1
Regulatory & Sanitary Pre-Screening
ONSSA Status
Producer holds a valid agrément sanitaire (not just an autorisation) CRITICAL
Agrément = HACCP-based self-control system verified by ONSSA. Autorisation = basic hygiene only. For export, agrément is essential.
Confirm the agrément has not been suspended or withdrawn CRITICAL
Cross-reference with ONSSA's published lists of approved establishments. 7 licences were revoked and 11 suspended in the 2024-2025 campaign alone.
Producer appears on the ONSSA list of agréés/autorisés
Available at onssa.gov.ma under "Agréments et autorisations sanitaires" → lists of approved establishments.
Verify compliance with Loi 28-07 (food safety law) and Décret 2-10-473
Producer follows Interprolive Good Sanitary Practices Guide for virgin olive oil (Arrêté 1004-20, March 2020)
This guide was validated by ONSSA and the Ministry of Agriculture. Compliance is mandatory under Loi 28-07.
Export Certifications
Producer's facility is registered with the FDA (Foreign Facility Registration) CRITICAL
Required under the Bioterrorism Act. The facility must designate a U.S. agent. Registration must occur prior to any export.
Morocco Foodex certification obtained for export compliance
Morocco Foodex controls conformity of exported food products (category, quality, conditioning, labeling, origin marking).
Phytosanitary certificate available for each shipment REQUIRED
Certificate of Analysis (COA) provided per lot REQUIRED
Sanitary certificate issued by competent Moroccan authority
2
Quality & Lab Analysis
Chemical Parameters (IOC / USDA Standards)
Free Fatty Acidity (FFA) ≤ 0.8% for EVOO CRITICAL
Lower is better. Target ≤ 0.5% for premium positioning. Measures oil degradation / freshness.
Peroxide Value (PV) ≤ 20 meq O₂/kg CRITICAL
Measures primary oxidation. For premium, target ≤ 15. California standard is ≤ 15.
UV Absorption: K232 ≤ 2.5, K270 ≤ 0.22, ΔK < 0.01
Detects oxidation and adulteration. K270 is particularly important for identifying refined oil blending.
Fatty Acid Ethyl Esters (FAEE) ≤ 35 mg/kg (IOC) / ≤ 30 mg/kg (EU)
Elevated FAEE indicates fermented olives or poor storage before pressing.
Fatty acid profile consistent with declared cultivar(s)
Verify oleic, linoleic, palmitic acid ratios match expected values for Moroccan Picholine, Haouzia, Menara, etc.
Sterol composition and wax content within EVOO parameters
Authenticity markers. Abnormal sterol profiles indicate blending with seed oils.
Contaminant & Pesticide Testing
Pesticide residue analysis — all compounds within EPA MRLs CRITICAL
ONSSA has quadrupled sampling (1,536 → 6,635 samples between 2020 and 2025). Chlorpyrifos is banned — zero tolerance. Verify no banned substances.
Heavy metals (lead, cadmium, arsenic) below FDA action levels
Polycyclic Aromatic Hydrocarbons (PAHs) within limits
Lab performing analysis is ISO/IEC 17025 accredited REQUIRED
LOARC (Casablanca) holds IOC accreditation for olive oil analysis since 1993. Third-party labs also acceptable if accredited.
Sensory Evaluation
IOC-compliant panel test: median of defects = 0, median of fruitiness > 0 REQUIRED
No fusty, musty, winey/vinegary, rancid, or other defects. Positive fruitiness, bitterness, and pungency expected.
Sensory profile matches cultivar and terroir expectations
Retain pre-shipment samples sealed with lot numbers for dispute resolution RECOMMENDED
Key Thresholds — Quick Reference
FFA ≤ 0.8% (premium: ≤ 0.5%) · PV ≤ 20 meq O₂/kg (premium: ≤ 15) · K232 ≤ 2.5 · K270 ≤ 0.22 · ΔK < 0.01 · FAEE ≤ 35 mg/kg · Sensory defects = 0
3
Facility & Operations Audit
Extraction & Processing
Cold extraction only (temperature ≤ 27°C) CRITICAL
Mechanical extraction without chemical solvents. Verify with thermometer records.
Time from harvest to press ≤ 24 hours REQUIRED
Longer delays increase FFA. Premium producers target ≤ 8 hours.
Modern two-phase or three-phase centrifugal extraction system
Traditional mat presses are a red flag for hygiene and oxidation. Two-phase preferred for lower water use.
Stainless steel equipment and piping throughout (no iron, copper, or plastic)
No blending with non-olive oils or refined olive oil CRITICAL
ONSSA inspectors specifically check for adulteration. Undisclosed blending = agrément revocation.
Hygiene & Infrastructure
Facility meets ONSSA architectural and sanitary plan requirements
Floor plans showing workflow circuits, water supply, wastewater disposal, personnel areas, storage zones.
