For EU imports of tea originating in China, check the current product-country-hazard row before booking, route the consignment through a suitable border control post, and have the EU operator responsible for the consignment submit Part I of a CHED-D in TRACES NT before arrival. On 24 September 2026, tea under CN 0902 remained in Annex I to Regulation (EU) 2019/1793 for pesticide residues, at a 20% overall frequency of identity and physical checks. That does not mean only 20% of shipments need a CHED-D, and it does not make a supplier COA an official release document.
Read the current EU control route before collecting documents
Regulation 2019/1793 is amended regularly. A checklist copied from an earlier shipment can be wrong even when the product and supplier have not changed. Freeze the legal snapshot by date, then match the commodity description, CN code, country of origin and named hazard. Do not search only by the commercial description “green tea.”
| Route | Border-control consequence | Evidence consequence |
|---|---|---|
| Annex I product-country row | CHED-D route; documentary checks on consignments and identity/physical checks at the Annex frequency | No third-country official certificate or official analytical results solely because the goods are in Annex I |
| Annex II product-country row | CHED-D route plus the listed special entry conditions | Official certificate, consignment analytical results and identification controls apply under Articles 9 to 11 |
| Not listed in either annex | No 2019/1793 increased-control route solely on that basis | General food, customs, pesticide-MRL, organic, plant-health or other applicable rules may still require action |
The current Annex I row covers “tea, whether or not flavoured,” CN 0902, originating in China. It identifies pesticide residues as the hazard and sets 20% for identity and physical checks. The pesticide footnotes cover residues in the EU control programme that can be analysed by GC-MS and LC-MS multi-residue methods and specifically include tolfenpyrad. Use the separate EU pesticide MRL guide to build the private testing scope; the Annex listing and the legal MRL database answer different questions.
Build an eight-field CHED-D readiness record
| Control field | Record before dispatch | Stop condition |
|---|---|---|
| Legal snapshot | Consolidated regulation URL, annex, check date, product, origin, hazard and check frequency | No dated evidence that the current row was reviewed |
| Classification and origin | Product description, CN code, formulation and non-preferential origin basis | Invoice, packing list and customs classification do not reconcile |
| Responsible EU operator | Legal name, TRACES role, contact and who submits or amends Part I | The supplier, broker and importer each assume another party will pre-notify |
| Entry facility | First-arrival BCP competent for CHED-D, control-point plan if applicable, booking acceptance and hours | Carrier route arrives at a facility not designated for the required control |
| Consignment identity | Exporter, importer, destination, container, seal, packages, weights, lot, voyage and arrival data | Identifiers differ across commercial documents, labels and CHED-D |
| Supporting files | Commercial and transport documents, product specification, traceability and agreed residue evidence | Missing or outdated records prevent Part I completion or risk review |
| Notification evidence | CHED-D reference, submission timestamp, estimated arrival and amendment owner | Deadline cannot be met or a material change is left unreported |
| Release evidence | Finalised CHED-D, control outcome, customs release link, charges, samples and any follow-up | Goods are moved, split or released before the competent decision |
Use an eight-step pre-alert and release method
1. Freeze the rule snapshot
Open the latest EUR-Lex consolidated text, not a search-result extract or an old broker memo. Capture the version date and the complete annex row. The European Commission says these lists are reviewed at least every six months, so repeat this check for each booking and whenever dispatch is delayed.
2. Prove the product-origin match
Map the actual goods to CN 0902 and confirm country of origin. A transit port or invoicing country does not automatically change origin. If the shipment contains botanicals, flavourings, extracts or composite presentation, obtain classification advice instead of assuming every tea-named product follows the same row. Align this record with the flavoured-tea composition checklist.
3. Assign the EU-side owner and facility
The operator responsible for the consignment uses the CHED to notify the competent authority. Name that party and its backup in the purchase file. Confirm that the first-arrival BCP is designated for feed and food of non-animal origin and can handle CHED-D controls; use the Commission's current Member State lists rather than assuming that every seaport or airport has the same competence.
