Key takeaways
- Novel food is a legal status, not a botanical description. Under Regulation (EU) 2015/2283 a "novel food" is any food not consumed to a significant degree by humans in the EU before 15 May 1997 that falls into a defined category. If a food fails that consumption-history test, it needs authorisation before it can be sold in the EU.
- The EU Novel Food Catalogue is your first lookup — but it is advisory, not law. The Commission's catalogue is explicitly non-binding and non-exhaustive, fed by information from Member States. It orients you; it does not decide your case. The only binding positive list is the Union list of authorised novel foods (Commission Implementing Regulation (EU) 2017/2470).
- A plant can be non-novel as a food yet NOVEL as an extract. Extraction, purification and concentration can change the status of the same botanical. Olive fruit is a food, but a high-polyphenol olive extract is treated as novel; ashwagandha root has a consumption history, yet its concentrated or isolated extracts are considered novel. Check the exact form you are buying, not just the plant name.
- There is a lighter route for foods eaten abroad: the traditional-food-from-a-third-country pathway. A food with a documented history of safe use of at least 25 years in the customary diet of a significant number of people in a non-EU country can use a simplified notification procedure instead of a full authorisation.
- Getting it wrong means the goods cannot be lawfully placed on the market — a withdrawal risk, not a paperwork nuisance. Arovela supplies Turkey-origin natural products into EU and Ukraine markets with lot-level documentation under ISO 22000, ISO 9001 and ISO 27001; novel-food status is a buyer-side regulatory determination that belongs in the RFQ before sampling.
Introduction
For an importer, QA lead or regulatory officer sourcing natural ingredients, novel food is the risk that hides in plain sight. A pesticide breach or an aflatoxin exceedance shows up in a lab result. Novel food status does not — it is a question of legal classification decided long before any sample is drawn, and a consignment can be perfectly clean analytically yet still be illegal to place on the EU market because the ingredient, in the form you bought it, requires an authorisation it does not have.
This matters most for the exact ingredients a Turkish natural-products catalogue is built on: botanicals, herbal preparations, and above all extracts and concentrates. The trap is that the raw plant and the concentrated extract are often treated as two different things under EU law. Buyers who assume "it's a traditional herb, so it must be fine" can find that the extract they specified — a higher-concentration, selectively purified preparation — sits on the wrong side of the line.
This guide explains the legal architecture of Regulation (EU) 2015/2283, the pre-1997 consumption test that defines what is not novel, how to read the Novel Food Catalogue for what it is (a lookup, not a verdict), why extraction can flip the status of the same botanical, the traditional-food-from-a-third-country route, and the concrete due-diligence workflow a buyer should run before issuing a purchase order. Every regulatory statement below is traceable to a published EU source, and where status genuinely depends on the specific case, the guidance is always the same: check, in writing, before you commit.
For adjacent regulatory context, see the Arovela guides on entering EU markets with natural products, sourcing botanical extracts for EU supplement brands, and exporting medicinal herbs to Germany.
The legal framework: Regulation (EU) 2015/2283
The controlling law is Regulation (EU) 2015/2283 on novel foods, adopted on 25 November 2015. It applies from 1 January 2018 and repealed the earlier novel food regulation, Regulation (EC) No 258/97. Like most EU food law, it applies regardless of origin: a Turkish, Chinese or Ukrainian ingredient must clear the same test as an EU-produced one before it can be placed on the market.
What "novel food" means
The European Commission states the definition plainly: a novel food is "food that had not been consumed to a significant degree by humans in the EU before 15 May 1997." Two elements have to be true together for a food to be novel:
- No significant consumption history in the EU before 15 May 1997, and
- It falls within one of the categories set out in Article 3 of the regulation.
The category list is broad. It includes food with a new or intentionally modified molecular structure; food from cell or tissue culture; food from microorganisms, fungi or algae; food from material of mineral origin; food from plants or their parts (with narrow exceptions for a safe history of use); food from a new production process that significantly changes composition or structure; engineered nanomaterials; and foods traditionally eaten outside the EU. For natural ingredients, the categories that bite most often are plant-derived preparations and new production processes — which is exactly where extraction lives.
The 15 May 1997 cut-off — why that date
The date is not arbitrary. 15 May 1997 is the day the EU's first novel food regulation (Regulation (EC) No 258/97) came into force. It is the fixed reference point for the whole system: if a food was already on the EU market and consumed to a significant degree before that date, it is treated as having a food history and is not novel. If it was not, it is presumed novel until proven otherwise.
