{"id":5112,"date":"2026-08-17T13:37:31","date_gmt":"2026-08-17T11:37:31","guid":{"rendered":"https:\/\/igifoodlaw.com\/?p=5112"},"modified":"2026-08-17T13:37:31","modified_gmt":"2026-08-17T11:37:31","slug":"eu-olive-oil-control-system-needs-improvement-blending-of-olive-oils-a-regulatory-gap","status":"publish","type":"post","link":"https:\/\/igifoodlaw.com\/en\/eu-olive-oil-control-system-needs-improvement-blending-of-olive-oils-a-regulatory-gap\/","title":{"rendered":"EU olive oil control system needs improvement. Blending of olive oils \u2013 a regulatory gap"},"content":{"rendered":"<p>The European Court of Auditors (ECA) has published Special Report 01\/2026, <em>\u201cOlive oil control systems in the EU \u2013 A comprehensive framework, but uneven application\u201d<\/em>. The Court assessed whether the EU control system ensures that olive oil placed on the EU market is authentic, safe and traceable as regards its origin. The audit covered the implementation of EU requirements since 2018 in Belgium, Greece, Spain and Italy.<\/p>\n<p><em><span style=\"color: #ff0000;\">IMPORTANT:<\/span> The content, concepts and materials published by IGI FOOD LAW constitute the intellectual property of IGI FOOD LAW and are protected by copyright law. We welcome inspiration from our work; however, we ask that our materials be used ethically and that IGI FOOD LAW\u2019s copyright and know-how be respected.<\/em><\/p>\n<p>The European Court of Auditors is an independent institution of the European Union responsible for auditing the proper and effective use of EU funds and assessing the implementation of EU policies and legislation. The ECA conducts audits and publishes special reports concerning specific areas of EU activity. Its recommendations are not legally binding, but they may lead to regulatory changes and changes in the way the European Commission and Member State control authorities operate.<\/p>\n<h3>Comprehensive rules, but inconsistent enforcement<\/h3>\n<p>Olive oil is one of the most extensively regulated food products in the EU. Member States are responsible for establishing national control systems, carrying out risk-based controls and applying effective, proportionate and dissuasive penalties. The controls are intended, among other things, to confirm that the quality and purity of olive oil correspond to the category declared on the label, that the product does not contain unacceptable contaminants and that its declared origin can be verified.<\/p>\n<p>However, the ECA concluded that Member States do not fully apply this framework. Among the shortcomings identified in the audited Member States were failures to carry out the required minimum number of controls, incomplete laboratory analyses and the exclusion of certain parts of the market from risk analyses. The Court also noted that the penalties applied are not always effective or dissuasive.<\/p>\n<h3>The actual quality of olive oil is one of the issues<\/h3>\n<p>Particularly noteworthy are the findings concerning compliance of olive oil with its declared category. Across the EU, physicochemical analyses showed a compliance rate of 93%, whereas the compliance rate for organoleptic assessments was only 68%. The ECA emphasises, however, that the results of official controls cannot be regarded as representative of the market as a whole, since controls are primarily targeted at products presenting a higher risk of non-compliance. Most infringements identified are detected through organoleptic assessment and are associated with deterioration in the quality of olive oil over time. According to the Court, this may be attributable, among other factors, to excessively long dates of minimum durability and certain production practices. This is particularly relevant for extra virgin olive oil. Its category is not determined solely on the basis of laboratory parameters. EU rules also require an organoleptic assessment performed by a certified tasting panel. In addition, 15 physicochemical parameters are examined for this category.<\/p>\n<h3>Unclear rules on blending olive oils<\/h3>\n<p>The ECA also identifies an important regulatory gap. The existing rules are not sufficiently clear regarding the blending of olive oils from different harvest years, or whether extra virgin olive oil may be blended with virgin olive oil and the resulting blend subsequently marketed as extra virgin olive oil. Member States apply different approaches in this respect. The Court therefore recommended that the European Commission clarify the rules governing the blending of different types of virgin olive oil, both those originating from different harvest years and those belonging to different categories. The deadline for implementing this recommendation is 2026.<\/p>\n<h3>Contaminant controls: pesticides well covered, other substances much less so<\/h3>\n<p>The Court generally assesses the system for controlling pesticide residues positively. The EU has established a minimum number of samples that Member States should analyse over a three-year period, while only a small number of cases involving exceedances of the applicable limits are identified. The system for controlling other contaminants, however, is considerably less developed. There is no EU requirement establishing a minimum number of such controls, and Member States themselves decide which contaminants to test for. Moreover, the audited Member States did not always adequately document their risk analyses or justify their selection of contaminants. The ECA paid particular attention to olive oil imported from third countries. Although imports correspond to approximately 9% of annual EU olive oil production, in the audited Member States imported olive oil was either not tested at all for pesticides and other contaminants or was subject to only very limited controls. The Court therefore recommended, among other things, that the Commission require Member States to explicitly include imported olive oil in their risk analyses. This recommendation is to be implemented in 2026.