Food Irradiation Labelling: Navigating Finnish Customs Compliance for Imported Food Products
When Missing Labels Stop a Shipment at Finnish Customs
Finnish Customs regularly inspects imported food products to verify compliance with EU food safety and labelling standards. In a recent case handled by LKOS Law Office, Customs detained shipments of a food product after laboratory analysis at the Finnish Customs Laboratory (Tullilaboratorio) confirmed that the product had been treated with ionising radiation — a process known as food irradiation — without any corresponding declaration on the packaging.
Under EU law, irradiated food products must be clearly labelled with the statement "irradiated" or "treated with ionising radiation" before they can be placed on the market. The absence of this declaration triggers a regulatory intervention, which can result in the goods being refused entry, destroyed, or — where the issue is remediable — admitted conditionally.
The Regulatory Framework for Irradiated Food in the EU and Finland
The treatment of foodstuffs with ionising radiation is governed at EU level primarily by Directive 1999/2/EC on the approximation of the laws of the Member States concerning foods and food ingredients treated with ionising radiation, and Directive 1999/3/EC establishing a Community list of foods and food ingredients authorised for treatment with ionising radiation. In Finland, these requirements are implemented through the Food Act (elintarvikelaki 297/2021) and related regulations, and enforced by Finnish Customs (Tulli) at the border as part of its import control mandate.
Irradiation is a legitimate food processing technique used to eliminate harmful bacteria, parasites, and insects from food products. It is widely applied to spices and dried herbs, where absorbed doses of up to 10 kGy (kilogray) are permitted. International bodies including the FAO, WHO, and IAEA have concluded that irradiated foods processed in accordance with Codex Alimentarius procedures are safe for consumption. The process does not make food radioactive, and extensive research — including long-term animal studies — has found no evidence of adverse health effects.
Nevertheless, EU consumer protection rules require that consumers are informed when food has undergone irradiation treatment. This mandatory labelling obligation applies regardless of the safety profile of the treatment and reflects the EU's commitment to consumer transparency and informed choice.
How the Case Was Resolved
The manufacturer a major international food company with an annual turnover of approximately USD 300 million had not been aware that its products required the irradiation declaration for EU market access. Upon being advised of the Finnish Customs findings, the company confirmed it would update its packaging without delay.
LKOS Law Office assisted the customer in assessing the regulatory position under the applicable EU directives and Finnish national legislation, preparing the necessary documentation and communications with Finnish Customs, and confirming the re-labelling approach required for conditional release of the detained shipments. Both shipments were ultimately admitted into the Finnish market on the condition that the products would be re-labelled to include the required irradiation declaration before being placed on the market.
Key Takeaways for Importers
This case illustrates a common compliance gap for companies exporting food products to the European Union. Even well-established manufacturers with significant global market presence can encounter regulatory obstacles when labelling requirements differ between jurisdictions. For irradiated food products, the EU labelling obligation is strict and non-negotiable products that do not carry the required declaration will be detained at the border.
Importers and manufacturers should review their product labelling against EU requirements before shipment, particularly for product categories such as spices, dried herbs, and certain other foodstuffs where irradiation is commonly used. Early engagement with experienced customs and regulatory counsel can help avoid costly delays and ensure smooth market access.
Frequently Asked Questions
What is food irradiation?
Food irradiation is a processing technique in which food products are exposed to ionising radiation — typically gamma or beta radiation — to eliminate bacteria, parasites, insects, and other organisms. It can also be used to inhibit sprouting in products such as potatoes and onions. The process takes place in licensed irradiation facilities and does not make the food radioactive.
Is irradiated food safe to eat?
Yes. International expert bodies including the FAO, WHO, and IAEA have concluded that food irradiated in accordance with Codex Alimentarius procedures is safe for consumption. Extensive research, including long-term studies, has found no evidence of adverse health effects. Irradiation may reduce the content of certain vitamins comparable to the effect of conventional cooking but does not produce harmful substances at the doses used in food processing.
What labelling is required for irradiated food in the EU?
Under EU Directive 1999/2/EC, irradiated food products must carry the statement "irradiated" or "treated with ionising radiation" on the packaging before they can be placed on the EU market. This applies to all irradiated food products and ingredients, regardless of the product category. Failure to include this labelling will result in enforcement action by national customs authorities, including detention of the goods at the border.
Can irradiated food be imported into Finland without the required labelling?
No. Finnish Customs enforces EU labelling requirements at the border. If irradiated food products arrive without the mandatory declaration, they will be detained. Depending on the circumstances, the goods may be refused entry, destroyed, or admitted conditionally for example, on the condition that they are re-labelled before being placed on the market. Importers should verify labelling compliance before shipment to avoid delays.
Contact Persons
For enquiries related to customs and product compliance matters, including food safety labelling and import controls, please contact:
Oscari Seppälä
Specialist Partner
LKOS Law Office
Liene Krumina
Managing Partner
LKOS Law Office
LKOS Law Office advises international companies on Finnish and EU customs law, product compliance, and food safety regulatory matters. If you have questions about importing food products into Finland or the EU, please contact us.