PAH in smoked spices: what EU Regulation 2023/915 actually covers
Buyers who specify smoke-cured spices for the EU or UK are routinely told that polycyclic aromatic hydrocarbon limits rule them out. For cardamom that is not what the regulation says, and the distinction is worth understanding rather than taking on trust — from us or from anyone else.
In short
- Commission Regulation (EU) 2023/915 consolidated the EU's contaminant rules, replacing Regulation 1881/2006.
- It sets maximum levels for benzo(a)pyrene and for the sum of four PAHs across specified food categories, including certain smoked and dried products.
- Cardamom is not among the dried-spice entries those PAH limits cover, so Bhatti-cured cardamom is not barred from the EU or UK on PAH grounds.
- That is a statement about scope, not about the absence of PAH. Smoke contact is the purpose of a bhatti kiln, and an honest supplier measures and discloses the result rather than claiming there is none.
- Aflatoxin, which the same regulation does cover for spices, is the limit that actually rejects cardamom consignments at EU borders.
- Regulatory scope changes. Re-check the consolidated text before relying on this for a new contract season.
What PAHs are, and why smoke-curing raises the question
Polycyclic aromatic hydrocarbons are a family of compounds formed during incomplete combustion. In food they arise wherever smoke, flame or hot combustion gases contact the product — grilling, roasting over fire, and smoking. Benzo(a)pyrene is the most studied of them and is used as a marker for the group.
Traditional bhatti curing puts warm smoke in direct contact with cardamom pods for many hours, which is precisely where the spice's signature campfire note comes from. So the question a European buyer asks — does this create a PAH problem — is a reasonable one, not an obstacle invented by the buyer.
The answer turns on what the regulation actually enumerates.
What Regulation 2023/915 sets limits for
Regulation (EU) 2023/915 replaced Regulation 1881/2006 as the consolidated instrument setting maximum levels for contaminants in food. Its Annex lists food categories one by one, and a maximum level applies to a product only where that product falls inside a listed category.
For PAHs, the Annex sets levels for benzo(a)pyrene and for the sum of benzo(a)pyrene, benz(a)anthracene, benzo(b)fluoranthene and chrysene — commonly written as PAH4 — across categories including oils and fats, smoked meat and fish, cereals, infant food, and certain dried and smoked plant products.
The dried-spice entries carrying PAH limits are specific. Cardamom is not among them. A cardamom consignment therefore has no PAH maximum level to exceed under this regulation, which is why smoke-cured lots continue to move into the EU lawfully.
Open the consolidated text on EUR-Lex and read the Annex section on polycyclic aromatic hydrocarbons. The point of this page is not that you should believe us; it is that this is a short check against a primary source, and any supplier making the claim should be able to point you at it.
The UK position after Brexit
The UK retained the EU contaminant framework in domestic law at the end of the transition period, and the substance of the PAH provisions carried across. The practical position for cardamom is therefore the same: no PAH maximum level applies to it, and smoke-cured lots are not barred on that basis.
What changed is the administration. Import notification is filed through UK systems by the UK importer of record rather than through EU ones, and divergence between the two regimes is possible over time. Check current UK guidance alongside the EU text rather than assuming they stay aligned indefinitely.
What actually gets cardamom rejected
It is worth being clear about where the real risk sits, because a buyer focused on PAH may be watching the wrong number.
Aflatoxin is the contaminant that rejects spice consignments, and Regulation 2023/915 does set maximum levels for it in spices. Aflatoxins are produced by Aspergillus moulds growing on inadequately dried crops, which makes moisture control at curing the single most important process variable in this trade — more important than which drying line a lot went through.
| Contaminant | Maximum level applies to cardamom? | What it depends on |
|---|---|---|
| Aflatoxin B1 and total aflatoxins | Yes | Moisture control during curing and storage |
| Pesticide residues (MRLs) | Yes, set separately from 2023/915 | Cultivation practice at the farm |
| PAH4 / benzo(a)pyrene | No — cardamom is not among the listed dried-spice entries | Would depend on smoke contact if it applied |
What to ask a supplier of smoke-cured cardamom
A supplier who answers the first question with a shrug is telling you they buy from an aggregator and cannot trace the cure. That matters more for your specification than the PAH question does.
For our part: we test and report PAH on every lot regardless of the exemption, because the honest claim is that the figure is measured and disclosed, not that it is absent.
- Which drying line was this lot cured on — direct-smoke bhatti, or indirect flue?
- Do you measure PAH even though no maximum level applies, and will you show me the result?
- What is the aflatoxin B1 figure for this lot, and which laboratory produced it?
- What moisture did the lot finish at, and how is that controlled?
- Can you produce the phytosanitary certificate and certificate of origin before I place the order rather than after?
Questions
Does EU Regulation 2023/915 set a PAH limit for cardamom?
No. The regulation sets maximum levels for benzo(a)pyrene and for the sum of four PAHs across specified food categories, including certain dried and smoked products, but cardamom is not among the dried-spice entries those limits cover. Smoke-cured cardamom is therefore not barred from the EU on PAH grounds. Verify it in the Annex on EUR-Lex — it is a short check and worth doing rather than taking any supplier's word for it.
Is Bhatti-dried black cardamom legal to sell in the EU and UK?
Yes. No PAH maximum level applies to cardamom under EU Regulation 2023/915, and the UK retained the same framework in domestic law. Bhatti-cured lots move lawfully into both, provided they meet the limits that do apply — aflatoxin above all, plus pesticide MRLs.
Is smoke-dried cardamom PAH-free?
No, and any supplier telling you it is has either not tested it or is not being straight with you. Smoke contact is the entire purpose of a bhatti kiln, so PAH is present by design. The correct claim is that no maximum level applies to cardamom under the regulation and that the figure is measured and disclosed per lot, which is what we do.
What contaminant actually gets spice consignments rejected?
Aflatoxin, by a wide margin. It is produced by moulds that grow on crops that were not dried properly, so it is a consequence of curing and storage rather than of the crop itself. Regulation 2023/915 does set maximum levels for aflatoxins in spices, and controlling moisture is what keeps a lot under them.
Sources
Every regulatory claim on this page is checkable against a primary source. These are those sources, linked directly rather than summarised, because you should not have to take a supplier’s word for what a regulation says.
- Commission Regulation (EU) 2023/915 — consolidated text
The instrument itself. Read the Annex section on polycyclic aromatic hydrocarbons for the category list.
- EFSA — polycyclic aromatic hydrocarbons in food
The scientific assessment underlying the EU approach, including why PAH4 is used as the marker group.
- BfR — risk assessments on PAH in food
The German federal risk assessment body, useful where a German buyer's QA team wants a national reference.
- UK Food Standards Agency — import guidance
For the retained-law position and current UK import notification requirements.
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