Two products, two customs codes, two different trades

Chicory, Cichorium intybus, reaches buyers in two quite separate forms, and conflating them is the most common error we see in enquiries.

• Raw chicory root, fresh, chilled, frozen or dried, whether or not cut or ground, sits under HS 1212.94. Its main industrial destination is inulin and oligofructose extraction.
• Roasted chicory and other roasted coffee substitutes, including extracts and essences, sit under HS 2101.30. This is the coffee-substitute and coffee-blending trade.

These are not two grades of one thing. They go to different factories, carry different specifications and differ in scale by more than an order of magnitude.

Raw roots, HS 1212.94, 2023

World imports under this heading exceeded USD 13.3 million and world exports exceeded USD 21 million in 2023. Note the gap. Exports reported are well above imports reported, which in a trade this small usually means inconsistent reporting rather than smuggling. Treat the ordering as indicative and the absolute figures as approximate.

The heading is small for a structural reason: most chicory root is processed close to where it is grown, because the root is bulky, perishable and worth more once the inulin is out of it. The Belgian and Dutch inulin industry takes local and regional root. What crosses borders as raw root is the exception, not the rule.

Roasted chicory and coffee substitutes, HS 2101.30, 2024

Those seven volume importers together account for about 60 per cent of the 63,000 tonnes traded. Note that the value ranking and the volume ranking are different lists. South Africa is the largest buyer by weight and does not appear in the top three by value; Germany is first by value and sixth by weight. If you benchmark a price against “the market” without knowing which of those two markets you are in, you will reach the wrong conclusion.

India is the volume origin. It is not the premium origin

Here is the disclosure that matters most, and it does not flatter us.

In 2024 India exported about 34,000 tonnes of roasted chicory and coffee substitutes, around 53 per cent of global export volume. By value that was about USD 42 million, roughly 20 per cent of the USD 213 million export total. Poland, on far smaller volume, took USD 37 million. Portugal took USD 28 million.

Put the two halves together. India ships more than half the world’s volume and collects a fifth of the world’s value. On the published figures that puts Indian material at roughly a third of the average unit value of the trade.

For once, we are in the right state

In our guides to turmeric, millet and sorghum we have had to disclose that Gujarat is not a significant producing state for those crops and that our chain of custody is correspondingly long. Chicory is the exception, and we will take it.

Chicory in India is cultivated mainly in Gujarat and Uttar Pradesh, which together account for about 97 per cent of national production, with smaller areas in Tamil Nadu, Bihar and Himachal Pradesh. Commercial seed comes from the temperate areas of Himachal Pradesh, Jammu and Kashmir and some hill regions of Uttar Pradesh.

We are in Rajkot, in Gujarat. For this crop that is a short chain rather than a long one, and you should hold us to a correspondingly higher standard of traceability than you would on a commodity we buy from three states away. Ask us for the district and the crop year, and expect a specific answer rather than a regional one.

The acrylamide number, and why it misleads

Roasting chicory is a Maillard process, and Maillard chemistry produces acrylamide. Commission Regulation (EU) 2017/2158 sets benchmark levels for acrylamide across food categories. Here is where chicory sits:

At 4000 µg/kg, pure chicory has the most permissive benchmark in the regulation: eight times the cereal-based substitute, ten times roast coffee, a hundred times infant food. A buyer who reads that line and relaxes has made a mistake, for two reasons.

First, the 4000 applies to chicory on its own. The moment chicory is blended with cereals, or blended into coffee, there is no fixed benchmark: the level is set by the relative proportion of the ingredients. Most chicory in world trade is blended, and Indian chicory in particular goes heavily into coffee blends. So the generous number describes a product that many buyers are not actually placing on the market. If you are making a 30 per cent chicory, 70 per cent barley substitute, your effective target sits far closer to the cereal figure than to 4000.

Second, a benchmark is not a limit. Benchmark levels are performance indicators. Exceeding one obliges a review of the mitigation measures being applied; it does not by itself determine whether a product may be placed on the market, and staying under one does not by itself make a product compliant. We take the values above from the European Commission’s guidance document on the implementation of the regulation, which reproduces them and which states that it has no formal legal status and was not adopted by the Commission. Work from the regulation itself for anything contractual.

