From September 2026, the EU tightens who even gets to try. Exporting countries need formal European Commission authorisation and a place on a category-specific list, assessed against animal health, plant health, residue and antimicrobial-resistance criteria, before certain products of animal origin can be offered for import at all. It’s one of several changes landing this year: border-check frequencies for individual commodities are being revised country by country, tighter checks on Turkish pistachios and Egyptian strawberries, eased checks on several Indian commodities and Brazilian black pepper, and EU border control posts are running a third more audits through 2026 and 2027. None of that shows up in a demand forecast. All of it decides whether the product crosses the border at all.
A food or agriculture company assessing a new market usually starts with demand, competitors, pricing and route to market. It should. But in this sector, the commercial case can look convincing long before the regulatory route is clear.
The problem is that “we can sell this there” and “we’re ready to enter the market” are two different things. Food and agricultural products bring requirements around the importer, the local company, the product itself, its ingredients, its labelling and the way it crosses the border. Miss one of those early enough in the process and it changes the entry plan. Miss it late enough and it changes the launch.
What the market model doesn’t show you
The same product can face a very different route to market from one country to the next, and the difference is rarely about the product itself. It’s about which regime is checking it, and how. Selling into the EU can mean navigating TRACES, the European Commission’s certification and border-control platform for animal products, plant products and certain food and feed of non-animal origin, and increasingly whether the country of origin even appears on the approved list for that category. Selling into the US typically brings USDA APHIS import permits into play for many plant and animal products, on top of FDA requirements. Selling into the UK means clearing sanitary and phytosanitary checks under the Border Target Operating Model. Meat, dairy, plants, seeds and fresh produce carry requirements that don’t apply to an ordinary manufactured product, and those requirements are revised product by product and country by country, sometimes more than once a year.
None of that necessarily makes the market unattractive. It does mean the regulatory work needs to happen alongside the commercial research, not after it.
There’s a sequencing problem too. A company registration may need to be in place before a licence can be applied for. A distributor may need an approval you assumed sat with the manufacturer. Packaging that works in ten existing markets may need changing for the eleventh.
Why the entry model matters
Companies often treat the choice between exporting through a distributor, establishing a local company and selling directly as mainly a commercial one.
For food and agriculture, it can also be a regulatory one.
Changing the route to market can change who imports the product, who holds the licence, who carries the compliance responsibility and what registrations need to be completed before the first sale.
That matters when you’re comparing entry options. A distributor-led model that looks cheap on paper is less attractive if the distributor can’t legally perform the role you need it to. Establishing locally may solve one problem and create three others. A launch da
What to check before you commit
- Map the requirements against the actual product, not the general rules for foreign companies; different food and agricultural categories can follow very different routes, including country-oforigin authorisation lists that change through the year
- Establish who holds each responsibility, whether that’s the manufacturer, importer, distributor, local entity, premises or product
- Check the product as it will actually be sold, including formulation, ingredients, labelling, packaging, origin claims and supporting certificates
- Build the sequence, not just the list, because one registration or approval may depend on another already being in place
- Test the proposed route to market against the rules, rather than assuming the commercial structure you’ve chosen can simply be made compliant afterwards
A market isn’t open to you because customers want the product. It’s open when the route to selling it actually works.
The distributor was ready. The launch wasn’t.
A European food producer identifies a promising Asian market for one of its premium ranges. Demand looks good, competitor pricing supports the case and a local distributor is ready to start selling.
The commercial work is largely done. The regulatory work isn’t.
A market-entry review finds that the proposed importer needs an additional authorisation, some of the products require supporting documentation before import and parts of the existing packaging need changing for the local market. None of those issues kills the opportunity. Together, they change who needs to do what, how much the launch will cost and when the first shipment can realistically move.
Found before the distributor agreement is finalised, that’s manageable. Found when stock is already sitting at the border, it isn’t.
This example is illustrative and anonymised. It reflects the kind of engagement we run, not a specific identifiable client.
Where this usually goes wrong
Companies separate the market research from the regulatory work. One team establishes that the opportunity exists; someone else checks later whether the proposed model can actually deliver it.
For food and agriculture, later is often too late.
The point isn’t to turn a market-entry study into a legal report. It’s to identify the requirements that change the commercial decision while there’s still time to do something about them.