4. Reconcile one consignment identity
Create a single data sheet for legal parties, origin, dispatch country, destination, CN code, description, package count, gross/net weight, container and seal, lot and transport. The TRACES guidance shows these as operational Part I fields. Compare the sheet with the lot-control record and the supplier document pack before submission.
5. Complete Part I without upgrading private evidence
Attach relevant commercial, transport and risk-control records requested by the responsible operator or authority. A supplier COA, buyer-arranged pesticide report or pre-shipment inspection can support risk management, but it is not the competent authority's finalised CHED-D and does not remove the possibility of official sampling. Review private reports using the green tea COA method.
6. Submit the pre-notification on time
Implementing Regulation 2019/1013 sets the normal minimum at one working day before expected arrival. Where logistical constraints prevent that timing, the BCP authority may apply a minimum of four hours; this is a permitted authority route, not an automatic importer option. Set an earlier internal deadline and update the estimated arrival when the vessel, flight or road movement changes.
7. Budget for the control branch
All covered consignments enter the documentary-control workflow. The 20% figure is an overall frequency for identity and physical checks across the Annex entry, not a promise that a particular container will bypass examination. Pre-agree who handles presentation, sampling access, terminal movement, storage, demurrage, laboratory delay and communication. Keep the tea under hold until the official decision is known.
8. Release only against the final record
Regulation 2019/1793 says customs may allow free circulation only on presentation of a duly finalised CHED confirming compliance. Reconcile the final document to the customs declaration and received goods, then archive the submitted Part I, authority outcome, amendments, charges and any official analytical result. Feed discrepancies into the arrival quarantine and release workflow.
Know which requirement controls the decision
- Legal requirement: EU official-control rules, the current 2019/1793 annex and applicable Member State procedures control entry, notification and release.
- Official guidance: Commission and TRACES instructions explain system roles and fields but do not replace the regulation.
- Voluntary standard: a food-safety or quality standard can improve document control but cannot issue or finalise a CHED-D.
- Trade reference: a broker checklist or prior shipment file can help planning but may be outdated or port-specific.
- Buyer specification: can require a private residue panel, reporting limit, lab scope, lot link and review rule beyond the border-control sampling frequency.
- Contract requirement: should allocate data, notice, testing, delay, charge and cooperation duties; it cannot bind the competent authority or guarantee release.
Common importer mistakes
- Reading 20% as “only 20% of shipments need CHED-D.”
- Confusing Annex I with Annex II certificate and official-analysis requirements.
- Checking the regulation at quotation but not before dispatch.
- Using dispatch country where the annex requires country of origin.
- Assuming any EU port can perform the required CHED-D control.
- Leaving TRACES ownership unclear between importer, broker and forwarder.
- Submitting inconsistent weights, lots, seals or arrival details.
- Treating a private COA as official border release.
- Planning no time or cost branch for sampling and laboratory delay.
- Moving or splitting goods before the CHED is finalised.
Practical conclusion
A reliable entry file follows current annex - product and origin - responsible operator - competent BCP - reconciled data - timely CHED-D - control contingency - final release record. Make the check shipment-specific and dated. For a real order, review Yunjing Tea's sample-to-shipment quality-control context and send the tea, formulation, destination, route and evidence list early; the EU importer and its customs and regulatory advisers remain responsible for classification, notification and entry decisions.
Sources checked 24 September 2026: the 30 June 2026 consolidated Regulation (EU) 2019/1793, especially Articles 4 to 6 and 12 and Annex I; Regulation (EU) 2017/625, especially Articles 47, 49, 56 and 57; Implementing Regulation (EU) 2019/1013 on prior notification; the Commission's current BCP and control-point directory; and official TRACES NT CHED-D Part I guidance. Recheck the live annex, product classification, origin, entry facility and Member State procedure for every consignment.
