SPS Certificates Brazil – Phytosanitary Requirements for EU Import

SPS compliance involves costs at both the exporting country and EU entry levels. Understanding these fees is essential for accurate landed-cost calculations.

TRACES NT Registration

Registration in the EU's TRACES NT (Trade Control and Expert System – New Technology) system is free of charge. Both EU importers and third-country operators can register at no cost. TRACES NT is the mandatory electronic platform for pre-notification of SPS-regulated consignments entering the EU. Every importer of food, plants, or animal products from Mercosur must have an active TRACES NT account.

Phytosanitary Certificate Costs

Phytosanitary certificates are issued by the competent authority in the exporting country:

• Brazil (MAPA): phytosanitary certificate fee of approximately USD 50–150 per consignment, depending on product type and inspection complexity
• Argentina (SENASA): USD 80–200, with additional charges for field inspections of certain crops
• Pre-shipment laboratory analysis: USD 100–500 per sample, depending on the number of pesticide residues tested and the accredited laboratory used
• Fumigation treatment: USD 200–600 per container for methyl bromide or phosphine treatment, required for certain plant commodities

Veterinary Certificate Costs

For animal products (beef, poultry, dairy, seafood), veterinary health certificates are issued by official veterinarians:

• Official veterinary inspection: USD 80–250 per consignment at the establishment level
• Laboratory testing (microbiological, residues): USD 150–800 depending on the testing panel (Salmonella, E. coli, hormone residues, antibiotics)
• EU-approved establishment audit costs: borne by the exporting country's authority, but exporters typically pay for corrective measures

EU Border Inspection Fees

At EU Border Control Posts, importers are charged for official controls:

• Documentary and identity checks: included in the standard BCP inspection fee of approximately €55 per consignment (base rate under Regulation (EU) 2017/625)
• Physical inspection: additional charges apply when goods are selected for physical examination — €150–400 depending on product type and volume
• Laboratory testing at EU border: €200–1,500 per sample depending on the analysis (pesticide residue screening, mycotoxin testing, heavy metals)
• Reinforced checks: products listed under Regulation (EU) 2019/1793 (increased controls) face higher inspection frequencies and associated costs

The EU's sanitary and phytosanitary controls are among the most comprehensive in the world. Importers must understand the key regulations governing the entry of agricultural and food products from Mercosur.

Regulation (EU) 2016/2031 – Plant Health

This is the EU's principal plant health law, establishing the framework to prevent the introduction and spread of plant pests. It requires that all regulated plant products imported from third countries be accompanied by a phytosanitary certificate issued by the exporting country's National Plant Protection Organization (NPPO). For Brazil, this is MAPA; for Argentina, SENASA. The regulation defines quarantine pests, regulated non-quarantine pests, and the phytosanitary measures required for each commodity.

Regulation (EC) 853/2004 – Animal Products

This regulation lays down specific hygiene rules for food of animal origin. It requires that animal products entering the EU come from approved third-country establishments that have been inspected and listed by DG SANTE. Brazil maintains hundreds of EU-approved establishments for beef, poultry, and fishery products. Only products from these listed establishments may be imported. The approved establishments list is maintained and updated in the TRACES NT system.

CHED – Common Health Entry Document

All SPS-regulated consignments must be accompanied by a Common Health Entry Document, submitted through TRACES NT. There are four types:

• CHED-P (Plants): for plants, plant products, and other objects subject to phytosanitary controls — e.g., Brazilian soybeans, coffee, fruit, timber, and cut flowers
• CHED-A (Animals): for live animals — e.g., ornamental fish, live bees, or breeding animals from Mercosur
• CHED-D (Food and Feed of non-animal origin): for food and feed products subject to increased controls under Regulation (EU) 2019/1793 — e.g., certain spices, nuts, or dried fruits with aflatoxin risk
• CHED-PP (Animal Products): for products of animal origin — e.g., Brazilian beef, poultry meat, honey, dairy, and fish products

Official Controls Regulation (EU) 2017/625

This regulation defines the rules for official controls at EU borders, including inspection frequencies, sampling procedures, and the designation of Border Control Posts. It mandates that all SPS-controlled goods enter the EU only through designated BCPs equipped with the necessary inspection facilities (cold storage, laboratories, etc.).

