Not always, but usually. Fumigation is not a blanket legal requirement for grain entering the European Union; it is a risk-management measure that becomes necessary when the importing country’s plant health requirements demand a treatment, when the cargo has any insect activity, or when the voyage and storage conditions make infestation likely before discharge. In practice most bulk grain moving long distances is fumigated, because the cost of the treatment is trivial against the cost of a live-insect finding at discharge.
The working fumigant into the Union is phosphine, applied as aluminium or magnesium phosphide, which releases gas on contact with moisture in the air. Methyl bromide, the industry default for decades, is not available for this use in the Union under Regulation (EC) No 1005/2009 on ozone-depleting substances, so an offer that quotes it should be questioned.
What matters more than whether the cargo was fumigated is whether the record proves the treatment could have worked. A usable fumigation certificate states the fumigant and formulation, the dose rate, the start and end of exposure, the ambient temperature during treatment, the ventilation period and the licensed operator. Temperature is the parameter most often missing and the most consequential: phosphine acts slowly and its efficacy falls sharply as temperature drops, so a normal exposure period applied to cold grain may not have killed anything at all.
Two further points. In-transit fumigation – dosing the cargo and sealing it so the exposure happens during the voyage – requires the carrier’s agreement and correct dangerous goods handling, and undeclared in-transit fumigation creates a genuine safety hazard for the people opening the hold. And fumigation kills insects; it does not remove dead insects and fragments, which are counted against a separate tolerance, so a fumigated cargo can still fail a cleanliness clause.
For the buyer, the contractual work is to agree where the insect inspection happens, on what sample, and what a live finding triggers. A live finding at discharge with no agreed procedure is a dispute; with an agreed procedure it is a claim with a defined route.