<\/p>\n<h3>Olive oil traceability does not always work<\/h3>\n<p>One of the report\u2019s most significant findings concerns traceability. For olive oil originating in the EU, it should be possible to trace its origin back to the geographical area where the olives were harvested and to the mill where they were processed. For olive oil originating outside the EU, traceability should extend at least to the country of origin. Business operators\u2019 documentation should make it possible to verify whether the origin information provided on the label corresponds to the actual origin of the product. The problem is that EU law does not specify in sufficient detail how and when authorities should verify traceability, for example by checking the place of origin or carrying out mass-balance checks. Nor has the Commission issued appropriate guidance. As a result, Member States have adopted different control models. Spain and Italy stand out in this respect, as they have introduced electronic registers recording movements of olives and olive oil. These two countries also regularly carry out mass-balance checks, comparing incoming and outgoing quantities and stocks \u2013 an important tool for preventing fraud.<\/p>\n<h3>ECA unable to confirm the origin of some of the olive oils tested<\/h3>\n<p>The Court also carried out its own case study on the traceability of olive oil available at retail level. Of the 24 bottles subject to mandatory origin labelling, all 16 olive oils produced in a single Member State could be successfully traced. Problems arose, however, in the case of blends. For two of the four olive oils originating from several Member States, it was not possible to trace the product back to the geographical area where the olives were harvested and milled. The contents of two of the four bottles containing olive oil of mixed EU and non-EU origin also failed to meet the traceability requirements. In practice, this means that for 4 of the 24 bottles analysed for which origin labelling was required, the Court was unable to fully confirm the declared origin of the olive oil. The ECA also points to difficulties in cooperation between Member States when tracing olive oil moved across borders.<\/p>\n<h3>Possible regulatory developments in the coming years<\/h3>\n<p>The report may have implications extending beyond an assessment of the current functioning of official controls. The ECA issued five recommendations to the Commission, with implementation scheduled for 2026\u20132028. In particular, they concern:<\/p>\n<ul>\n<li>strengthening Commission oversight of national control systems;<\/li>\n<li>clarifying the rules governing the blending of olive oils from different harvest years or belonging to different categories;<\/li>\n<li>improving contaminant controls, including controls of imported olive oil;<\/li>\n<li>clarifying the rules governing traceability controls;<\/li>\n<li>developing electronic registers recording movements of olives and olive oil and improving the interoperability of national traceability systems.<\/li>\n<\/ul>\n<h3>SIGNIFICANCE FOR BUSINESSES<\/h3>\n<p>For businesses operating on the olive oil market, the report is relevant not only as an assessment of the current control system. Some of the ECA\u2019s recommendations are due to be implemented as early as 2026, which may result both in changes or clarifications to the regulatory framework governing olive oil and in a more detailed approach by authorities to controls concerning origin, quality and contaminants. The ECA report may also be of practical importance to businesses in disputes concerning the commercial quality of olive oil, particularly where the classification of olive oil into a specific category is based on organoleptic assessment. The Court highlights a significant difference between the results obtained using the respective control methods: physicochemical analyses showed a compliance rate of 93%, whereas organoleptic assessments showed a compliance rate of 68%. At the same time, the ECA notes that although organoleptic assessment has the same legal status as physicochemical analysis, it is inherently subjective due to the complexity of sensory perception. Where an operator disputes the result, it may request two additional assessments by other tasting panels. The ECA\u2019s findings may therefore provide supporting arguments in proceedings before a competent authority, particularly where consequences for a business are based on a single negative sensory assessment. The report does not call into question the legal significance of organoleptic assessment, but highlights the characteristics of this method and the importance of mechanisms allowing its results to be verified.<\/p>\n<p>The report may also be useful in cases concerning the traceability and declared origin of olive oil. The ECA found that EU law does not specify how or when individual elements of traceability, such as place of origin or mass balance, should be checked, and that the absence of Commission guidance has resulted in different control methods being applied across Member States. It should nevertheless be remembered that the ECA report is not a source of law and does not, in itself, create rights or obligations for businesses. It may, however, constitute an important authoritative reference supporting legal arguments concerning the interpretation, application and enforcement of EU requirements.<\/p>\n<p><strong>If you have questions concerning the category, composition, origin, traceability, labelling or quality requirements applicable to olive oil, including requirements concerning olive oil used as an ingredient in other food products, contact the experts at IGI FOOD LAW.<\/strong><\/p>\n<p><strong>We support businesses both in the ongoing assessment of product and labelling compliance and in cases involving questions or disputes concerning the results of official controls and product classification.<\/strong><\/p>\n<p>Contact: <a href=\"mailto:igifoodlaw@igifoodlaw.com\" target=\"_blank\" rel=\"noopener\">igifoodlaw@igifoodlaw.com<\/a><\/p>\n<p><a href=\"https:\/\/www.eca.europa.eu\/ECAPublications\/SR-2026-01\/SR-2026-01_EN.pdf\" target=\"_blank\" rel=\"noopener\">REPORT\u00a0<\/a><\/p>\n","protected":false},"excerpt":{"rendered":"<p>The European Court of Auditors (ECA) has published Special Report 01\/2026, \u201cOlive oil control systems in the EU \u2013 A comprehensive framework, but uneven application\u201d. The Court assessed whether the EU control system ensures that olive oil placed on the EU market is authentic, safe and traceable as regards its origin. The audit covered the [&hellip;]<\/p>\n","protected":false},"author":5,"featured_media":5110,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[3],"tags":[],"class_list":["post-5112","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-uncategorized"],"acf":[],"yoast_head":"<!-- This site is optimized with the Yoast SEO plugin v28.2 - https:\/\/yoast.com\/product\/yoast-seo-wordpress\/ -->\n<title>EU olive oil control system needs improvement. 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