Ethylene oxide in spice exports: one test, two verdicts
The same ethylene oxide result can clear an Indian spice lot at home and sink it in the EU or Hong Kong. The limits are destination-specific and the gap between them is enormous.
- Every destination limit runs on one residue definition, the sum of ethylene oxide and 2-chloro-ethanol expressed as ethylene oxide, and the degradation product is usually the larger fraction.
- The EU figure for every spice subgroup is 0.1 mg/kg, set in Annex V to Regulation (EC) No 396/2005 by Commission Regulation (EU) 2015/868. The 0.02 that circulates belongs to fresh produce, pulses and cereals.
- Hong Kong's CFS acted on 5 April 2024 on presence under Cap. 132CM for four MDH and Everest products. Singapore's SFA ordered a separate recall on 18 April 2024 of one product for exceeding its own limit.
- Spices Board registration is mandatory. A CRES is issued under section 11 of the Spices Board Act, 1986, in addition to the Importer Exporter Code, for a block period of three years.
What ethylene oxide is doing in a spice lot
The Spices Board’s own Comprehensive Guidelines on Prevention of Ethylene Oxide Contamination in Spices Exports, document SB/EXP/SOP/02 Rev.01 issued on 6 May 2024, describes it as a gas serving as a disinfectant, fumigant, sterilising agent and insecticide. On spices the point of it is microbial load. 2-chloroethanol, or ECH, is its degradation product, and that matters more than the parent.
The same document records something exporters rarely hear: ethylene oxide has been reported to arise from natural sources, because in certain plants ethylene, a natural plant growth regulator, degrades to it. A positive result is not proof that somebody fumigated.
In India it is not registered as an insecticide with the Central Insecticides Board and Registration Committee under the Insecticides Act, 1968, and it is not a permitted food additive. The Board tells exporters to avoid it entirely and points them to steam sterilisation, irradiation, which is unavailable for NPOP organic product, or another method approved by FSSAI. We found no FSSAI order naming the substance and prohibiting it expressly, so the position rests on the absence of registration rather than on a prohibition.
April 2024 was two separate actions, not one event
On 5 April 2024 Hong Kong’s Centre for Food Safety announced that prepackaged spice mix samples, collected from three Tsim Sha Tsui retail outlets under its routine Food Surveillance Programme, contained the pesticide ethylene oxide. Four products were named: MDH Madras Curry Powder, Everest Fish Curry Masala, MDH Sambhar Masala Mixed Masala Powder and MDH Curry Powder Mixed Masala Powder. The CFS cited the Pesticide Residues in Food Regulation, Cap. 132CM, under which food containing pesticide residue may be sold only if consuming it is not dangerous or prejudicial to health. It told vendors to stop sale and clear shelves, noted that importers had initiated recalls, and cited the IARC classification of ethylene oxide as a Group 1 carcinogen.
On 18 April 2024 the Singapore Food Agency ordered a separate recall of one product only: Everest Fish Curry Masala in 50 g packs with a best before date of September 2025, imported by Sp Muthiah and Sons. Its stated ground was ethylene oxide at levels exceeding the permissible limit.
Two different legal tests, which is why the actions look alike and are not. Hong Kong acted on presence, against a general safety provision. Singapore acted on exceedance of a numeric limit it publishes. Neither declared the brands unsafe across their ranges.
The limits, where consignments are actually lost
The EU figure does not sit where most people look. Ethylene oxide was removed from Annex II to Regulation (EC) No 396/2005 and placed in Annex V by Commission Regulation (EU) 2015/868, applicable from 30 December 2015. Annex V holds the different default values permitted under article 18(1)(b). Every spice subgroup there carries 0.1 mg/kg at the lower limit of analytical determination, on one residue definition: the sum of ethylene oxide and 2-chloro-ethanol expressed as ethylene oxide.
The 0.02 figure that circulates in export circles is real and sits elsewhere in the same annex. It covers fresh commodities, including fruiting vegetables such as peppers of the genus Capsicum, plus citrus, pome and stone fruit, pulses and cereals. Tree nuts, herbs, oilseeds and honey are 0.05. The general default is 0.01. Fresh chilli faces 0.02, dried chilli powder faces 0.1, and reading one off the other loses consignments. Verify ginger yourself: the Board’s table shows dry ginger at 0.02, the EU instrument reads 0.1, and the Commission’s database returns none for ginger.
The rest of the Board’s country table:
- Hong Kong and Thailand. Not detected, with the Board recording the limit of quantification as 0.01. Great Britain, Norway, Switzerland and Turkey mirror the EU. Singapore 50 for spices, Canada 7.
- United States. 40 CFR 180.151 sets two separate postharvest fumigation tolerances, 7 ppm for ethylene oxide and 940 ppm for its reaction product, on dried herb and spice group 19 other than basil.
- India. No ethylene oxide specific limit. FSSAI’s order of 8 April 2024 set the default for pesticides not registered with the CIB&RC at 0.1 mg/kg for spices and culinary herbs, against 0.01 mg/kg for other foods. We found no Indian instrument defining the residue as a sum.
- Japan and Codex. Neither Japan’s positive list nor the Codex pesticide index carries an ethylene oxide entry, so there is no fallback international figure.
India and the EU print the same 0.1 for spices, which is why the gap catches people. It bites twice. The European number is a sum, and the degradation product is usually the larger fraction, so a lot reading clean on ethylene oxide alone can fail the European arithmetic. And Hong Kong and Thailand want non-detection, so a lot sitting inside both 0.1 figures is rejected there anyway.
Who tests, and what the paper has to say
Spices Board Circular 05/2022-23 of 27 May 2022 made a cleared analytical report from the Board’s own Quality Evaluation Laboratories mandatory for notified spices going to the EU, in line with Commission Implementing Regulation (EU) 2021/2246 of 15 December 2021, and recorded that an Official Certificate from the Board for ethylene oxide is required for clearance at EU destination ports. The EU instrument behind that, Implementing Regulation (EU) 2019/1793 on temporary increased official controls, has its annexes revised repeatedly, including during 2026.
When a limit sits at the limit of determination, a report saying absent or not detected, without the quantification limit and residue definition, proves nothing. It must state the result on the sum basis, and the quantification limit has to sit at or below the destination figure.
Registration, and the lesson for the seller who never exports
Registration with the Spices Board is mandatory. Its own licensing FAQ states that a Certificate of Registration as Exporter of Spices, the CRES, is issued under section 11 of the Spices Board Act, 1986, is mandatory in addition to the Importer Exporter Code, and runs for a block period of three years under the Spices Board Rules, 1987 and the Spices Board (Registration of Exporter) Regulations, 1989.
If you sell only on Indian marketplaces and quick commerce, none of the certificates apply and all of the supply chain does. The grinding unit treating an export lot treats yours on the same line, and the Board’s controls read as ordinary supplier discipline: name the hazard in the plan, store treated and untreated material separately, test incoming material instead of trusting a declaration. That is the ground covered by food safety audit readiness and by co-packer selection for food brands.