Sector hazards

Food Safety for Fruit Exporters and Traders: The Hazards in Citrus, Pome Fruit and Private Label Nut Mixes, and What a Broker Can Control

By Mthokozisi Nkosi, Food Safety Specialist & Lead Auditor, ASC Food Safety · 13 min read

Food safety for fruit exporters and traders comes down to a short list of hazards that the broker never touches but must still control: pesticide and post-harvest residues, pathogens on the fruit surface, mycotoxins and Salmonella in nuts and dried fruit, allergens and sulphites in mixes, foreign matter, and fraud. A broker controls them through specifications, supplier approval, release checks, testing and communication. This guide walks through each hazard for fresh citrus and pome fruit and for private label dried fruit and nut mixes, and shows where the control sits. The same worked example runs through ASC’s IFS Broker Version 3.2 Document Templates Toolkit.

What are the main hazards in fresh citrus and pome fruit?

Pesticide residues are the food safety hazard most likely to stop a consignment. On the farm, the wrong product, the wrong rate, a missed pre-harvest interval, spray drift or an unregistered product can leave a residue above the destination limit, or a substance that is not authorised there at all. In South Africa, agricultural remedies must be registered under Act 36 of 1947 for the crop.

Post-harvest treatments add a second layer. Citrus is commonly treated with fungicides and waxes in the packhouse, and a dip or drench running at the wrong concentration, or the wrong treatment applied to a market line, gives a residue that a pre-harvest result never sees. That is why the residue result used for release must be drawn from packed and treated fruit where the packhouse applies post-harvest treatments.

Pathogens on the fruit surface are less likely but severe. Listeria monocytogenes, Salmonella and pathogenic E. coli can survive on fruit that consumers eat whole or peel by hand. The controls sit at the farm and packhouse: water quality, sanitiser control in recirculated wash water, environmental monitoring for Listeria on food contact surfaces and worker hygiene, under Codex CXC 53-2003 Code of Hygienic Practice for Fresh Fruits and Vegetables.

Physical and packaging hazards include glass, hard plastic, wood and staples in cartons, and liners, punnets or labels that are not suitable for food contact. Cold chain failure mostly causes decay, for example green and blue mould from Penicillium, which is a quality loss and a claim rather than a safety hazard in most cases. No allergen is reasonably expected in fresh citrus or pome fruit, but write that conclusion down rather than leaving the row blank.

Which legal requirements catch fruit exporters out?

• Residue limits of the destination market. Regulation (EC) No 396/2005 in the EU, the GB MRL Statutory Register for Great Britain (with EU MRLs applying in Northern Ireland), and the official residue standards of each Middle East destination. Many retail customers set limits below the law, cap the number of residues detected, or restrict named substances.
• Marketing standards. Commission Delegated Regulation (EU) 2023/2429 replaced Regulation (EU) No 543/2011 from 1 January 2025. In South Africa, export standards are set under the Agricultural Product Standards Act 119 of 1990.
• Plant health. Regulation (EU) 2016/2031 and Commission Implementing Regulation (EU) 2019/2072 set the import requirements for citrus, including citrus black spot (Phyllosticta citricarpa) and false codling moth (Thaumatotibia leucotreta), with cold treatment of oranges unless pest freedom applies. The Agricultural Pests Act 36 of 1983 still applies at home.
• Export certification. The PPECB, established under the Perishable Products Export Control Act 9 of 1983, inspects and certifies consignments before shipment.

A point that catches people: a size or class defect is not always only a customer matter. Below the minimum size of the export standard or the destination marketing standard, fruit is not legal for that market, so no brand owner approval can release it under requirement 5.6.5.

Never keep a list of MRL values in a spreadsheet. Keep a list of where to look them up, and look them up on the day the result comes in.

What are the hazards in dried fruit and nut mixes?

A customer branded trail mix of almonds, cashews, raisins and sulphited dried apricots carries a different hazard profile, and the broker owns the specification, so requirements 4.3 and 4.6.3 apply in full.

Sulphur dioxide is also an additive with its own maximum, under Regulation (EC) No 1333/2008 in the EU and R.965 of 1977 in South Africa. Packaging matters as well: laminate pouches must comply with Regulation (EC) No 1935/2004 and, for plastics, Regulation (EU) No 10/2011. Labelling falls under Regulation (EU) No 1169/2011 for the EU and R.146 of 2010 as amended at home, where R.1145 of 2004 covers mycotoxins and R.692 of 1997 microbiological standards. For EU mycotoxin sampling, Commission Implementing Regulation (EU) 2023/2782 replaced Regulation (EC) No 401/2006.

Where does food fraud show up in these supply chains?

Requirement 4.7.2 asks for a vulnerability assessment of every purchased product and its packaging. In this trade the vulnerabilities are well known.

Requirement 4.7.5 also asks you to make sure suppliers have their own vulnerability assessment and mitigation plan. If you need a structured way to score vulnerabilities, ASC’s Food Fraud Tool costs R750.

What can a broker actually control?

The broker does not grow, pack, store or transport anything. Its control is real all the same, because nothing moves without its contract, specification, approval and release. The table shows how the work divides.

Building that split into a scored hazard analysis is covered step by step in our guide to the IFS Broker risk assessment.

How should a broker plan testing?

Requirement 5.2.4 asks for a sampling programme based on hazard analysis that covers all purchased products and broker services, and 5.2.3 prefers laboratories accredited to ISO/IEC 17025 for the methods used. Check the schedule of accreditation as well as the certificate, because accreditation is granted per method and matrix.

1. Fruit releaseRelease rests on a valid residue result for each production unit and variety supplied, checked against the destination MRL and any customer limit, plus your own risk based verification sampling of packed fruit. Not every consignment needs its own test.
2. Result above a limitA result above the MRL or a customer limit stops release, and the customer is told where product has shipped.
3. Result close to a limitA result above your internal alert level, set as an illustrative percentage of the MRL, raises a trend flag and increases testing for that supplier. It is not an automatic hold.
4. Nut mix releaseCertificates of analysis per lot for aflatoxins, ochratoxin A, Salmonella and sulphur dioxide as relevant, plus verification tests including peanut cross contact.
5. Customer special analysesEvery test a customer demands goes into a written testing plan with results on file. This is KO 5.2.2.
6. Trend reviewResults are reviewed regularly for trends, and a trend drives corrective action (5.2.5).

Where a supplier’s status is not available, the Doctrine on 4.4.7 expects increased frequency and scope of testing until it is. How these tests protect the KOs is explained in our guide to the IFS Broker KO requirements.

What about the cold chain and product defence?

Requirement 4.8.1 asks that contracted transport and storage providers either hold IFS Logistics or another GFSI recognised certificate for the scope, or work under a contract that sets out every product safety and quality requirement, product defence included. For fruit that means reefer pre-trip inspection, set point control and logger downloads. For the mix, clean, closed and sealed loads with no mixed cargo that could taint it. Chapter 6 asks you to make sure suppliers and logistics providers have a product defence assessment and plan, and ASC’s Food Defence Tool (R750) structures your own. If you also run a warehouse or sample room, ASC Pest Control services warehouses and offices.

All of this sits inside the wider Standard set out in our IFS Broker 3.2 requirements guide, and the order in which to build it is in our guide to IFS Broker certification in South Africa. ASC’s implementation course for trading companies (R5,500) applies these hazards to your own products, and the ASC shop sells stand-alone risk assessment templates.

Frequently asked questions

Published by ASC Food Safety, South African food safety and quality consultants. This article is general guidance and not a substitute for certification-specific advice.