercial comparison.
Ethylene oxide, and why it is not on this list
Fumigation with ethylene oxide is not an authorised treatment for food in the Union, and residues of it in spices, seeds and additives have triggered extensive recalls and border enforcement in recent years. It appears here only to be excluded: a supplier offering a fumigated product for the EU market is offering a non-compliant product, and the question should be asked explicitly at supplier approval rather than assumed away.
Practical steps for a buyer
- Decide your position and write it in. “Not treated with ionising radiation” is a legitimate specification clause and most EU retail programmes carry one. If you accept treatment, say so, and name the maximum dose and the facility requirement.
- Require the declaration in the documentation, not just on the label, so that the information reaches your own labelling team.
- Check the facility approval for imported treated product. Union approval of the facility is a condition of import, and it is verifiable.
- Separate the sterilisation question from the mycotoxin question. They are answered by different controls and a treated lot is not a safe lot on that axis.
- Ask what the untreated microbiological load actually is, because in many applications with a downstream cook step, no treatment is needed and you are paying for a process you do not require.
- Read the limits in the instrument. Dose limits, maximum levels and authorisation lists change by amendment, and the consolidated text on the day of shipment is the one that governs.