This Report updates the sections concerning food laws, labeling requirements, and specific standards and import procedures in Tunisia.
THIS REPORT CONTAINS ASSESSMENTS OF COMMODITY AND TRADE ISSUES MADE BY
USDA STAFF AND NOT NECESSARILY STATEMENTS OF OFFICIAL U.S. GOVERNMENT
Required Report - public distribution
GAIN Report Number: TS1107
Food and Agricultural Import Regulations and Standards -
FAIRS Country Report
Hassan F. Ahmed, U.S. Embassy, Tunis
Youssef Chahed, Ag Specialist, Tunis
This Food and Agricultural Import Regulations Report updates the sections concerning food laws, labeling
requirements, and specific standards and import procedures in Tunisia. The process of approving new and
comprehensive food legislations in 2011 has been disrupted by the Tunisian revolution and the fall of Ben Ali‟s
regime in January 2011.
Section I. Food Laws:
After the fall of Ben Ali‟s regime in January 2011, Tunisia has been engaged in a progressive reform and
democratization process. On October 23, Tunisians participated in the first fair and democratic elections in their
history and elected the 217 members of the Constitutional Assembly whose major task will be to draft a new
Constitution. Today, Tunisia economy is in a recovery phase and the general environment for investment and
foreign cooperation is showing some positive signs.
Tunisian food legislations are currently incorporated in several general laws intended to organize the food sector
and to protect consumer (law # 92-117, 1992). Quarantine and phytosanitary requirements applying to
unprocessed agricultural products of plant origin as well as sanitary control of live animals and food products
from animal origin are defined by laws # 92-72 and # 99-24, respectively. Food distribution and marketing are
structured by the law # 94-86 dated July 23, 1994 which organized market and retail services. Finally, law # 99-
42 establishes the procedures for seeds production, propagation, import, marketing and protection of the rights
relating thereto. These laws are implemented through a set of food regulations referred to as decrees or „Arrêtés‟.
Food controls activities are coordinated by the National Agency of the Sanitary and Environmental Control of
Products (ANCSEP) created in 1999. The ANCSEP also ensures the observance of national and international
standards in matters of sanitary and environmental food controls.
Food safety is a top priority for the Tunisian Government. One of the government‟s main initiatives is to set up a
consumer protection body through establishing a comprehensive food legislation that will encompass all the
above mentioned laws, and specifically targeted at the food sector and food safety. The new law, which was
prepared by the Ministry of Commerce and is currently under review, is expected to help harmonize the Tunisian
legislation with the EU food regulation 178/2002. It is projected to encompass all principles, requirements and
procedures concerning food and consumers‟ safety. It will contain regulations on official controls, contaminants,
additives, food contact materials, and pesticides. The adoption of this new food law by the Tunisian parliament is
likely to be delayed until 2012.
Tunisia has made significant progress toward reforming its trade policy and reducing barriers facing trade of
agricultural and food products. The law #94-41 liberalized trade and abolished the import-licensing regime to
ensure compliance with WTO trade rules. A large majority of goods can be freely imported to Tunisia, with only
3 percent of imported products need prior authorization. Products under the free imports regime need an import
certificate supported by commercial documentation in order to be cleared, while products not included in the free
regime require an import authorization granted by the Ministry of Commerce and generally last for 12 months. To
obtain this license, a number of documents are required, such as the commercial contract (or other equivalent
documents), as well as information about the contracting parties, the products, their origin and where they come
from. Export companies and companies operating under the free trade zone regime can import freely without
these requirements. The highest tariffs are applied to fruits, vegetables, and other imported agricultural products
that compete with domestic products. Non tariff barriers such as quotas still exist for many agricultural products.
Section II. Labeling Requirements:
The Tunisian Ministry of trade published a new Order in September 2008 revising the old departmental Order
dated July 22, 1985 and laying out labeling requirements regarding pre-packaged foodstuffs and consumer-ready
food products. The Order does not apply to bulk and intermediate foods products intended for further processing.