Proving significant pre-1997 consumption is an evidence exercise. Acceptable documentation includes sales statistics and invoices, import records, national catalogues and sales brochures, dated labels, and declarations or certificates from EU Member States showing the food was on the market. "Use within the Union" refers to any Member State, irrespective of its date of accession — so consumption in a country that joined the EU after 1997 still counts. A supplier who claims an ingredient is "traditional" should be able to point to this kind of record for the EU specifically, not merely to global use.
The EU Novel Food Catalogue: your lookup, not the law
In practice, the first thing a buyer does is search the EU Novel Food Status Catalogue. It is the right first move — but it is essential to understand what the catalogue is and, critically, what it is not.
The catalogue lists products of animal and plant origin, algal and fungal species, cultures of microorganisms and other substances that may fall under the Novel Food Regulation. It is compiled from information provided by EU Member States, and the Commission is explicit that it is a non-binding tool and a non-exhaustive list. It is orientation on whether a product is likely to need authorisation — not a legal determination of your specific case. An ingredient can be absent from the catalogue entirely and still be novel; a catalogue entry can be updated as new Member State information arrives.
The binding instrument is different. Only the Union list of authorised novel foods — established by Commission Implementing Regulation (EU) 2017/2470 under Article 6 of Regulation (EU) 2015/2283 — carries legal force. If a novel food is on the Union list, any operator may place it on the market provided the authorised conditions of use, specifications and labelling are respected. If it is a novel food and it is not on the Union list, it cannot lawfully be placed on the market.
| Instrument | Legal weight | What it tells you | Use it to… |
|---|---|---|---|
| Novel Food Catalogue | Non-binding, non-exhaustive (advisory) | Member-State-fed orientation on likely novel status of a plant/part/preparation | Screen an ingredient early; spot the "extract vs. whole plant" distinction |
| Union list (Reg (EU) 2017/2470) | Binding positive list | Which novel foods are authorised, in which forms, with which conditions/specs | Confirm a novel food may actually be sold, and under what conditions |
| National authority guidance | Binding at Member State level | Additional restrictions a specific country imposes | Catch country-level bans/limits the EU lists do not show |
The three-layer reading matters because the catalogue, the Union list and national rules can each say something the others do not. Treat the catalogue as the map, the Union list as the gate, and the national authority as the local by-law.
Why an extract can be novel when the plant is not
This is the single most important idea for a buyer of natural ingredients, because it is where clean-looking traditional botanicals turn into regulatory exposure. The status of a food and the status of an extract of that food are assessed separately. Extraction, selective purification and concentration are "new production processes" and higher-concentration preparations that can change the legal status even when the source plant has an unimpeachable food history.
Two well-documented examples make the principle concrete:
- Olive and olive extracts. Olive fruit is plainly a food. But a concentrated, high-polyphenol olive extract, produced by selective purification to raise the level of active compounds far above the raw material, is treated as novel — precisely because the concentration of actives is increased relative to the food it came from. In May 2026 the Commission clarified the novel-food position of certain concentrated olive polyphenol extracts, underlining that the form drives the classification.
- Ashwagandha (Withania somnifera). A traditional root infusion/extract of ashwagandha has generally been treated as not subject to the Novel Food Regulation on the basis of pre-1997 food use, whereas extracts from other parts of the plant, and isolated or concentrated constituents, are considered novel. The same plant name spans both sides of the line depending on the part used and the degree of processing.
The practical lesson is that "botanical X is a food" tells you almost nothing until you specify: which part of the plant, what extraction solvent and process, and at what concentration of actives. A water-infused traditional preparation and a standardised high-strength extract of the same herb can have opposite novel-food status. This is why the extraction route you specify is a regulatory decision, not only a technical one — a point developed in the Arovela guides on CO2 vs. ethanol extraction and B2B essential-oil sourcing.
| Same botanical, different form | Typical treatment (always verify per case) | Why the status shifts |
|---|---|---|
| Olive fruit / culinary olive | Food — not novel | Long EU food history |
| Concentrated high-polyphenol olive extract | Novel | Selective purification raises actives above the raw food |
| Ashwagandha root, traditional infusion/extract | Generally not novel | Root form with pre-1997 food-use basis |
| Ashwagandha extract from other parts / isolated constituents | Novel | Different plant part and/or concentration = new preparation |
| Whole plant traded as food vs. a purified constituent (e.g. an isolated flavonoid) | Whole plant may be food; purified constituent often novel | Isolation/concentration creates a preparation without food history |
Read this table as risk logic, not as a fixed legal citation. The stable rule is: identify the exact preparation, then check the catalogue entry for that preparation. Where a catalogue line distinguishes the plant from its extract or a concentration threshold, the more concentrated form is the one to scrutinise.