Maximum Residue Levels (MRLs)

Regulation (EC) 396/2005 sets maximum residue levels for pesticides in food and feed. Brazilian agricultural exports must comply with EU MRLs, which are often stricter than Codex Alimentarius standards. Products exceeding MRLs are subject to rejection at the border. The EU's Rapid Alert System for Food and Feed (RASFF) regularly flags Mercosur consignments for pesticide residue violations.

A complete set of SPS documents is essential for smooth clearance at EU Border Control Posts. Missing or incorrect documentation is the leading cause of cargo delays and rejections.

Phytosanitary Certificate

Issued by the NPPO of the exporting country (MAPA in Brazil, SENASA in Argentina) in accordance with the International Plant Protection Convention (IPPC) model. The certificate confirms that the plants or plant products have been inspected and found free from quarantine pests, and that they conform to the phytosanitary requirements of the EU. It must be issued no more than 14 days before the date of export.

Health Certificate (Veterinary Certificate)

For animal products, the health certificate is issued by the official veterinary service of the exporting country. It follows EU model certificates specified in Implementing Regulation (EU) 2020/2235. The certificate attests that the products originate from approved establishments, have been produced under adequate hygiene conditions, and meet EU requirements for animal health, public health, and residue monitoring.

Certificate of Origin

While primarily a customs document, the certificate of origin is important in the SPS context as it confirms the country and region of production. This is critical for verifying compliance with regionalisation agreements — for example, EU restrictions on beef imports may apply to specific Brazilian states affected by foot-and-mouth disease rather than the entire country.

TRACES NT Pre-notification

The importer (or their customs broker) must submit a pre-notification in TRACES NT at least one working day before the physical arrival of the consignment at the EU Border Control Post. The TRACES NT notification includes details of the goods, the accompanying certificates, the expected arrival date, and the designated BCP of entry.

CHED Form (Common Health Entry Document)

The CHED is generated within TRACES NT as part of the pre-notification process. The correct CHED type must be selected (CHED-P, CHED-A, CHED-D, or CHED-PP). After official controls at the BCP, the competent authority completes the CHED with the inspection outcome, which determines whether the goods are released for free circulation, subjected to further testing, or rejected.

Laboratory Analysis Reports

Pre-shipment laboratory analysis reports from accredited laboratories in the exporting country strengthen the compliance case, especially for products under increased EU controls. These may include:

• Pesticide residue analysis: multi-residue screening covering EU-regulated active substances
• Mycotoxin testing: aflatoxin B1, ochratoxin A levels for nuts, cereals, spices
• Microbiological testing: Salmonella, Listeria, E. coli for animal products
• Heavy metal analysis: cadmium, lead, mercury levels

Fumigation Certificate

Required when plant products have undergone fumigation treatment as a phytosanitary measure. The certificate details the active substance used (e.g., methyl bromide, phosphine), the dosage, treatment duration, and temperature during treatment. Additionally, all wood packaging materials (pallets, crates, dunnage) must comply with ISPM 15 and bear the IPPC stamp confirming heat treatment or fumigation.

SPS compliance adds time to the import process that must be factored into supply chain planning. Below is a breakdown of the key stages and their typical durations.

Pre-Shipment Inspections (2–5 Days)

Before goods leave the exporting country, the following SPS procedures must be completed:

• Application for phytosanitary/veterinary certificate: submitted to MAPA (Brazil) or SENASA (Argentina) at least 3–5 working days before intended shipment
• On-site inspection: official inspectors visit the establishment or packing facility to verify compliance — typically 1–2 days
• Laboratory sampling and analysis: if required, pre-export testing for pesticide residues, microbiological parameters, or contaminants — results in 2–5 days depending on the laboratory
• Certificate issuance: once inspection and any testing are satisfactory, the certificate is issued within 1–2 working days

TRACES NT Pre-Notification (24 Hours Before Arrival)

EU law requires that the importer submit a TRACES NT notification at least one working day before the consignment arrives at the designated Border Control Post. In practice:

• Preparation of CHED: 1–2 hours to complete all fields accurately
• Upload of supporting documents: scanned phytosanitary/health certificates, laboratory reports
• Submission deadline: minimum 24 hours prior to arrival; for certain high-risk goods, earlier notification may be advisable

