The Document Pack, and the One Everyone Asks For That They May Not Need
A shipment of dried botanicals is a physical thing and a paper thing, and the paper is where most first-time imports go wrong. Not because the requirements are difficult, but because buyers routinely ask for documents they do not need, forget documents they do, and assume the supplier is responsible for filings that are legally theirs.
This guide sets out what actually travels with a bulk dried herb consignment, who issues each document, and — for the one document everyone asks about first, the phytosanitary certificate — what the rules genuinely say rather than what the trade assumes.
It pairs with our guide to buying bulk dried herbs from Georgia, which covers order quantities, lead times, Incoterms, and routing.
A note on scope before we start. The detail below is written primarily from the perspective of an import into the European Union, because that is the destination most of our enquiries name. Rules differ by destination country and change over time. Nothing here substitutes for confirming the current requirement with your own customs broker or competent authority.
The Commercial Set: Always, Every Shipment
Three documents accompany essentially every cross-border consignment. They look routine, which is exactly why they are worth getting right for botanicals specifically.
Commercial invoice. The legal and customs description of what is being sold. For herbal raw material it should carry the botanical name and the plant part, not just a trade name — “Urtica dioica, dried leaf, cut” rather than “nettle”. Include the lot or batch number, the harvest year, the country of origin, the quantity in net weight, the Incoterms 2020 rule with its named place, and the customs commodity code. A vague invoice description is the single most common cause of a consignment being held for questions at the border.
Packing list. How the shipment is physically made up: number of sacks or cartons, net and gross weight per unit and in total, dimensions, pallet count, and the marks and numbers on the packages. The packing list is what the receiving warehouse checks against, and the mismatch between net and gross weight on a light, bulky commodity is larger than most people expect — see the density discussion in the bulk buying guide.
Transport document. A Bill of Lading for sea freight, a CMR consignment note for international road transport, or an Air Waybill for air. This is the contract of carriage and, in the case of a negotiable bill of lading, the document of title. Whether the seller or buyer holds it depends entirely on the Incoterms rule agreed.
The Origin Set: Where Duty Is Won or Lost
Two different documents get confused with each other constantly, and they do different jobs.
Certificate of Origin (non-preferential). A general statement of where the goods were produced, typically issued or endorsed by a chamber of commerce. It answers “which country is this from?” for statistical, labelling, and general regulatory purposes. It does not, by itself, get you a tariff reduction.
Proof of preferential origin. This is the one that changes the duty you pay. Georgia’s Deep and Comprehensive Free Trade Area (DCFTA) with the European Union has applied provisionally since 1 September 2014, alongside free trade agreements with China, Türkiye, the EFTA states, the United Kingdom, and the CIS countries (Georgia’s free trade regimes). To claim preferential treatment on entry into the European Union, the consignment normally needs a Movement Certificate EUR.1.
Key facts on the EUR.1 that buyers should know:
- It is issued by the customs authority of the exporting country — in Georgia, the Revenue Service — on application by the exporter, on a pre-printed serial-numbered form (Movement Certificate EUR.1, Access2Markets).
- It is valid for ten months from the date of issue. If it expires before your customs entry is made, the preference is at risk.
- The exporter must be able to prove originating status on request and retain the supporting evidence for at least three years.
- For low-value consignments, an origin declaration on the invoice can substitute for the EUR.1 under the applicable protocol — worth asking about for samples and trial lots, where the administrative cost of a EUR.1 is disproportionate.
For wild-harvested plants gathered in Georgia, originating status is about as clean as it gets: the goods are wholly obtained in the country. Where originating status becomes genuinely arguable is with blends and processed preparations that incorporate material from elsewhere. If you are buying a blend, ask how origin was determined.
The Phytosanitary Certificate: The Honest Answer
This is the document buyers ask for first, and the honest answer surprises them.
A phytosanitary certificate is a government-to-government plant health attestation, issued by the exporting country’s National Plant Protection Organisation on the model form set out under the International Plant Protection Convention (IPPC) standard ISPM 12. Its purpose is to prevent the international spread of plant pests. In Georgia it is issued by the National Food Agency.
For imports into the European Union, dried herbs generally do not require one. Under Regulation (EU) 2016/2031 and Commission Implementing Regulation (EU) 2019/2072, a phytosanitary certificate is required for the plants and plant products listed in Annex XI — and within the herbs and spices category, that requirement falls on seeds for sowing and on fresh herbs and spices such as fresh garlic, ginger, and fresh culinary herbs. Dried herbs and spices are generally outside it, on the straightforward logic that dried plant material cannot be grown on after import and therefore does not carry the same pest-introduction risk (CBI, buyer requirements for herbs and spices; EU plant health rules).
So why does the trade ask for it constantly? Four legitimate reasons, and one bad one.
- Other destinations do require it. The European Union’s position is not universal. Plenty of importing countries require a phytosanitary certificate for dried plant material regardless. Check your own destination rather than generalising from the EU.
- Seed is a genuinely different case. Nettle seed is a seed, and seed rules are stricter than leaf rules. What matters is the declared intended use — seed destined for processing into food, oil, or extract is not seed for sowing — but this is precisely the kind of distinction that needs to be stated clearly on the documents rather than left for a border officer to infer.
