Compliance reviews age badly. The useful ones separate what is stable from what is in motion, and are explicit about which is which. That is what this is.
What has not changed, and will not soon
The structural rules for frozen fruit and vegetables entering the Union are old and stable, and a supplier who builds around them does not have to rebuild every year.
- The quick-frozen regime under Council Directive 89/108/EEC: minus 18 C or colder, with short upward fluctuations treated as exceptions to be recorded.
- Temperature monitoring and record retention under Commission Regulation (EC) No 37/2005.
- Traceability one step back and one step forward under Article 18 of Regulation (EC) No 178/2002.
- HACCP-based procedures under Regulation (EC) No 852/2004.
- Microbiological criteria under Regulation (EC) No 2073/2005 and pesticide residue limits under Regulation (EC) No 396/2005.
- Consumer information under Regulation (EU) No 1169/2011.
- The framework for official controls under Regulation (EU) 2017/625.
None of these have been replaced. If a supplier is failing on one of them, the failure is operational rather than regulatory.
What moves, and where to check it
**Increased official control frequencies.** Regulation (EU) 2019/1793 lists commodity and origin combinations subject to a temporarily increased level of official controls, and its annexes are revised periodically. This is the single most practical thing to re-check before each season, because a change here changes the probability of a physical check and therefore the transit planning. Check the current annexes for your commodity and origin rather than relying on last season’s experience.
**Organic import arrangements.** The organic framework is Regulation (EU) 2018/848, and the arrangements for third country imports have been in transition from an equivalence basis toward a compliance basis, with transitional periods that have been extended. The practical instruction is unchanged in shape and specific in detail: confirm with your control body which route applies to your goods for the current shipment, and confirm that the certificate of inspection can be issued in TRACES NT on that basis. Do not assume the basis used for a previous shipment still applies.
**Digital entry and safety data processes.** The Union’s import control and safety data systems have been introduced in phases, and the phasing has been revised more than once. Whether and when a particular obligation applies to a road consignment from Ukraine is a question for the customs agent handling the declaration, and the answer should be re-confirmed rather than carried over.
**Contaminant limits.** Maximum levels for contaminants are set under Regulation (EC) No 1881/2006 and have been amended repeatedly, including consolidation and recasting. Where a buyer specification cites a limit, check that it cites the current instrument.
What moved on the buyer side, which is not law at all
The largest practical change in the last few seasons is not regulatory. It is that buyer requirements have hardened faster than legislation has.
- GFSI-recognised certification has moved from a large-buyer requirement toward a default expectation across Member States and across buyer sizes.
- Supply chain due diligence questionnaires covering human rights and environmental impacts now arrive with the first specification request rather than after the first order, and German buyers are the most systematic about it.
- Buyers increasingly ask for the temperature record as a matter of routine rather than after a problem, which changes logger placement from a precaution into a deliverable.
- Organic buyers are asking mass balance questions earlier, because a failed mass balance is the failure mode that costs them the most.
Three questions worth asking your buyer this season
A compliance review is more useful when it produces a conversation rather than a filing. Three questions surface most of what has actually changed in a given buyer relationship.
**”Has your certification requirement changed for our category?”** Scheme preference and required scope move quietly, usually because the buyer’s own customer moved first. A certificate that satisfied last season may not cover a newly added product line.
**”What are you now asking suppliers for on due diligence?”** The questionnaires are getting longer and the expected evidence is shifting from policy documents to records and corrective actions. Asking early converts a scramble into a project.
**”What did our temperature records look like from your side?”** Buyers download and archive these now as a matter of routine. Asking to see what they saw is the cheapest quality audit available, and it turns the record from a defensive document into a commercial one.
How to use this
Treat the stable list as the design basis for the quality system and the moving list as a seasonal checklist with named owners.
- Before each season: current control frequencies for the commodity and origin; current organic import basis with the control body; current entry procedure with the customs agent; certification scope against the actual product list.
- Before each shipment: certificate validity, certificate of inspection in TRACES NT where organic, commodity code confirmation, document set complete before the truck reaches the border.
Nothing on this page should be taken as legal advice, and every instrument named here should be read in its current consolidated version before a decision is based on it.