Why EU buyers ask Indian dehydrated onion suppliers for a processing factor
2026-09-04
European buyers of Indian dehydrated onion often ask for something that surprises first-time exporters: not just a residue report, but a justification of how the fresh-onion result relates to the dried product. This is not the importer being difficult. It follows directly from how EU residue law treats processed food.
Regulation (EC) No 396/2005 sets maximum residue levels for pesticides, and the same MRLs apply to imported and EU-grown products alike. There is no separate, looser limit for cargo arriving from outside the Union. The complication for our category is that MRLs are generally set on the raw agricultural commodity — the onion — while what actually crosses the border is a dried concentrate of it.
Dehydration removes most of the water. Whatever residue was present in the fresh bulb stays with the solids, so its concentration in the finished flakes, kibbled onion or powder is several times higher than in the raw crop. A lot that comfortably passed as fresh onion can therefore exceed the same numeric MRL once dried, without anything having been done wrong agronomically.
The EU handles this with processing factors: a figure describing how a given substance behaves through a defined process, applied to relate the processed result back to the raw-commodity MRL. Where no processing factor has been established for that substance-product-process combination, the food business operator is expected to justify why the processed product complies. In practice that justification lands on the importer, and the importer asks the supplier for the data behind it.
What this means when you write the enquiry. Say up front that the destination is the EU. Ask for residue testing on a scope that matches the EU list rather than only the Indian domestic panel, state whether you need the result reported on the dried product or the fresh input, and agree who commissions and pays for the analysis before production, not after the container is booked. A residue question raised at Rotterdam is far more expensive than the same question raised at the PO stage.
We are a new exporter and we would rather say this plainly than discover it on a first EU shipment. If you are importing dehydrated onion into the EU, tell us your MRL scope and reporting basis on the enquiry and we will confirm in writing what we can and cannot evidence for that lot before anything is loaded.
This note is general information about how the rules work, not regulatory advice. The EU Pesticides Database is the authoritative source for current MRLs, and your own compliance team or customs broker should confirm the position for your substance list and product.