New EU requirements for importing dairy and fish: what changes in 2026

Key data

Importers of dairy and fishery products operating with suppliers outside the EU face a regulatory change that can directly affect their supply chains. The Delegated Regulation (EU) 2026/1304, published on 24 August 2026, amends Regulation 2022/2292 and updates the health and documentary requirements for the entry into the European Union of certain foods of animal origin.

Spain, with a fishing and dairy sector of great weight in the national economy, is one of the member states where this change has the greatest operational impact. Companies that do not adapt their processes in time are exposed to having their shipments retained or rejected at EU border control points.

What does this regulation establish?

Delegated Regulation (EU) 2026/1304 updates the import framework established by Regulation 2022/2292, which already regulated the conditions for entry into the EU of products of animal origin. The changes specifically affect three major product groups:

The changes introduced by this regulation may include, according to the published text:

• Modifications to health certifications required for the entry of these products.
• Update of the list of authorized third countries to export to the EU.
• Changes to treatment conditions that products must meet before import.

The regulation directly modifies the Delegated Regulation (EU) 2022/2292, which was the previous reference framework for these entry requirements. Any company that has adjusted its processes to the 2022 regulation must verify what specific aspects have changed with this 2026 update.

Economic and operational impact

The impact of this regulation is not abstract: it translates into real operational costs and direct economic risks for importing companies.

• Rejection of shipments at the border: If a shipment does not meet the new documentary or health requirements, it may be rejected at the EU border control point. This entails return costs, destruction of goods or re-shipment, in addition to the loss of the shipment's value.
• Administrative sanctions: Non-compliance with import requirements may result in administrative sanctions, the specific amount of which is not specified in the published text but is provided for in the general EU official control regulations.
• Review of supplier contracts: If any of the countries of origin of current suppliers has been modified in the list of authorized countries, the company will need to renegotiate or seek new sources of supply.
• Recertification costs: Obtaining new health certifications or adapting existing ones entails time and administrative cost for both the exporter at origin and the importer at destination.
• Impact on cold chain and logistics: Changes in treatment conditions may require adjustments to logistics and storage processes.

Who does it affect?

• Direct importers of dairy products (milk, cheese, butter, cream, etc.) from countries outside the EU.
• Importers of fishery products (fresh, frozen, processed fish) from third countries.
• Importers of bivalve molluscs (mussels, oysters, clams, cockles), echinoderms (sea urchins), tunicates and marine gastropods (sea snails) from third countries.
• Wholesale distributors who purchase these products already imported but must verify that their suppliers comply with the new regulation.
• Food industry operators who use these products as raw materials and import them directly.
• Customs agents and logistics operators who manage the clearance of these goods at the border.

Practical example

A Spanish company importing frozen mussels from Morocco and fresh cheese from Argentina currently operates under the requirements of Regulation 2022/2292. With the entry into force of Regulation 2026/1304, this company must:

1. Verify whether Morocco and Argentina continue to appear on the updated list of third countries authorized to export bivalve molluscs and dairy products respectively to the EU.
2. Check whether the health certificates accompanying its current shipments remain valid or whether the new models require additional or different information.
3. Confirm with its suppliers that the treatments applied to the products meet the new conditions established.

If the company does not carry out this verification before the regulation comes into force and sends a shipment with outdated documentation, the EU border control point may reject the goods. The cost of that rejection—return, destruction or re-shipment—can far exceed the cost of preventive review.

What should companies do now?

1. Identify affected products: Review the import catalog and determine which fall within the categories of dairy, fishery products, bivalve molluscs, echinoderms, tunicates or marine gastropods from third countries.
2. Verify the status of countries of origin: Check in the full text of Regulation 2026/1304 whether current supplier countries remain on the list of authorized third countries for each product category.
3. Review current health certificates: Compare the certificate models currently used with the new models or requirements established in the amended regulation.
4. Communicate changes to suppliers: Inform exporters at origin of the new requirements so they can adapt their documentation and processes before the first shipment after the regulation comes into force.
5. Coordinate with the customs agent: Ensure that the logistics operator and customs agent are aware of the new documentary requirements to avoid border delays.
6. Consult with a specialized advisor: Given that the date of entry into force is not specified in the published text, it is advisable to consult the full text of the regulation and, if necessary, a foreign trade or food safety regulation advisor to determine the exact adaptation timelines.

Official source

Consult complete regulation in official source — EUR-Lex, Official Journal of the EU

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601304