The traditional-food-from-a-third-country pathway
Not every novel food faces the full authorisation process. Regulation (EU) 2015/2283 created a lighter, faster route for foods that are new to the EU but well established elsewhere — directly relevant to ingredients with a long history in Turkish, Middle Eastern, Central Asian or other non-EU food cultures.
A traditional food from a third country is a novel food with a history of safe food use for at least 25 years in the customary diet of a significant number of people in at least one country outside the EU. Instead of a full application, the applicant may use a notification procedure: safety is substantiated by reliable data on composition and on the experience of continued use, together with proposed conditions of use, and normal consumption must not be nutritionally disadvantageous. The detailed data requirements are set by Commission Implementing Regulation (EU) 2017/2468, and EFSA has published guidance on what a valid notification must contain.
The mechanism has a built-in check: within four months of a valid notification, a Member State or EFSA may raise duly reasoned safety objections. If none are raised, the food can be placed on the market; if objections are raised, the file typically escalates to a full application with an EFSA safety assessment. For a buyer, the point is that a genuinely traditional non-EU food is not automatically blocked — but the 25-year, documented, safe-use evidence has to exist and be assembled, and that is the supplier's and importer's burden, not the regulator's.
Authorisation and the Union list
When an ingredient is novel and has no traditional-third-country shortcut, it needs a full authorisation before it can be sold. The applicant submits a dossier to the Commission (Article 10); EFSA carries out a scientific safety assessment; and if the outcome is favourable, the Commission adds the food to the Union list with defined specifications, conditions of use and labelling requirements. Only once it is on that list can any operator place it on the market — and only within those conditions.
Concrete, verifiable examples of authorised novel foods on the Union list include chia seeds (Salvia hispanica), whose uses and conditions have been extended over time (for instance by Commission Implementing Regulation (EU) 2020/24, and partially defatted chia powders by Regulation (EU) 2020/500), and noni (Morinda citrifolia), which carries several separate authorisations for different marketed forms (fruit juice, juice powder, purée and concentrate, leaves, and fruit powder). These illustrate two things a buyer must internalise: authorisation is often form-specific (juice vs. powder vs. leaf), and each authorised form comes with its own conditions of use that the finished product must respect.
The buyer's due-diligence workflow
Novel food risk is manageable if it is checked at the right point — before sampling and pricing, not after a border problem. The workflow below turns the law into a repeatable desk check for each candidate ingredient and SKU.
Step 1 — Define the exact ingredient, not the plant
Write down the botanical (genus/species), the part of the plant, the preparation (whole/cut, powder, water infusion, ethanol/CO2 extract, purified fraction), and the concentration of the target actives. Most novel-food mistakes are made here, by describing "an extract of herb X" without the detail that decides its status.
Step 2 — Search the Novel Food Catalogue for that exact form
Look up the plant and the specific preparation in the EU Novel Food Catalogue. Note whether the entry distinguishes the whole plant from an extract, or flags a concentration threshold. Remember the catalogue is advisory and non-exhaustive — absence is not clearance.
Step 3 — Check the pre-1997 consumption history
If the ingredient looks non-novel, ask what evidence supports significant EU consumption before 15 May 1997 in that form. Traditional culinary use of a whole herb is one thing; a modern high-strength extract of it is another and rarely shares that history.
Step 4 — If it is novel, find the route
Determine whether it is on the Union list (authorised — check the conditions/specifications you must meet), eligible for the traditional-food-from-a-third-country notification (documented 25-year safe use outside the EU), or requires a full authorisation (a multi-year EFSA process to plan around, not to discover at the port).
Step 5 — Check the national overlay
A food that is not novel at EU level can still be restricted by individual Member States. Ashwagandha is the cautionary case: even though the root is not treated as novel, several countries (for example Denmark and France) have restricted or banned it in food supplements on safety grounds. Confirm the rules of your destination market, not only the EU baseline.
Step 6 — Put the determination in the RFQ and lot file
Record the status determination, the catalogue/Union-list references, and any conditions of use, and make the supplier confirm the exact preparation in writing so the specification, sample, COA and invoice all describe the same material. This is buyer-side regulatory work; a supplier's ISO systems evidence how the product is made and documented, not its novel-food classification.