II-A General Requirements
The 2008 Ministry of Trade‟s Order stipulates that any pre-packaged foodstuff has to be labeled in order to be
marketed. Labels shall be applied in such manner that they will not become separated from the container and
should avoid any misleading or confusing indications. Arabic has to be one of the languages used for product
labeling (decree #2003-1718) while the measuring system in use is the international metric system. If pork meat,
pork fat, beef fat or alcohol is one of the ingredients it should be clearly mentioned on the label. Labeling is also
mandatory for all foods and food ingredients containing genetically modified organisms (GMO). An obligation
exists to inform consumers when genetic engineering methods of production are involved (Principe de
precaution). However, this obligation is not enough clear and doesn‟t give sufficient details on the type of
products involved, the percentage of GMO authorized and the authority in charge of the enforcement. In general
the following particulars are mandatory on the labeling:
The name of the food product, the country of origin, the name and address of the manufacturer, packager,
importer, and/or distributor.
Full list of ingredients in descending order of predominance. Ingredients that are supposed to be at the
origin of allergy should be conspicuously labeled. This includes all cereal containing gluten, soybean,
dairy products and shell fruits. Any ingredients that were obtained through biotechnologies should also be
indicated in the labeling.
Net content: to be indicated using the international metric system in units of volume in the case of liquids,
units of mass in the case of other products. Food items packed in a liquid medium shall carry an
indication of the net drained weight.
Time limit for use or time limit for optimum use: the date of production and date limit for perishable food
products has to be clearly indicated (dd/mm/yy). It is prohibited to import a food product that has
exceeded half of its time limit for use. For goods having a shelf life of 3 months or more the mention of
the month and the year is sufficient. For non-perishable goods a time limit for optimum use must be
indicated using one of the following wordings: to be consumed preferably before…/ to be consumed
preferably before end of…/ to be consumed preferably within a period of...
Storage instructions: indications such as „keep in a cool place, protect from light or from dampness‟ must
be indicated when necessary.
II-B Specific Requirements to Nutritional Labeling
A new regulation partially inspired of the EC regulations of 2006 on the use of nutrition and health claims for
foods had been adopted in Tunisia in 2008. This Regulation lays out rules for the use of health or nutritional
claims (such as “low fat” and “helps lower cholesterol”) on foodstuffs based on nutrient profiles by means of
positive lists of authorized claims that can be made on food. Health claims are prohibited on food intended for
babies and children. Nutritional labeling of vitamins, minerals and other nutrients is mandatory when a producer
is making health or dietary claims on the label. This provision applies to fortified products and to food items
intended for particular use (e.g. infant formula). Otherwise, nutrition information is voluntary.
II-C Food Quality Label
A recent decree by the Ministry of Ministry of Industry and Technology (Decree #2010-2525-JORT N°080) that
was published on September 28, 2010 establishes for the first time labeling for quality of consumer-oriented
products. The new label, which is called the Food Quality label, will be granted to products that meet certain
quality attributes as Traditional and Superior products. The first group of products to benefit from the quality
labeling includes bottled olive oil, sardines, and dates. A special committee called the “Committee of label
quality" is created within the Ministry of Industry and Technology and will be in charge of granting, monitoring
and suspending the quality labels for the producing companies.
Section III. Packaging and Container Regulations:
Materials intended to come into contact with foodstuffs, i.e. packaging materials, must meet Tunisian standards
and bear a food grade international logo shown below (Decree #2003-1718 of August, 2003). This requirement
entails either clearly stating on the container a short message such as ''material fit for food contact" or featuring
the food grade logo.
