Who buys fennel, and in what quantity

2024 trade in whole fennel seed under HS 0909.61:

India is the largest importer and the largest exporter at the same time

India leads both sides of this trade: 22,423 tonnes imported and 73,591 tonnes exported, the latter worth USD 87.72 million. Egypt is the second exporter at 12,231 tonnes for USD 58.81 million.

The unit values tell you what is actually happening, and they are not flattering to us. India exports at roughly USD 1.19/kg and imports at roughly USD 3.56/kg. Egypt exports at roughly USD 4.81/kg. India is the volume origin in fennel, not the premium one. Egyptian fennel commands around four times the Indian export unit value, and India itself buys in higher-value material it does not grow to its own top specification.

If what you need is pharmacopoeia-grade sweet fennel for a branded tea, Egypt is the origin with the price and the reputation to match, and you should price us against it rather than assume India is automatically the answer. Where India wins is scale, continuity of supply, organic group certification at volume, and cost per kilo of volatile oil. Those are real advantages. They are not the same advantage as being the premium origin.

The Annex II problem, and why organic does not exempt you

Most spices from India that face EU scrutiny sit in Annex I of Regulation (EU) 2019/1793, which simply raises the share of consignments subject to identity and physical checks at the border. Fennel does not sit there.

Fennel falls under CN 0909 — seeds of anise, badian, fennel, coriander, cumin or caraway, and juniper berries — and the India entry for that heading is in Annex II, Part 1, row 9, in the consolidated text as it stands at 18 February 2026. Annex II is the special entry conditions tier. It is materially harder, and the difference is worth setting out in full because it changes your costs and your lead times.

None of this is waived by an organic certificate. The regulation lists by CN code and country of origin; it does not look at organic status. Your organic fennel needs the full Annex II file in addition to its NPOP transaction certificate and its EU certificate of inspection. If a supplier quotes you organic fennel and does not mention Annex II, they either have not shipped it to Europe recently or they are leaving the hardest part out of the conversation.

For contrast, cumin from the same origin sits in Annex I at 30 per cent checks — a higher check rate but no official certificate and no mandatory pre-shipment analysis. More checks, less paperwork. Fennel is the other way round, and the paperwork is what causes the delays.

The four-month clock is the one that catches people

An official certificate valid for four months from issue sounds generous until a vessel is rolled, a transhipment slips, or a booking moves across a congested period. The certificate is issued at origin, before the goods move. If the consignment arrives at the border control post after the certificate has expired, the document no longer does its job. Build the margin into your shipping schedule and agree in the contract who bears the cost of re-certification if the sailing changes.

Ethylene oxide, and why you should ask for the split

The hazard recorded against the India entry for CN 0909 is pesticide residues, and the footnote specifies ethylene oxide. The EU residue definition for it is the sum of ethylene oxide and 2-chloroethanol, expressed as ethylene oxide.

That definition matters more than it looks. Two different compounds are measured, added together and reported under a single name. A certificate of analysis that says “ethylene oxide: detected” therefore does not tell you which of the two was actually present. Most analytical methods can distinguish them, and the limit of quantification is 0.01 mg/kg.

So ask for the split, not just the sum. It is a one-line request to the laboratory and it changes what you know. Ethylene oxide is prohibited on food in the EU and prohibited under every organic standard, so a result driven by 2-chloroethanol rather than by ethylene oxide itself is a different conversation about a different question — one about materials, storage history and the supply chain the goods passed through, rather than about what was applied to the crop.

We are not offering that as an excuse. A consignment that fails, fails. We are saying that if you are going to investigate a positive result properly, the sum alone will not let you.

Estragole: a demand risk, not only a compliance risk

Estragole occurs naturally in both sweet and bitter fennel. It is not an additive, not a residue and not something a producer puts there.

In July 2025 EFSA published a draft opinion on preparations from the fruits of sweet and bitter fennel. The conclusions, as reported at the time: estragole is genotoxic and carcinogenic, no safe level of exposure could be established from the available data, and the populations flagged were babies, young children, breastfed infants and fetuses exposed through pregnant or lactating women. The products in scope included infusions, spice mixes and food supplements. The review followed concerns raised by German authorities about fennel seed products intended for infants. Preparations from which estragole has been removed, or in which it is undetectable, were not considered to pose a health risk. The draft went out for public consultation until 25 September 2025.

