Regulatory Review Comes First in the German Food Market
As European consumer interest in K-Food continues to grow, an increasing number of Korean companies are considering entry into Germany across categories such as ramen, kimchi, beverages, and health foods.
However, Germany is one of the more demanding EU markets in terms of food regulatory compliance. A single labeling error can lead to customs delays or product recalls, while missing certifications may make negotiations with distributors difficult.
Entering the German food market is therefore not simply an export process.
Companies need to review EU food law, labeling, certification, packaging, and import/distribution agreements as part of one integrated compliance strategy.
EU Food Law and Germany’s Food Safety Framework
The foundation of EU food regulation is the General Food Law Regulation, Regulation (EC) No 178/2002.
This regulation establishes the basic framework for:
- food safety;
- risk analysis;
- the precautionary principle; and
- traceability.
In Germany, food safety oversight and market surveillance are carried out by the competent federal and state authorities, including the Federal Office of Consumer Protection and Food Safety (BVL) and the relevant authorities of the Länder.
To distribute food products in Germany, companies must establish controls not only over the safety of the finished product, but also over:
- raw materials;
- manufacturing processes;
- distribution channels; and
- mandatory product information.
Labeling Is a Core Issue in German Food Exports
Packaged food sold in Germany must comply with the Food Information to Consumers Regulation (FIC), Regulation (EU) No 1169/2011.
Key mandatory labeling information generally includes:
- name of the food;
- list of ingredients;
- allergens;
- net quantity;
- minimum durability date or use-by date;
- storage conditions;
- name and address of the food business operator;
- country of origin or place of provenance, where applicable; and
- nutrition declaration.
Products sold to German consumers must provide the mandatory information in German.
Even where Korean or English labeling can technically be added, products may encounter problems at customs, marketplace onboarding, or distribution if the required German-language information is missing.
Particular care is required for traditional fermented Korean foods such as:
- gochujang;
- doenjang;
- soy sauce; and
- kimchi,
especially in relation to allergen declarations for ingredients such as soy, wheat, and sesame.
Certification and Hygiene Requirements Should Be Prepared in Advance
The EU food hygiene rules, including Regulation (EC) No 852/2004, require food businesses to maintain hygiene-management systems based on HACCP principles.
Even if a Korean manufacturer already holds HACCP certification, German buyers or EU importers may separately request:
- hygiene-management documentation compliant with EU standards;
- manufacturing-process records; and
- traceability documentation.
For supply to major German distributors, IFS Food certification may also function as an important commercial requirement in practice.
Where organic products are exported, separate review is required under the EU Organic Regulation, Regulation (EU) 2018/848, including applicable certification and import procedures.
Check Whether the Product Qualifies as a Novel Food
The EU Novel Food Regulation, Regulation (EU) 2015/2283, generally treats foods or food ingredients that were not consumed to a significant degree within the EU before 15 May 1997 as novel foods.
If a product qualifies as a novel food, prior authorization from the European Commission may be required, and the process may involve a safety assessment by EFSA.
For Korean food products, potential review may be required for categories such as:
- ginseng-derived products;
- highly concentrated extracts;
- products with enhanced functional ingredients;
- certain seaweed ingredients; and
- certain fermented ingredients.
The result may vary depending on the raw materials, strain, additives, fermentation method, and functional claims used in products such as kimchi, gochujang, doenjang, and soy sauce.
Accordingly, Novel Food status should be reviewed before export.
Major Regulatory Changes in 2026
Several regulatory developments in 2026 are particularly relevant to food exporters entering the German and EU markets.
Packaging and Packaging Waste Regulation
The Packaging and Packaging Waste Regulation (PPWR) will begin applying directly across EU Member States from 12 August 2026.
Food exporters should review product-specific obligations regarding issues such as:
- PFAS restrictions in food-contact packaging;
- recyclability requirements; and
- packaging minimization and space-efficiency requirements.
Strengthened Listeria Standards
From 1 July 2026, stricter microbiological requirements will become increasingly important, particularly for ready-to-eat (RTE) foods.
Companies exporting chilled foods, side dishes, and mixed ready-to-eat products should review microbiological-control standards and supporting test data in advance.
BPA Restrictions for Food-Contact Materials
The transition period for strengthened restrictions on BPA in food-contact materials will also become increasingly relevant during 2026.
Companies should review whether BPA-related restrictions apply to:
- can coatings;
- lids;
- containers; and
- food packaging films.
Import Partner Agreements Should Clearly Allocate Regulatory Responsibility
Entry into the German market often takes place through a local importer or distributor.
In these cases, the contract should address not only delivery and payment terms, but also who bears responsibility for regulatory compliance.
The following matters should be clearly allocated in advance:
- designation of the responsible operator within the EU;
- responsibility for reviewing labeling and mandatory product information;
- allocation of recall-related costs;
- scope of exclusive or non-exclusive distribution;
- minimum purchase quantities and termination rights; and
- governing law and dispute-resolution procedures.
If responsibility is unclear when a labeling error, certification issue, or recall occurs, the Korean exporter may incur significantly greater costs than anticipated.
Why Legal Review Is Important Before Entering the German Food Market
The German food market has high entry requirements, but companies with a well-designed compliance system can build a stable distribution platform.
Food labeling, certification, Novel Food classification, packaging requirements, and importer agreements are difficult to address effectively only after the product is ready for shipment.
Reviewing these issues during the product development, production, packaging selection, and distribution-contract stages can reduce unnecessary customs delays and distribution risks.
DECENT Law Firm provides integrated support for companies preparing to enter the German food market, including:
- review of EU food regulations;
- labeling compliance;
- Novel Food analysis;
- packaging regulation review; and
- import and distribution agreement review.