Cleaning and sanitation protocols documented and followed
Pest control program in place
Potable water supply verified and tested
Proper waste management for pomace and wastewater (margines)
Storage Conditions
Oil stored in stainless steel tanks with nitrogen blanketing REQUIRED
Protects against oxidation. Temperature-controlled storage (14–18°C ideal).
Storage area is dark, cool, and away from strong odors
FIFO (First In, First Out) inventory management practiced
4
Traceability & Documentation
Supply Chain Traceability
Lot-level traceability from grove → mill → tank → bottle CRITICAL
Required by both ONSSA and FDA (FSMA). Must be able to trace back within 24 hours.
Olive sourcing records: grove location, cultivar, harvest date, harvest method
Pressing records: date, time, temperature, yield per lot
Tank assignment records with fill dates and quantities
Bottling records: date, lot number, best-before date assignment
Labeling Compliance (FDA + Morocco)
Product identity statement (e.g. "Extra Virgin Olive Oil") REQUIRED
Country of origin clearly stated: "Product of Morocco" REQUIRED
Lot number and best-before date on every unit CRITICAL
Absence of these was the exact issue flagged by Belgium's AFSCA on the contested shipment.
Nutrition Facts panel compliant with FDA 21 CFR 101
Net quantity in both metric and US customary units
Allergen declaration (olive oil is tree-fruit derived — check FDA guidance)
Name and address of manufacturer, packer, or distributor
Harvest date on label RECOMMENDED
Not mandatory but strongly expected by quality-conscious US buyers. Best-by within 24 months of harvest.
5
U.S. Import Compliance
FDA & CBP Requirements
Prior Notice filed with FDA 15–30 days before arrival CRITICAL
Electronic filing via FDA PNSI (Prior Notice System Interface). Mandatory under Bioterrorism Act.
Foreign Supplier Verification Program (FSVP) implemented CRITICAL
Importer must document hazard analysis and supplier verification activities. Required under FSMA.
Customs bond secured (mandatory for food imports regardless of value)
ISF filing (Importer Security Filing, "10+2") for ocean shipments
Correct HTS code assigned (olive oil: 1509.x) — duty 3.4¢–5¢/kg + tariffs
Consider VQIP enrollment for expedited FDA clearance RECOMMENDED
Voluntary Qualified Importer Program — fee-based but significantly faster entry.
Packaging & Shipping
Packaging materials comply with FDA food contact requirements
Dark glass bottles or coated tins to protect from UV degradation RECOMMENDED
Wooden pallets ISPM-15 treated and marked
USDA-APHIS requirement for all wood packaging entering the US.
Packaging volumes conform to Moroccan authorized sizes (0.1L–25L range)
Morocco–US Trade Context
The Morocco-US FTA (in force since 2006) may offer preferential duty treatment on certain products. Verify whether olive oil qualifies for reduced rates under the agreement. Current general duty: 3.4¢–5¢/kg + potential ad valorem tariffs. Always confirm with a licensed customs broker for the latest rates.
6
Commercial & Relationship Due Diligence
Business Verification
Verify Registre de Commerce (RC) and Identifiant Fiscal (IF)
Confirm legal entity status and ownership structure
Request references from other export buyers (especially US/EU)
Check for competition awards or listings on bestoliveoils.org RECOMMENDED
Cross-reference with the Best Olive Oils database for quality reputation and competitive standing.
Production Capacity & Reliability
Confirmed annual production volume meets your order requirements
Producer can provide consistent supply across seasons (drought contingency?)
Olive grove ownership vs. sourcing model understood
Estate-bottled (domaine) vs. cooperative vs. aggregator — different risk profiles for quality consistency.
Cultivar mix documented: Picholine Marocaine, Haouzia, Menara, Dahbia, etc.
Contractual Protections
Quality specifications written into supply agreement with reject/rework clauses
Pre-shipment sample approval required before each lot ships
Payment terms tied to quality verification milestones
Consider: deposit on order, balance on approval of pre-ship sample, retention until arrival inspection.
Insurance and liability clauses for non-conforming product
Exclusivity / non-compete terms if relevant to brand positioning
7
On-Site Validation Visit
In-Person Checks
Visit during trituration season (Nov–Feb) to see operations live RECOMMENDED
Observe olive reception, sorting, and washing process
Verify extraction equipment condition and cleanliness
Inspect storage tanks — condition, temperature, nitrogen system
Review actual records and logbooks (not just prepared documents)
Conduct an impromptu tasting of current stock
Meet the mill master / technical lead — assess expertise and commitment
Take independent samples for third-party lab testing REQUIRED
Regional Context
Understand the terroir and microclimate of the production region
Key regions: Fès-Meknès, Marrakech-Safi, Béni Mellal-Khénifra, Drâa-Tafilalet, Tanger-Tétouan-Al Hoceïma.
Assess water availability and irrigation practices (drought risk)
Check proximity to ONSSA regional inspection offices