Section IV. Food Additives Regulations:
Departmental Order dated Mai 20, 1998 relating to the validation of Tunisian standard NT 117-01 (1995) governs
the use of food additives. The purpose of this Order is to give an exhaustive listing of authorized additives
(positive list), their conditions of use as well as their respective identification E-numbers. This standard is largely
based on European regulations (directive 94/35/CE on sweeteners for use in foodstuffs, directive 94/36/CE on
colors for use in foodstuffs, and directive 95/2/CE on food additives other than colors and sweeteners).
Section V. Pesticides and Other Contaminants:
The trade, distribution and use of pesticides for agricultural purposes have been systematically regulated in
Tunisia since 1961. The last amendments to this law were approved in 1992 (law # 92-72). Any pesticide that is
imported or formulated in the country has to be registered and officially authorized by laboratory of the Ministry
of Agriculture (Laboratoire de Contrôle et d‟Analyse des Pesticides, created in 1985). In 1994, the decree #94-
1744 made the control of the formulation of imported pesticides mandatory. Obligatory labeling items are set by
the law, particularly the necessity to use French and Arabic language. Tunisian imports of pesticides amount to
3600 tons per year with more than 725 pesticides distributed in the market.
The laboratory of the National Institute for Nutrition of the Ministry of Public Health (Laboratoire de l‟Institut
National de Nutrition) and the Central Laboratory of the Ministry of Industry (Laboratoire Central) are
responsible for pesticide residue analysis in foodstuffs. Maximum pesticide residues tolerated in food items are
set in the Tunisian standard NT 117-03 enacted in 1983 and technically equivalent to the Codex Alimentarius
Standard #100-1981 (Codex CAC/RS 100-1978). It must be noted that Tunisian MRL could differ from the
Codex MRL in case of a particular threat to the Tunisian consumer's health is identified.
In addition to pesticides, Tunisia also sets admissible maximum limits for other contaminants in foodstuffs, such
as metals, metalloids, aflatoxines (B1, B2, G1, G2, M1, M2, ochratoxine and histamine). Maximum limits are
laid out in Tunisian standard NT 117-02.
The implementation of these regulations is not always rigorous, particularly the regulations that govern labeling,
conditioning, handling, transport and storage of agricultural and food products. The National Institute for
Statistics (Institut National des Statistiques -INS) has reported the importation of banned compounds such as
DDT that were not authorized by the Ministry of Agriculture or Public Health has occurred in many instances.
Moreover, investigations have shown that banned compounds were still being illegally imported from
neighboring countries where their use has not been prohibited.
Section VI. Other Regulations and Requirements:
Principal other requirement for the majority of food products is the technical quality control prior to customs
clearance. Importers must apply for a consumption authorization document called „Autorisation de Mise à la
Consommation‟ (AMC). The list of the products concerned by the technical control is regularly published in
departmental orders. In general it focuses more on ready-use foods and beverages rather than products shipped in
bulk in a protecting consumer approach. The last decree #94-1744 of 29 August 1994, published three lists of
imported goods, as amended by a Commerce Departmental Order dated on Jan 7, 2004, that are subject to
technical controls according to three distinct modalities:
1. List A includes all goods submitted to a systematic control i.e. a conformity assessment with or without
sampling for further laboratory testing to be undertaken at each shipment regardless of whether the
product has or has not been already tested in the past. This list includes virtually all processed agricultural
2. List B includes products submitted to the so-called certification regime whereby customs clearance is
granted for goods accompanied by a certificate issued by the country of origin and stating that those
goods are in compliance with international standards. Agricultural products are not among products
subject to the certification regime.
3. List C includes products submitted to a conformity assessment with the conditions defined by a GOT-
sanctioned specifications book (Cahier des charges). Agricultural products submitted to „cahier des
charges‟ are, in their majority, bulk and intermediate agricultural products. Conditions set out in „cahier
des charges‟ very often go beyond sanitary and phytosanitary aspects and set out conditions about the
importer‟s eligibility in terms of storage capacity, funding availability, production data disclosure, etc.
