EU Caviar Rules

EU caviar rules operate through two independent systems: wildlife trade controls govern protected species, while food law governs hygiene, imports and consumer information. Commercial consignments must also clear customs and applicable sanctions; permission under one system does not replace permission under another.

EU caviar rules at a glance

The table identifies the principal instruments, not a complete clearance checklist. Read the Northern Ireland qualifications below before applying an EU row to a Belfast consignment.

Wildlife permits and species coverage

Regulation (EC) No 338/97 places Acipenser brevirostrum and Acipenser sturio in Annex A. All other sturgeons and paddlefish fall under the order-wide Acipenseriformes entry in Annex B, including beluga, kaluga, Siberian, Russian, white and Adriatic sturgeons, sterlet and American paddlefish. These are legal listings, not food definitions.

For commercial Annex B imports, Article 4 requires an EU import permit alongside the exporting country's CITES export permit, or a re-export certificate where appropriate. Obtain the documents before dispatch and arrange their presentation to customs at an authorised wildlife entry point. Article 5 governs exports and re-exports from the EU.

Annex A commercial activity is generally prohibited, subject to narrowly defined exemptions and certificates under Article 8. Farmed origin does not, by itself, remove wildlife controls. The law and regulation hub explains the wider framework, while importing and re-exporting covers the document sequence.

Suspensions and scientific review

As of November 2026, Implementing Regulation (EU) 2025/6, replacing 2023/2770, is current; a draft replacement is pending. Its application depends on the listed species, country and any specimen or source restrictions; it is not a blanket prohibition on caviar.

Before committing a shipment, check the current suspension regulation's entries for sturgeons and paddlefish, and obtain a current species-and-country check from the importing member state's CITES management authority, including the relevant source and any applicable exemption.

The Scientific Review Group brings together member-state scientific authorities and evaluates whether trade could harm species conservation. Its opinions inform import decisions; a negative opinion can prevent permit issuance before a formal suspension appears in legislation. Checking only the suspension regulation is therefore insufficient.

Labels, repacking and internal EU trade

Regulation (EC) No 865/2006 supplies the implementation rules. Articles 64 and 65 connect caviar trade to marking requirements; Article 66(6) requires non-reusable labels on individual primary containers. Where the label does not seal the container, the packaging must reveal opening.

Article 66(7) reserves processing, packaging and repackaging for export, re-export or intra-EU trade to plants licensed by the member state's management authority. Those plants receive registration codes and must retain quantity records for inspection. A food establishment approval and a wildlife repacking licence are separate permissions.

Ordinary Annex B caviar moving between member states does not need a fresh CITES import permit at each internal border. However, Article 8(5) of 338/97 requires lawful acquisition and, where relevant, lawful introduction to be demonstrable. Keep invoices, lot links and import documentation available; a CITES label supports traceability but does not independently prove the contents.

The 125 g personal-effects exemption

Article 57(5)(a) of 865/2006 exempts eligible personal introductions of up to 125 g of Acipenseriformes caviar per person from the usual wildlife documents, provided containers are individually marked under Article 66(6). The other conditions in Article 57 also apply. This is an Annex B personal effects provision, not an allowance for commercial stock or Annex A caviar.

The limit is per person, not per tin, and does not displace food, customs or sanctions rules. The Court of Justice confirmed in Case C-87/20 that, without the required documents, exceeding the limit does not entitle the traveller to retain the first 125 g.

Food hygiene and import approval

Regulation (EC) No 853/2004 sets specific hygiene requirements for food of animal origin, including fishery products in Annex III, Section VIII. It operates alongside general hygiene duties under 852/2004. Retail exemptions and activities requiring establishment approval must be assessed against the actual business operation, rather than its description as a shop or restaurant.

For commercial imports, Regulation (EU) 2017/625 supplies the official-controls framework. Check the exporting country's eligibility under Implementing Regulation (EU) 2021/405, particularly Annex IX for fishery products and the relevant aquaculture control-plan requirements. Read restrictions in the country entry: permission for wild-caught fishery products does not establish permission for farmed caviar.

Delegated Regulation (EU) 2022/2292 also requires the relevant establishments to appear on the Commission's approved lists, accessible through TRACES. Country eligibility alone does not approve a particular processor. Arrange the appropriate official certification under Implementing Regulation (EU) 2020/2235 and entry through a border control post authorised for the product, with advance notification and the applicable Common Health Entry Document.

Confirm both the food-control route and the wildlife customs route before booking transport. A facility suitable for one clearance is not automatically suitable for the other, and release under food controls does not authorise release under wildlife law.

Additives and consumer information

Annex II, Part E, category 09.3 of Regulation (EC) No 1333/2008 authorises boric acid, E284, and sodium tetraborate or borax, E285, only for sturgeons' eggs. The maximum is 4,000 mg/kg expressed as boric acid. Regulation (EU) No 1169/2011 governs food information, including a non-misleading name, ingredients, fish allergen identification, net quantity, date marking, storage conditions and the responsible food business operator's details, subject to applicable exemptions. Mandatory information must be understandable in the market where the food is sold. Customs terminology does not settle the permitted retail name.

Keep invoices, lot links and import documentation available; a CITES label supports traceability but does not independently prove the contents.

Article 35 of Regulation (EU) No 1379/2013 does not impose its special fishery-product consumer information on prepared caviar under heading 1604. That heading falls in Annex I category (h), outside Article 35's categories (a), (b), (c) and (e). General food information and wildlife labelling still apply; caviar labelling laws covers their interaction.

Registered by Implementing Regulation (EU) 2025/342, Caviar d'Aquitaine (PGI) covers unovulated eggs of Acipenser baerii baerii meeting the registered geographical and production specification, not all caviar from that species.

Customs and sanctions

For 2026, the Combined Nomenclature distinguishes 1604 31 00, caviar, from 1604 32 00, caviar substitutes prepared from fish eggs. Use the applicable TARIC measures and origin rules for the actual consignment; neither a tariff code nor EU repacking changes the underlying wildlife origin.

Article 3i and Annex XXI of Regulation (EU) No 833/2014 prohibit the purchase, import or transfer of listed caviar and caviar substitutes that originate in or are exported from Russia, subject to any applicable exceptions. A CITES permit cannot override that prohibition. Routing Russian-origin caviar through another country is not a solution.

Article 3h and Annex XVIII separately restrict exports of listed luxury goods to Russia, including caviar and substitutes, subject to applicable value thresholds, conditions and exemptions. Screen counterparties and the current consolidated sanctions legislation, including origin, transaction restrictions, applicable thresholds and exemptions, before proceeding.

Northern Ireland and neighbouring jurisdictions

Northern Ireland is not an EU member, but EU wildlife trade rules apply there under the Windsor Framework. For those rules, EU to Northern Ireland movements are internal movements; Great Britain to Northern Ireland movements are imports. UK authorities issue the relevant Northern Ireland permits.

EU food law generally applies to Northern Ireland production and ordinary food supply. Eligible retail goods moved from Great Britain under the Northern Ireland Retail Movement Scheme can instead follow specified UK public-health and consumer-protection standards, subject to scheme conditions and continuing animal-health safeguards. Do not extend that exception to ordinary EU-bound wholesale trade.

Great Britain has its own amended wildlife and food-law regimes: follow UK caviar rules, not this EU checklist. Switzerland is outside the EU, so an EU permission does not establish Swiss admissibility. Likewise, US entry requires a separate assessment under US wildlife and food requirements, not recognition of an EU permit.