Consequences of getting it wrong
The reason this deserves a desk check before sampling is that the failure mode is severe and commercial. If a novel food is placed on the EU market without authorisation (or a valid traditional-food notification), it is not lawfully on the market — full stop. That exposes the importer to product withdrawal or recall, official-control detention, destruction or re-export costs, potential RASFF notification, and the reputational damage of a delisting with a retail customer. Because novel-food status is a classification problem, no amount of clean analytical data fixes it after the fact: a spotless COA on an unauthorised novel ingredient is still an unauthorised novel ingredient.
The asymmetry is stark. The desk check in the workflow above costs an afternoon per ingredient. Discovering the problem after a container has shipped — or after a product is on shelf — costs the goods, the listing and the relationship. For any ingredient where the status is not obviously settled, the disciplined answer is to resolve it on paper, before the purchase order, and to state the agreed determination in the specification so it cannot drift silently as extract grades or concentrations change between orders.
Frequently asked questions
Is a traditional Turkish herb automatically exempt from EU novel food rules?
Not automatically, and the answer depends entirely on the form. A whole herb with a genuine record of significant consumption in the EU before 15 May 1997 is generally not novel as a food. But a modern extract or concentrate of that same herb — a higher-strength, selectively purified preparation — is assessed separately and can be novel even when the whole herb is not, because extraction and concentration are treated as new production processes. So "it's a traditional herb" is never a complete answer. The buyer has to specify the part of the plant, the extraction process and the concentration of actives, then check that exact preparation in the Novel Food Catalogue and, if it is novel, against the Union list. Where a herb also faces national restrictions in the destination country, those apply on top of the EU position.
Can I rely on the EU Novel Food Catalogue as proof an ingredient is legal?
No — and this is a common and expensive misunderstanding. The catalogue is explicitly a non-binding, non-exhaustive orientation tool, compiled from information supplied by Member States. It is the correct place to start a screening, and it is very useful for spotting the crucial "whole plant vs. extract" distinction, but it does not make a legal determination of your specific case, and an ingredient can be missing from it entirely and still be novel. The instrument that carries legal weight is the Union list of authorised novel foods (Commission Implementing Regulation (EU) 2017/2470): if a novel food is on that list you may sell it under the stated conditions, and if it is novel but not on the list, you may not. Use the catalogue to orient, the Union list to confirm, and the national authority to catch local restrictions.
What is the traditional-food-from-a-third-country route, and does it help a Turkey-origin ingredient?
It is a simplified notification pathway for foods that are novel to the EU but have a documented history of safe food use of at least 25 years in the customary diet of a significant number of people in a non-EU country. Because Turkey sits outside the EU, an ingredient with a long, evidenced Turkish (or wider regional) dietary history can, in principle, use this lighter route instead of a full authorisation — provided the safety file (composition data plus the 25-year continued-use evidence) is assembled and the food fits an eligible category. After a valid notification, a Member State or EFSA has four months to raise reasoned safety objections; if none are raised, the food can be placed on the market. The evidence burden sits with the applicant, so this route rewards suppliers and importers who can actually document the consumption history, not merely assert it.
Who is responsible for determining novel food status — the supplier or the buyer?
Legally, the operator placing the food on the EU market is responsible for ensuring it is lawful — which, for an import, is the EU importer. Novel-food status is therefore fundamentally a buyer-side regulatory determination, and it should be settled in the RFQ before sampling. A supplier's role is to describe the exact preparation accurately and consistently (species, plant part, extraction process, concentration) and to keep the specification, sample, COA and invoice aligned so the material cannot change silently. A supplier's certifications — for Arovela, ISO 22000, ISO 9001 and ISO 27001 — evidence how the product is produced and documented; they are not, and cannot be, a novel-food clearance. If your programme needs the status confirmed in writing, make it an explicit line item during qualification.
Source with confidence
Novel food risk is a classification problem that lands before any lab test: an ingredient can be analytically flawless and still be unlawful to place on the EU market because the form you bought requires an authorisation it does not have. Close that gap the way the regulation is built — define the exact preparation, screen it in the Novel Food Catalogue, confirm the pre-1997 consumption history, and where it is novel, locate the right route on the Union list or through the traditional-food notification before you issue a purchase order.
Arovela supplies Turkey-origin natural products — botanicals, extracts, dried fruit and natural snacks — into EU and Ukraine markets, with lot-level documentation under ISO 22000, ISO 9001 and ISO 27001. Novel-food status is a determination we help you specify precisely, not a certificate we claim. Tell us the exact ingredient form and destination market: send a technical quote request, compare wholesale supply options, or review Arovela certifications before you finalise your RFQ.