Rajasthan Herbal Extract Company Unlocks EUR 1.5M Moringa EU Market After Novel Food Navigation

Curated by Vinod Kumar Jain & Amit Jain · All Frontier Global · free, no login

India-Netherlands

Challenge

A Rajasthan-based herbal extract company (moringa leaf powder, amla extract, neem products) had been selling to Indian Ayurvedic companies and attempted to export to EU supplement companies. They discovered that moringa powder had a complex novel food status in EU — it was not on the EU novel food list but had been on the market before 1997 in some EU countries as a botanical ingredient. The company was confused by conflicting information and afraid to ship.

Solution

AJG engaged an EU food law specialist in Brussels. A thorough analysis found: moringa leaf powder had been consumed in France and Portugal prior to 1997 as a traditional food ingredient from overseas territories — establishing a significant history of food use in EU under Regulation 2015/2283 exemption. Documentation of traditional use was compiled from French colonial-era botanical records and Portuguese food database. The Dutch importer was provided with a legal opinion supporting the non-novel food classification. FSSAI and APEDA export certificates were obtained.

Outcome

Moringa leaf powder cleared as non-novel in the Netherlands and France based on traditional use documentation. First EU shipments commenced month 6. Annual EU moringa revenue: EUR 1.5M. The company subsequently filed for novel food authorisation for their concentrated moringa extract (a novel product with no pre-1997 history) — separate from the leaf powder.

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