The practical consequence: specify acrylamide as a number on the finished form you are buying, state whether the result is to be read against the pure-chicory benchmark or a blend proportion, and ask what mitigation the roaster applies. Roast profile, final moisture and root sugar content all move the result.

Inulin: the percentage is not the specification

For the raw-root trade, almost every enquiry we receive specifies inulin content and nothing else. That is not enough, and the reason is chain length.

Chicory root carries roughly 17 per cent inulin in fresh mass, typically 40 to 60 per cent of dry weight, and selected industrial cultivars reach about 70 per cent of dry weight. But native chicory inulin is not one molecule. It spans a degree of polymerisation from 2 to 60, and the fractions do different jobs:

Two lots with identical total inulin can therefore be useless to each other’s buyers. Specify the DP distribution, not only the percentage, and state the method.

There is also a connection between this table and the previous section that is worth noticing. The short-chain fractions have more reducing ends and brown more readily in the Maillard reaction. Maillard browning is what roasting is, and acrylamide is a Maillard product. The same raw-material property that determines whether your inulin behaves as a sweetener or a fat mimetic also bears on how the root behaves in the roaster.

The fat nobody mentions

This one surprises buyers regularly, and it is standard rather than exceptional.

In the Indian roasted-chicory process set out in published processing guidance, roots are washed, sliced and dried with kiln drying preferred, graded into four sizes, and roasted for about 30 minutes in rotating cylinders. Then roughly 0.9 kg of oil or butter is added per 50 kg of chicory before the material is powdered. That is about 1.8 per cent added fat.

If the fat is a vegetable oil, you have an added ingredient to declare. If it is butter, the product contains a dairy ingredient, which bears on vegan claims, on allergen declarations and on some religious certifications. None of that is improper, and the addition has a technical purpose in roasting and powder handling. It is simply something you need to know, and it does not always appear on an offer sheet.

Ask three questions: what fat, at what rate, and is it on the ingredient declaration. If you need the material fat-free, say so at enquiry, because that is a process change rather than a sorting decision.

Drying and roasting: where the quality is decided

For the coffee-substitute route, roots are separated from leaves and chopped, dried, roasted at about 140 to 180 °C and ground; instant versions are roasted, percolated and spray-dried. Traditional drying is sun drying at 40 to 45 °C for three to four days, now often replaced by mechanical drying, and kiln drying is preferred for the roasted-powder route.

For inulin extraction the route is different again: roots are soaked in 0.75 per cent citric acid for 24 hours, dried at 40 °C and ground, then extracted in water at a 1 to 10 ratio at 80 °C for an hour, clarified with lime and phosphoric acid, decolourised with charcoal, concentrated to 40 °Brix, precipitated with ethanol, freeze-dried and milled.

Two things follow for a buyer. Drying method and temperature belong in the specification, because sun drying at ambient humidity and kiln drying at controlled temperature do not give the same microbiological or colour outcome. And roast profile belongs in the specification too, stated as temperature and time rather than as a colour word, because “dark roast” is not a measurement and acrylamide tracks the profile.

EU border controls, and one classification trap

Indian chicory is not subject to increased official controls as chicory. CN 1212, covering chicory roots, and CN 2101, covering roasted chicory and coffee substitutes, appear in neither Annex I nor Annex II of Regulation (EU) 2019/1793, for India or for any other country. We verified this against the India rows as amended by Implementing Regulation (EU) 2026/1206, in force from 30 June 2026, rather than inferring it from a summary of changes.

Standard caveats apply. Not being listed means your consignment is not subject to mandatory increased checks as a category; it does not mean it cannot be sampled, and it does not mean contaminant limits do not apply. The annexes are revised roughly twice a year, so confirm the position at your shipment date.