Dioxin and Radio-contamination
A certificate indicating the amount of dioxin residue is required for all imports of bulk and processed food items.
A certificate of non-contamination from radioactivity issued at the country of origin or failing that delivered in
Tunisia by the National Center for Radioprotection after testing is also required.
Tunisia is at a crossroads on biotechnology policy. Tunisian policymakers are aware of the potential for
biotechnology to address chronic problems such as crop disease, weed control, and irregularity of rainfall. A
draft law is currently under consideration to establish a legal framework for the importation, commercialization,
and usage of biotechnology in agriculture. However, this effort may be delayed by skepticism on about the use of
biotechnology and Tunisia's close commercial ties with Europe. Labeling of food products and food ingredients
containing genetically modified organisms (GMO) is mandatory. An obligation exists to inform consumers when
genetic engineering methods of production are involved (Principe de precaution). However, this obligation is not
sufficiently clear and does not give details on the type of products involved, the percentage of GMO authorized
and the authority in charge of the enforcement.
Tunisia has an environmental labeling requirement that applies for pre-packaged food items. So far this
requirement is only enforced for bottled water and soft drinks. Decree #97-1102 dated on June 2, 1997 mandates
for a national system managed by the ANPE, the National Agency for Environmental Protection, to collect and
recycle used packaging. The manufacturer or the importer has three options to comply with this regulation:
Tacking back and recycling the used packaging
Entrusting the implementation of this obligation to an approved companies on a contractual basis
Enrolling in the state-owned recycling system, which gives the right to print the Eco-lef logo on the product‟s
Section VII. Other Specific Standards:
The Tunisian Office of Cereals (the Grain Board) still enjoys a monopoly on the importation of durum wheat, soft
wheat and barley. Physical, chemical as well as phytosanitary requirements are laid down in a tender document
referred to as „cahier des charges‟. The latter stipulates that in case wheat is originated in the United States, the
required quality is the one defined by the USDA/FGIS relevant standards for the grade mentioned in contracting
Import of corn has been liberalized since the mid-90s. Technical and phytosanitary requirements are defined by
an Order jointly issued on January 11, 1997 by ministers of Agriculture, Finance and Commerce.
B. Milk products
Title V, Chapter III of Law # 2005-95 dated October 18, 2005 sets legal conditions relating to milk production,
processing and marketing. Some of the applicable standards are listed below:
TS 14-01 Milk definition
TS 14-02 Raw and natural milk
TS 14-28 Determination of milk density
TS 14-32 Determination of milk fat content
Most of the milk being processed or imported into Tunisia is essentially semi-skimmed, UHT (Ultra High
Temperature), thus permitting dairy plants to recover fats for butter production. A new sanitary certificate for
exporting U.S. dairy products to Tunisia has been successfully negotiated between USDA/FDA and the Tunisian
regulatory authorities and is awaiting signature by the two parties.
B-1 Dry milk
Import of dry or powdered milk, which is subject to a quotas allocation system run by the Ministries of
Agriculture and Commerce, shall be undertaken according to specifications set in the so-called „Cahier des
C. Animal feed
The Ministers of Agriculture, Public Health and Commerce Orders dated July 29, 1999 and September 12, 2001
lay down rules for feed production and marketing. To import ingredients for compound feed production,
importers are required to maintain a register showing:
- Name and quantities of imported ingredients
- Name and address of supplier
- Date of production of ingredients
- Name and address of buyer
- Quantities and numbers of lots of ingredients sold or in stock
- Analysis certificates giving contents of noxious elements
In addition, the same decree defines:
- Marketing and labeling regulations
- And animal feeds quality controls
D. Feed Additives
The list and conditions of production and marketing of additives used as feed constituents are set by the Ministers
of Public Health, Agriculture and Commerce Orders dated January 4, 1996 and September 7, 2005.