- Your customer’s contract may require it even where the law does not. A specification inherited from a pharmaceutical or retail customer often lists it as mandatory.
- It is cheap insurance. Obtaining one is not expensive or slow relative to the value of a held consignment.
The bad reason: treating a phytosanitary certificate as a quality or food-safety document. It is neither. It attests to plant health — freedom from quarantine pests — and says nothing whatsoever about moisture, pesticide residues, heavy metals, or microbiological quality. A buyer who accepts a phytosanitary certificate as evidence of product quality has confused two entirely different regimes.
Our position: we can arrange a phytosanitary certificate through Georgia’s National Food Agency where a shipment needs one. Tell us at the quotation stage rather than after the goods are packed, and confirm the requirement with your own broker rather than assuming it either way.
The Food-Safety and Quality Set
This is where the substantive product assurance actually lives.
Certificate of Analysis (CoA). The laboratory result for the specific lot against the agreed specification. European buyers frequently require that testing be performed by an ISO/IEC 17025-accredited laboratory and that the certificate be recent — often less than six months old (CBI).
We will say plainly what we say everywhere else on this site: BioGroup does not yet operate its own laboratory and does not issue its own Certificate of Analysis. We arrange independent third-party analysis on request. That is a limitation, and we would rather state it than paper over it — but it is worth understanding that a self-issued certificate from a supplier’s own uncredentialed bench is worth considerably less to your quality team than an accredited third-party report on the same lot. If you are evaluating suppliers, the question to ask is not “do you issue a CoA?” but “which accredited laboratory tested this lot, and may I see the raw report?”
Specification sheet. The agreed parameters the CoA is measured against. This should be signed off before the first shipment, not reverse-engineered from the first result. Our full guide to writing one is here.
Supporting statements. Depending on your quality system, expect to request some or all of: a HACCP or food-safety management statement, an allergen declaration, a non-GMO statement, a non-irradiation statement, a TSE/BSE-free declaration, and a food-contact conformity declaration for the packaging materials. These are attestations, not test results, and should be treated as such.
Entry-Side Documents: Yours to File, Not Ours
A recurring source of friction is the assumption that the exporter handles everything up to the buyer’s door. Under most Incoterms rules — and under food law generally — several obligations are unambiguously the importer’s.
Customs entry. The import declaration is made by the importer or their broker in the destination country. Under DDP the seller takes this on, which is one of several reasons DDP is rarely a good idea across a border the seller does not operate in.
Pre-notification, where applicable. Consignments subject to official border controls require a Common Health Entry Document (CHED) raised in the European Union’s TRACES NT system by the importer or their representative, with pre-notification typically at least 24 hours before arrival, or around 4 hours for air freight (CHED and TRACES). Whether your specific product and origin fall under increased official controls is set out in Regulation (EU) 2019/1793 and its annexes, which are revised periodically — check the current version for your commodity and origin, because entries move on and off those lists.
Food business obligations. As the importer you become a food business operator placing the product on the market, with the traceability, labelling, and due-diligence duties that follow from it. The exporter supplies documents; the exporter does not discharge your obligations.
Organic, If You Need It
Organic is its own parallel documentary regime. Imports into the European Union under Regulation (EU) 2018/848 require an electronic Certificate of Inspection (e-COI) issued through TRACES, alongside certification of the operator by an approved control body.
We are direct about this: BioGroup is not certified organic. Our material is wild-harvested from unsprayed land that receives no agricultural inputs — which is a genuine and meaningful thing — but it is not the same as certified organic status, and we will not blur the two. Wild collection can be brought within organic certification, and a buyer who needs certified organic material needs a certified operator. If that is your requirement, say so at the enquiry stage so nobody wastes time.
A Practical Document Checklist
| Document | Issued by | When you need it |
|---|---|---|
| Commercial invoice | Exporter | Always |
| Packing list | Exporter | Always |
| Bill of Lading / CMR / Air Waybill | Carrier or forwarder | Always, per transport mode |
| Certificate of Origin | Chamber of commerce | Commonly; check destination rules |
| EUR.1 movement certificate | Exporting country’s customs authority | To claim preferential duty under a free trade agreement |
| Phytosanitary certificate | Exporting country’s plant protection authority | Where the destination requires it; generally not for dried herbs entering the EU |
| Certificate of Analysis | Accredited third-party laboratory | Whenever a specification is contractually binding |
| Specification sheet | Agreed between buyer and seller | Before the first shipment |
| CHED via TRACES NT | Importer or representative | Where official border controls apply |
| e-COI via TRACES | Approved organic control body | Certified organic consignments only |
| Insurance certificate | Insurer | Under CIF and CIP; otherwise per agreement |
Partner with BioGroup
We supply wild-harvested Georgian botanicals — St John’s Wort, Immortelle, Rosehip, Nettle, Nettle Seed, Dandelion, Blackberry Leaf, and Eucalyptus — with traceability to the harvest area and the export documentation set described above. Third-party laboratory analysis is arranged on request; we do not issue our own Certificate of Analysis.
Tell us your destination country and your customer’s documentary requirements at the enquiry stage and we will confirm exactly which of the documents above your consignment will carry. Get in touch, or read more on how we wild-harvest and dry medicinal plants and why source medicinal herbs from Georgia.