Specification: what to put in the contract

If you want it organic

This guide covers chicory as a product rather than as a certification, and most of it applies either way. For certified organic root or powder, three documentation layers sit on top of the specification above:

The usual caution carries over: organic is not an analytical zero. Organic certification governs what may be applied, not what may be detected, and carry-over sits in parts per billion while a parts-per-million result is a traceability question. Note also that organic certification says nothing at all about acrylamide, because acrylamide is formed by heat during processing rather than applied in the field.

What to ask for before you buy

1. Which heading you are buying under, 1212.94 or 2101.30, and the settled classification for the shipped form.
2. Inulin percentage on dry matter and the DP distribution, each with method.
3. Acrylamide on the finished form, with the blend proportion stated if it is a blend.
4. What fat is added, at what rate, and whether it is declared. Butter or vegetable oil.
5. Roast profile as temperature and time, and drying method and temperature.
6. Moisture, total ash and acid-insoluble ash against stated methods.
7. District and crop year on the lot.
8. If organic: the NPOP transaction certificate for the lot, verified with the certifying body directly.

Frequently asked questions

Why does the EU allow 4000 µg/kg of acrylamide in chicory?

It does not quite allow it, and the number is more dangerous than it looks. Commission Regulation (EU) 2017/2158 sets a benchmark level of 4000 µg/kg for coffee substitutes made exclusively from chicory, against 500 for coffee substitutes made exclusively from cereals, 400 for roast coffee and 850 for instant coffee. That makes chicory the most permissive category in the regulation. But the benchmark applies to chicory on its own. For coffee substitutes made from a mixture of cereals and chicory, and for mixtures of coffee with coffee substitutes, there is no fixed value: the level is set by the relative proportion of the ingredients. Since most chicory is blended rather than drunk alone, the 4000 figure describes a product many buyers are not actually making. Benchmark levels are also performance indicators that trigger a review of mitigation measures, not legal maximum limits, and they cannot by themselves decide whether a product may be placed on the market.

Is inulin content a sufficient specification for chicory root?

No. Chicory root carries roughly 17 per cent inulin in fresh mass and typically 40 to 60 per cent of dry weight, with selected industrial cultivars reaching about 70 per cent. But native chicory inulin spans a degree of polymerisation from 2 to 60, and the fractions behave differently. Short-chain material below DP 10, often called oligofructose, is highly soluble and delivers roughly 30 to 50 per cent of the sweetness of sucrose, which suits sugar reduction. Long-chain material above DP 23 is less soluble and more viscous, and at 20 to 40 per cent concentration it forms a gel network of microcrystalline particles that holds water and mimics the mouthfeel of fat, which suits fat reduction in yoghurt and low-fat cheese. Two lots with identical total inulin can therefore do opposite jobs. Specify the DP distribution, not just the percentage.

Is anything added to roasted chicory powder?

Often yes, and buyers are regularly surprised by it. In the standard Indian process described in published processing guidance, roots are washed, sliced, dried with kiln drying preferred, graded into four sizes and roasted for about 30 minutes in rotating cylinders, and roughly 0.9 kg of oil or butter is added per 50 kg of chicory before powdering. That is about 1.8 per cent added fat. If the fat used is butter, the product carries a dairy ingredient, which matters for vegan claims, for allergen declaration and for some religious certifications. Ask what fat is used, at what rate, and require it on the specification and the ingredient declaration. A supplier who says the product is pure roasted chicory without addressing this has not answered the question.

Is Indian chicory subject to increased EU border controls?

Not as chicory. CN 1212, which covers chicory roots, and CN 2101, which covers roasted chicory and coffee substitutes, appear in neither Annex I nor Annex II of Regulation (EU) 2019/1793, for India or for any other country. We verified this against the India rows as amended by Implementing Regulation (EU) 2026/1206, in force from 30 June 2026. There is one trap worth checking. Annex II does list botanical food supplements from India under ex 1302 and ex 2106 for pesticide residues at a 10 per cent control frequency. Inulin or chicory root fibre presented and classified as a botanical food supplement could fall under that entry rather than under 1212 or 2101. Settle the tariff classification for the form you are actually shipping before you ship it, because the presentation can move the goods into a listed line.

Where does India rank in the chicory trade?