We have not been able to verify what has happened to that opinion since, so treat the above as the position at the draft stage and confirm the current status before you act on it. What we will say is this: the industry response has argued that assessing an isolated molecule ignores the matrix effect of the whole plant and that long traditional use shows no population-scale harm. That is a reasonable argument and it may prevail. It may also not.

Either way, the commercial point for a buyer is that this is a demand-side risk and it is concentrated in exactly the highest-value end uses: infant and children’s teas, herbal infusions and food supplements. If your fennel programme is built on those applications, the question to put to your regulatory affairs team is not whether you can source compliant fennel today — you can — but what your product looks like if estragole-bearing fennel preparations are restricted in those categories. That is a conversation worth having a year early rather than a month late.

Specification: what to write into the contract

A volatile oil figure without a method is not a specification. Steam distillation under ISO 6571 and a solvent-extraction figure are not interchangeable, and the anethole and fenchone percentages are proportions of the oil, not of the seed — a lot can have excellent anethole ratios and still be thin on total oil. Specify both.

The three commercial grades

The organic paperwork, on top of Annex II

Fumigation, and what organic leaves you with

Organic standards prohibit synthetic chemical fumigants and ethylene oxide, and ethylene oxide is prohibited on food in the EU regardless of organic status. The permitted routes for microbiological and insect control are validated saturated steam treatment, controlled atmosphere and carbon dioxide treatment, operated in India under the National Standards for Phytosanitary Measures, NSPM-25.

For fennel there is a specific cost to the steam route that does not apply to a root spice. Fennel is bought for its volatile oil, and volatile oil is what steam removes. A process validated for log reduction without a measurement of what it did to the oil content is only half validated. Ask for the validation report, and ask for the volatile oil assay taken after treatment rather than on the untreated lot.

Where our fennel comes from, and what that means

Indian fennel is grown principally in Gujarat — Unjha, Mehsana, Patan and Banaskantha — and in Rajasthan, around Nagaur, Jodhpur and Tonk. Unjha is the trading hub.

We are in Rajkot, in Saurashtra. That is the same state as the main Gujarat fennel districts but a different region of it, a few hours away rather than on our doorstep. We say this because we have been explicit elsewhere in this series that our turmeric comes from Meghalaya and Kerala and our basmati from Punjab and Haryana, both of them long chains far from us. Fennel is genuinely closer: same state, same regulatory environment, same trade networks, and we buy at Unjha rather than through three intermediaries in another part of the country. It is not quite our doorstep crop in the way groundnut and sesame are, and we are not going to claim that it is.

Organic is not an analytical zero

Organic certification governs what may be applied. It does not promise that nothing will ever be detected.

Drift from neighbouring conventional plots, carry-over on shared drying yards, shared cleaning and grading lines and shared transport all produce low-level detections in genuinely organic material. The question a competent buyer asks on a positive result is not “is this organic?” but “at what concentration, and is that concentration consistent with carry-over or with application?” Carry-over sits in parts per billion. A result in parts per million is a traceability question and should be investigated as one.

For fennel in particular, with ethylene oxide as the listed hazard and a residue definition that sums two compounds under one name, a supplier who promises you a clean zero on everything is telling you something about their testing rather than about their crop.

What to ask before you place the order

1. Confirmation that the supplier can produce a complete Annex II file: official certificate, ISO/IEC 17025 accredited analysis results on the actual consignment, and a matching identification code.
2. The issue date of the official certificate, checked against your expected arrival date for the four-month validity.
3. The ethylene oxide result reported as the split between ethylene oxide and 2-chloroethanol, not only as the sum.
4. The NPOP transaction certificate for the specific lot, verified directly with the certifying body.
5. Volatile oil by ISO 6571 with trans-anethole and fenchone as percentages of the oil, assayed after any steam treatment.
6. The microbiological treatment used and its validation report.
7. Grade and growing district — Lucknowi, Gujarat Bold Green or Machine Cleaned Standard, and where it was grown.
8. For the United States: the NOP Import Certificate, raised before the goods move.

Frequently asked questions

Why is fennel from India harder to import into the EU than most spices?