Additives that may be included in compound feeds are:
- Substances with anti-oxygen effects
- Coccidiostatics and medicinal substances
- Colorants, including pigments
- Emulsifying, stabilizing, thickening and jellying matters
- Vitamins and provitamins
- Conservation agents
- Binding, coagulating and anti-lumping agents
- Growth factors
- Aromatic substances
- Acid regulators
E. Live Animals/ Animal Semen
An import health certificate approved by the Tunisian Veterinary service must accompany all shipments of live
animals (dairy heifers and bull-calves) as well as animal semen to Tunisia. At the present time, U.S exports of
live animals to Tunisia are almost non-existent, partly due to the lack of the import health certificates. However
productive discussion on live animal and bovine semen certificates took place between USDA and Tunisian
Ministry of Agriculture in September 2011, and import certificate is expected be approved.
Imports of bovine and sheep meat are governed by a set of specifications (cahier des charges). Post is working on
the establishment of model health certificate between Tunisia and the US. It is important to know that
slaughtering according to the Halal ritual is mandatory and that meat from hormone-fed animals cannot be
allowed into the country.
G. Plant Products
Imports of seeds and seedlings must comply with Decrees #2002-621 and #2004-2179, dated March 19, 2002 and
September 14, 2004, respectively. These decrees set rules to import all seeds and seedlings. Of particular interest
is the impact of systematic technical controls applied to planting seed imports. These imports are subject to a
redundant system of phytosanitary controls. This delays clearance by several weeks in some cases, making the
seeds not available for farmers at sowing time or obliges them to sow late. Apart from the phytosanitary aspects,
main provisions are the obligation for the importer to apply for a license, to have a minimum storage capacity and
to keep records for its inventories. Seeds and seedlings covered by these decrees are: potato, citrus, strawberry,
pulses, horticultural seeds, forages, cereals and vines.
F. Fruits (Apple)
According to a decree published in August 1992, imports of several fruits including apples into Tunisia are
banned. The reason for the ban is to prevent the spread of Fire blight (Erwinia amylovora) which is a contagious
disease that affects apple and pear cultivations. It is worth mentioning that despite the official ban there are apples
imported illegally into Tunisia, though in small quantities. The Tunisian Ministry of Agriculture has no intention
of removing this import ban soon.
Section VIII. Copyright and/or Trademark Laws:
Tunisia has a copyright law (law #94-36 dated February, 1994). The Law establishes the Tunisian Institution for
the Protection of Copyright (Organisme Tunisien de Protection des Droits d‟Auteur). The Institution has several
functions, including the protection of copyright. According to Article 18 of the Law, the copyright shall be valid
during the author's lifetime and shall continue for fifty calendar years after the author's death. The law established
monetary sanctions for violations or infringements. A person who violates the law may be obliged to pay fines
ranging from $ 500 to 5,000.
Tunisia is a member of WIPO (World Intellectual Property Organization) and has signed most WIPO
conventions. The law # 2001-36 enacted on March 17, 2001 protects trademarks and brand names. Registration
with the National Institute for Standardization and Industrial Property (INNORPI) is a necessary to obtain
protection and is normally issued upon filling an application for registration. A trademark registration is valid for
fifteen years from the date on which the application for registration is filled. It may be renewed indefinitely for
similar periods of time. Tunisia does not require use of a trademark as a condition for maintaining registration.
Section IX. Import Procedures:
In addition to phytosanitary and sanitary certificates, the majority of consumer-oriented food products are subject
to a technical quality control prior to customs clearance mandated by decree # 94-1744 dated August 1994. In
order to expedite customs clearance, the importer is entitled to a temporary document called “Autorisation
Provisoire d‟Enlevement (APE)”, pending dossier instruction but must refrain from distributing or further
processing the imported good until the AMC is delivered by the Ministry of Commerce, Directorate of Quality
and Consumer Protection.