India dominates the roasted side by volume and is a mid-sized player in raw roots. For roasted chicory and other roasted coffee substitutes under HS 210130, India exported about 34,000 tonnes in 2024, around 53 per cent of global export volume, worth about USD 42 million or roughly 20 per cent of the USD 213 million export total, with Poland at USD 37 million and Portugal at USD 28 million. The gap between 53 per cent of volume and 20 per cent of value is the important part: Indian material sells at roughly a third of the average unit value of the trade. For raw chicory roots under HS 121294 in 2023, India was the third largest exporter at about USD 2.84 million, behind Hungary and Belgium. India is the volume origin in this commodity, not the premium origin, and we would rather you knew that before negotiating than after.

• It does not quite allow it, and the number is more dangerous than it looks. Commission Regulation (EU) 2017/2158 sets a benchmark level of 4000 µg/kg for coffee substitutes made exclusively from chicory, against 500 for coffee substitutes made exclusively from cereals, 400 for roast coffee and 850 for instant coffee. That makes chicory the most permissive category in the regulation. But the benchmark applies to chicory on its own. For coffee substitutes made from a mixture of cereals and chicory, and for mixtures of coffee with coffee substitutes, there is no fixed value: the level is set by the relative proportion of the ingredients. Since most chicory is blended rather than drunk alone, the 4000 figure describes a product many buyers are not actually making. Benchmark levels are also performance indicators that trigger a review of mitigation measures, not legal maximum limits, and they cannot by themselves decide whether a product may be placed on the market.
• No. Chicory root carries roughly 17 per cent inulin in fresh mass and typically 40 to 60 per cent of dry weight, with selected industrial cultivars reaching about 70 per cent. But native chicory inulin spans a degree of polymerisation from 2 to 60, and the fractions behave differently. Short-chain material below DP 10, often called oligofructose, is highly soluble and delivers roughly 30 to 50 per cent of the sweetness of sucrose, which suits sugar reduction. Long-chain material above DP 23 is less soluble and more viscous, and at 20 to 40 per cent concentration it forms a gel network of microcrystalline particles that holds water and mimics the mouthfeel of fat, which suits fat reduction in yoghurt and low-fat cheese. Two lots with identical total inulin can therefore do opposite jobs. Specify the DP distribution, not just the percentage.
• Often yes, and buyers are regularly surprised by it. In the standard Indian process described in published processing guidance, roots are washed, sliced, dried with kiln drying preferred, graded into four sizes and roasted for about 30 minutes in rotating cylinders, and roughly 0.9 kg of oil or butter is added per 50 kg of chicory before powdering. That is about 1.8 per cent added fat. If the fat used is butter, the product carries a dairy ingredient, which matters for vegan claims, for allergen declaration and for some religious certifications. Ask what fat is used, at what rate, and require it on the specification and the ingredient declaration. A supplier who says the product is pure roasted chicory without addressing this has not answered the question.
• Not as chicory. CN 1212, which covers chicory roots, and CN 2101, which covers roasted chicory and coffee substitutes, appear in neither Annex I nor Annex II of Regulation (EU) 2019/1793, for India or for any other country. We verified this against the India rows as amended by Implementing Regulation (EU) 2026/1206, in force from 30 June 2026. There is one trap worth checking. Annex II does list botanical food supplements from India under ex 1302 and ex 2106 for pesticide residues at a 10 per cent control frequency. Inulin or chicory root fibre presented and classified as a botanical food supplement could fall under that entry rather than under 1212 or 2101. Settle the tariff classification for the form you are actually shipping before you ship it, because the presentation can move the goods into a listed line.

What you should take from that, and what you should ask us. There are honest reasons for a low unit value: bulk industrial grade rather than retail-ready, coarse rather than fine grind, commodity packing, and a cost base that is genuinely lower. There are also less honest reasons: over-roasting to mask poor root, high ash from soil carry-over, excessive added fat, and blending with cereals that are not declared. The number alone does not tell you which you are being offered. So do not treat a low Indian price as a bargain or as a warning. Treat it as a question, and make us answer it line by line against the specification below. If a supplier cannot explain why their chicory is cheap, assume the explanation is one of the second set.