BIP Inspection at EU Border (1–3 Days)

At the Border Control Post, official controls follow a defined sequence:

• Documentary check: verification of CHED, certificates, and accompanying documents — typically completed within a few hours
• Identity check: confirmation that the goods match the documentation (seals, labels, markings) — same day
• Physical check: opening of containers, visual inspection, temperature verification for reefer cargo, and sampling if required — 1–2 days
• Decision and release: if satisfactory, CHED is completed and goods are released for customs clearance — 0.5–1 day

Laboratory Testing if Needed (3–10 Days)

When official sampling is carried out at the BCP, goods are held pending laboratory results:

• Pesticide residue screening: 3–5 working days for standard multi-residue analysis
• Mycotoxin and contaminant testing: 3–7 working days
• Microbiological testing: 5–10 working days (especially for Salmonella culture methods)
• Goods under detention: the consignment remains at the BCP under official control, incurring storage costs, until results are available

Total SPS Clearance Time

Under normal circumstances with complete documentation and no laboratory testing: 2–4 days from arrival at BCP to release. If laboratory testing is triggered: 5–14 days. For products under reinforced controls (Regulation (EU) 2019/1793), inspection frequencies are higher and delays more likely. Importers should plan a buffer of at least 5 working days for SPS clearance in their supply chain.

SPS non-compliance is one of the most costly errors in Mercosur-EU agricultural trade. Below are the most frequent mistakes and how to avoid them.

1. Incorrect TRACES NT Notifications

The most common procedural error is submitting a flawed TRACES NT pre-notification. Mistakes include selecting the wrong CHED type (e.g., filing CHED-D instead of CHED-PP for animal products), entering incorrect consignment weights, using the wrong commodity codes, or failing to link the correct official certificates. An incorrect TRACES NT notification results in the consignment being stopped at the BCP, requiring amendment and re-submission — adding 1–3 days to the clearance process and incurring additional storage charges.

2. Missing Establishment Approvals

Animal products may only be imported into the EU from third-country establishments approved by DG SANTE. A frequent mistake is sourcing products from Brazilian or Argentine processing plants that are not on the EU-approved list. This results in automatic rejection at the border — the goods cannot enter the EU under any circumstances. Before placing orders, importers must verify the supplier's establishment number against the TRACES NT approved establishments list.

3. Temperature Chain Breaks for Reefer Cargo

Chilled and frozen products from Mercosur (beef, poultry, seafood, dairy) must maintain an unbroken cold chain from production to delivery. Temperature deviations detected during BCP inspection — typically via data logger review — can result in consignment rejection. Common causes include reefer container malfunctions, improper pre-cooling before stuffing, and delays during port handling. Importers should require continuous temperature monitoring (data loggers) and verify records upon arrival.

4. Non-Compliant Pesticide Residue Levels

EU Maximum Residue Levels (MRLs) for pesticides are among the strictest globally. Brazilian agricultural practices frequently use active substances at concentrations that comply with Brazilian (ANVISA) or Codex standards but exceed EU limits. Products most at risk include coffee, soybeans, citrus fruits, mangoes, and peppers. The EU's RASFF database regularly publishes alerts for Mercosur products with MRL exceedances. Importers should require pre-shipment testing against EU MRLs at accredited laboratories and consider contractual clauses ensuring EU compliance.

5. Wrong CHED Type Selection

Selecting the incorrect CHED type is a surprisingly frequent error that causes significant delays. Key distinctions:

• CHED-P: for plants and plant products (not for processed food)
• CHED-PP: for products of animal origin (beef, poultry, fish, dairy, honey)
• CHED-D: for food/feed of non-animal origin under increased controls
• CHED-A: for live animals

For composite products (e.g., a product containing both plant and animal ingredients), determining the correct CHED type requires careful analysis of the product composition and applicable EU regulations. When in doubt, consult the BCP authority or an experienced customs broker before submission.

6. Expired or Incorrectly Issued Certificates

Phytosanitary certificates that are older than 14 days from the date of export, health certificates with errors in the establishment approval number, or certificates that do not match the EU model format are all grounds for rejection. Importers must verify that all certificates are current, correctly completed, and match the actual goods being shipped — including species, quantities, and lot numbers.