Local agents/distributors are crucial to introducing new products into the Tunisian market. Both commission
agents and distributors may represent foreign businesses in Tunisia. The agency-principal relationship is
governed by article 625 and 626 of the Commercial Code of Tunisia. Tunisian law prohibits the flow of currency
out of Tunisia as payment for imports before documents are presented to the issuing bank confirming that the
merchandise has entered the country. Imports have to be domiciled at a bank in order to make international
payments in hard currency. The process of customs clearance is composed of two essential operations:
It should be noted that in 2010 Tunisia upgraded its electronic trade information systems that allowed a faster
way for assembling import and export documents.
Since 2001, import declaration could be made electronically on-line with the Tunisian customs. As a result, time
needed to conduct an import declaration has been reduced significantly to 45 minutes. The declaration consists in
an application form which has to be submitted along with the following documents:
Commercial invoice: Since October 2006, customs clearance requires domiciliation of the commercial
invoice with an approved financial intermediary (i.e. commercial bank).
Bill of lading
Technical notice describing the product
Other document (s) at the discretion of the Authorities
2- Custom control
All merchandises arrive to the entry port are systematically sorted by the information system of the custom called
SINDA (Système d‟information douanier automatisé) according to certain criteria, particularly the type of the
product and the importer. The products are then inspected accordingly to the procedures described in section VI
in order to receive the approval for market distribution (Autorisation de Mise â la Consommation). This operation
can take up to 20 days depending on the product. The entire customs clearance procedure for a product imported
under the free regime takes, on average, less than 12 days. Customs fees are assessed at about 3%.
Appendix I. Government Regulatory Agency Contacts:
Directorate General for Veterinary services (DGSV)
Ministry of Agriculture, Environment and Hydraulic Resources
30, rue Alain Savary, 1002, Tunis, Tunisia
Phone: 216 71 786 833
Directorate General for Agricultural Production (DGPA)
Ministry of Agriculture, Environment and Hydraulic Resources
30, rue Alain Savary, 1002, Tunis, Tunisia
Phone: 216 71 786 833
Directorate General for Crop Protection and Quality of Agricultural Products (DGPCQPA)
Ministry of Agriculture, Environment and Hydraulic Resources
30, rue Alain Savary, 1002, Tunis, Tunisia
Phone: 216 71 786 833
Directorate General of Customs
Directorate of Quality and Consumer Protection (DQPC)
Ministry of Commerce
Address: 37, av. Keireddine Pacha, 1002 Tunis
Phone: (216) 71 890-070 / 890 337
National Agency of the Sanitary and Environmental Control of Products (ANCSEP)
Ministry of Public Health
Adresse : Appt. Idriss - 3ème Etage - Bloc N°9 - Cité Elmhiri - Berges du Lac - 2045 Tunis
Phone : +216 71 960 222
E-mail : firstname.lastname@example.org
Institut National de Normalisation et de Propriété Industrielle (INNORPI)
Standards setting and intellectual property enforcement authority
BP 23 - 1012 Tunis Belvédère
Phone: 216 71 785 922
Fax: 216 71 781 563
The Packaging Technical Centre (PACKTEC)
Address : Cité El Khadra, par la rue Alain SAVARY. BP 64 .1003 Tunis.
Tel. : +216 71 772 755
Fax. : +216 71 773 300
Email : Packtec@packtec-tunisia.com
Institut National des Statistiques (INS)
Trade and demographic statistics
Phone: 216 71 891 002
Fax (216) 71 792 559
E-mail : INS@mdci.gov.tn
US Embassy/ USDA-Foreign Agricultural Service Contacts
Hassan F. Ahmed, Regional Agricultural Attaché (Resides in Rabat, Morocco)
Phone : 212 53776 5987
Fax : 212 53 776 5493
Youssef Chahed, Agricultural Specialist
Phone: 216 71 107 486
Fax : 216 71 107 101
Adresse : Zone Nord-Est des Berges du Lac, Nord de Tunis, 2045 La Goulette, Tunisia