Because it sits in Annex II of Regulation (EU) 2019/1793 rather than Annex I. Annex II imposes special entry conditions, not just a higher check rate. Every consignment must travel with sampling and analysis results produced by the Indian competent authority from an ISO/IEC 17025 accredited laboratory, plus an official certificate on the Annex IV model valid for no more than four months, plus a matching identification code on all three documents. On top of that, 20 per cent of consignments receive identity and physical checks.

Does an organic certificate exempt fennel from those requirements?

No. Regulation (EU) 2019/1793 lists goods by CN code and country of origin. Fennel falls under CN 0909 alongside anise, badian, coriander, cumin, caraway and juniper berries, and the India entry applies to all of them regardless of organic status. An organic consignment needs the Annex II documentation exactly as a conventional one does, in addition to its organic paperwork.

What is the hazard the EU is testing fennel for?

Pesticide residues, and the footnote to the India entry specifies ethylene oxide, defined as the sum of ethylene oxide and 2-chloroethanol expressed as ethylene oxide. Because the two compounds are summed and reported under one name, a positive result labelled ethylene oxide does not by itself tell you which compound was found. Ask the laboratory for the split between the two, since most methods can distinguish them and the limit of quantification is 0.01 mg/kg.

What is the estragole issue with fennel?

Estragole occurs naturally in sweet and bitter fennel. In July 2025 EFSA published a draft opinion concluding that it is genotoxic and carcinogenic and that no safe level of exposure could be established from the available data, flagging infants, young children and exposure through pregnancy and breastfeeding. The review followed concerns raised by German authorities about fennel products for infants. Preparations from which estragole has been removed, or in which it is undetectable, were not considered a health risk. Confirm the current status of the opinion before relying on any summary.

What volatile oil content should organic fennel seed deliver?

Commercial Indian fennel typically runs 1.5 to 3.5 per cent volatile oil by steam distillation under ISO 6571, with trans-anethole at roughly 60 to 75 per cent of the oil and fenchone at 10 to 18 per cent. Moisture is usually specified at a maximum of 8.5 to 9.5 per cent by ISO 939, total ash at a maximum of 8.0 per cent and acid-insoluble ash at a maximum of 1.0 per cent. State the method alongside the number, because a figure without a method is not a specification.

• Because it sits in Annex II of Regulation (EU) 2019/1793 rather than Annex I. Annex II imposes special entry conditions, not just a higher check rate. Every consignment must travel with sampling and analysis results produced by the Indian competent authority from an ISO/IEC 17025 accredited laboratory, plus an official certificate on the Annex IV model valid for no more than four months, plus a matching identification code on all three documents. On top of that, 20 per cent of consignments receive identity and physical checks.
• No. Regulation (EU) 2019/1793 lists goods by CN code and country of origin. Fennel falls under CN 0909 alongside anise, badian, coriander, cumin, caraway and juniper berries, and the India entry applies to all of them regardless of organic status. An organic consignment needs the Annex II documentation exactly as a conventional one does, in addition to its organic paperwork.
• Pesticide residues, and the footnote to the India entry specifies ethylene oxide, defined as the sum of ethylene oxide and 2-chloroethanol expressed as ethylene oxide. Because the two compounds are summed and reported under one name, a positive result labelled ethylene oxide does not by itself tell you which compound was found. Ask the laboratory for the split between the two, since most methods can distinguish them and the limit of quantification is 0.01 mg/kg.
• Estragole occurs naturally in sweet and bitter fennel. In July 2025 EFSA published a draft opinion concluding that it is genotoxic and carcinogenic and that no safe level of exposure could be established from the available data, flagging infants, young children and exposure through pregnancy and breastfeeding. The review followed concerns raised by German authorities about fennel products for infants. Preparations from which estragole has been removed, or in which it is undetectable, were not considered a health risk. Confirm the current status of the opinion before relying on any summary.

Read this ranking directionally, not literally. HS 0909.61 is a basket heading covering seeds of anise, badian, caraway and fennel, plus juniper berries, neither crushed nor ground. The figures therefore include material that is not fennel, and the mix differs by country. The ordering is a reliable guide to where the trade sits; the individual values are not fennel-pure. Any guide that quotes this heading as if it were fennel alone is overstating its precision, and we would rather tell you that than let you quote our table in a board paper.