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An Armchair Guide on Exporting to Germany
By Dietmar Achilles
Germany’s affluent 82 million people and its robust economy make the country a significant target market for U.S. food and beverage exporters. How significant? Consider that, in 1997, U. S. exports of food, feed and forest products to Germany topped $2 billion.
Already making up a third of these agricultural exports, the consumer-oriented product sector is flourishing. With steady growth in this sector expected to continue, substantial opportunities exist for exporters prepared to invest the resources it takes to market their products in Germany.
Before exporting to Germany,
producers should research the country’s import requirements.
With this need in mind, the Foreign Agricultural Service (FAS)
posts in Bonn and Hamburg have outlined relevant aspects of
German and overlapping European Union (EU) food law, labeling,
packaging and certification requirements.
The German marketplace has three unique characteristics:
Since German importers are legally responsible for the products they market in Germany, they have a strong interest in working with exporters to make sure their products meet all import and marketing requirements.
And Germany’s EU membership yields a paperwork break for some U.S. exports. Most EU members now follow EU-harmonized requirements for food marketing, and more often than ever, Germany is adhering to EU standards.
Oddly enough, in Germany, no official agency is responsible for food label registration, so exporters must rely on the private food laboratories for food label review.
Labeling Requirements
Multi-language labels are allowed as long as German is included. The actual information requirements for the labeling are straightforward:
Special labeling requirements apply to food or beverage products with additional claims:
Packaging, Weights and Measures
The German Consumer Packaging
Law identifies mandatory and non-mandatory standard container
sizes for certain products. Most liquids must be sold in
mandatory container sizes. Other products that are packaged in
non-mandatory but privileged standard container sizes do not
require price-per-unit information. If a product is not sold in
the privileged size container, the box must show a per unit
price.
If a package contains less than 250 grams or 250 milliliters, a unit price must be shown for the 100-gram or 100-milliliter unit.
Food Additive Regulations
EU harmonized regulations apply to food additives, coloring and artificial sweeteners. Most are approved only for specific purposes and foods. The names of food additives must appear clearly on the label. The German private food labs mentioned earlier will determine if an additive can be marketed in Germany.
Pesticide Residue Laws
The German Pesticide Residue Law sets maximum tolerances for many pesticides in foods derived from both plants and animals. It establishes import tolerances for many pesticides not approved for use in Germany. Within the EU, pesticide tolerance levels for only a quarter of pesticide residues have been harmonized.
Novel Foods
In Germany, the term "novel foods" is officially applied to foods that are nontraditional and new to market. In vernacular use, the term designates products of bioengineering. So far, Germany has relied on the EU Novel Foods Regulation as the guide for approving foods in this controversial category.
No irradiated foods are allowed in Germany, so cross them off your export list.
"Green Dot" a Must for Packaging
Germany’s increasing waste disposal problems led to a
cooperative effort for the collection and recycling of packaging
materials. The Duales System Deutschland (DSD) 
oversees recycling and disposal in
Germany. It authorizes use of the green dot symbol on packaging
for products sold in Germany, which means the packaging has met
certain requirements that make its disposal easier.
The symbol is not legally required, but marketing a product without it is almost impossible. The importer pays a license fee (amount depends on type and amount of packaging) to the DSD for use of the green dot.
________________________________
The author, an agricultural specialist in the FAS Office of
Agricultural Affairs in Bonn, prepared this article from reports
prepared jointly by two Foreign Agricultural Service field
offices: Office of Agricultural Affairs, American Embassy, Bonn,
Federal Republic of Germany, Tel.: (49-228) 3391. Fax. (49-228)
334-697, and the U.S. Agricultural Trade Office, Hamburg, Federal
Republic of Germany, Tel. (49-40) 414-6070. Fax. (49-40)
414-60720.
Export Certification Requirements
Meat and Poultry. Due to recent changes in EU import regulations, U.S. poultry meat is not currently permitted. Previously, meat and poultry products were exported to Germany from U.S. plants approved by EU veterinarians. These meats were accompanied by an export certificate issued at the slaughtering or processing plant by a USDA meat and poultry inspector.
USDA’s Food Safety and Inspection Service (FSIS) can supply information on German and EU requirements and certification for meat and poultry:
USDA/FSIS/Technical Service
106 S. 15th St.
Rm 904
Omaha, NE 68102
Tel.: (402) 221-7400
Fax: (402) 221-7438
Fruits and Vegetables. All exports of fresh fruits and vegetables and unprocessed or raw nuts to Germany and the EU must be accompanied by a USDA phytosanitary certificate (Form PPQ 577). This certifies that the product is free of insects, plant diseases and other harmful organisms. It is issued following inspection by a USDA Animal and Plant Health Inspection Service (APHIS) inspector. Further information about the process can be obtained from:
USDA/APHIS/Export Certification Unit
4700 River Rd., Unit 140
Riverdale, MD 20737-1239
Tel.: (301) 734-8537
Fax: (301) 734-5786
Seafood Products. Fish and fish products can be exported to Germany only from U.S. plants accepted into the U.S. Food and Drug Administration (FDA), EU Export Health Certificate Program. Information on this program can be obtained from:
FDA/Division of Program & Enforcement Policy/Center for
Food Safety and Applied Nutrition
200 C Street SW
Washington, DC 20204
Tel.: (202) 418-3150
Fax: (202) 418-3196
We Can Help
The 
Foreign
Agricultural Service (FAS) maintains two posts in Germany that
can help answer questions for exporters. The Bonn office oversees
all USDA activities in Germany and is expert on issues involving
German food law. The Hamburg office coordinates FAS marketing
activities in Germany, facilitating trade contacts between U.S.
suppliers and German importers.
Office of Agricultural Affairs
American Embassy, Bonn
PSC 117, Box 385
APO AE 09080-0385
Tel.: (49-228) 339-2133
Fax: (49-228) 334-697
Homepage: http://www.usembassy.de/embassy/fas-and-
U.S. Agricultural Trade Office
Alsterufer 28
20354 Hamburg
Germany
Tel.: (49-40) 414-6070
Fax: (49-40) 4146-0720
Homepage: http://www.usembassy.de/atohamburg
For general questions about German food law requirements, contact:
USDA/FAS/Food Safety & Technical Services Division
Ag Stop 1027
Washington, DC 20250-1027
Tel.: (202) 720-1301
Fax: (202) 690-0677
E-mail: ofsts@fas.usda.gov
The FAS AgExport Services Division offers detailed information on available export services:
USDA/FAS/AgExport Services Division
Ag Stop 1052
1400 Independence Ave., SW
Washington, DC 20250-1052
Tel.: (202) 720-7103
Fax: (202) 690-4374
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