Exporting Tunisian Olive Oil to the US: Customs & FDA

The United States has quietly become the third destination for Tunisian olive oil exports, well behind Spain and Italy but growing fast. For a US buyer or importer negotiating a first Tunisian lot, the entry process looks nothing like EU customs: a US tariff code, FDA facility registration, a Prior Notice filed for every shipment, and a tariff landscape that has shifted more than once in eighteen months. Here is the full mechanics — what is stable, and what still needs checking before each shipment.

A growing market, still modest next to Spain and Italy

Over the first eight months of the 2025-2026 season (November to June), Tunisian olive oil exports reached roughly 352,000 tonnes, up 56.7% on the same period the year before. Within that total, the United States absorbs about 19.4% of volumes, just behind Italy (19.7%) and well behind Spain (32.4%), which remain the top two destinations largely because they re-import a significant share of Tunisian bulk oil to blend, bottle, or re-export under their own commercial origin. The US market, by contrast, buys directly for its own consumption and its own bottling — a shorter chain, one where Tunisian origin stays visible all the way to the shelf.

That growth is not only about price. It also reflects a quality reputation that has been climbing, helped by medals won at international competitions in recent seasons — a point we cover in our roundup of Tunisian olive oil's international competition medals — and a structural need among US bottlers to secure volumes outside the European Union, particularly in seasons when Spanish supply tightens.

US customs: HTS 1509, base duty and a shifting surcharge layer

Olive oil enters the United States under Chapter 15 of the Harmonized Tariff Schedule, searchable on the official USITC portal. Classification depends on grade and packaging:

• Virgin and extra virgin (HTS 1509.10): roughly 5 cents/kg in retail units (containers under 18 kg), and roughly 3.4 cents/kg in bulk (containers of 18 kg or more) — flexitank, ISO tank, drums.
• Refined or blended olive oil (HTS 1509.90): a similar schedule, also charged by weight rather than value.
• Olive pomace oil (HTS 1510.00): roughly 5 cents/kg, oil and container combined.

That base, most-favored-nation duty has stayed stable over the long run and does not depend on bilateral negotiations. What has moved is the layer of surcharges added since 2025 on top of it for much of the US's trading partners, under a legal framework that has itself changed repeatedly — a Supreme Court ruling in February 2026 struck down part of the IEEPA-based tariff regime, a temporary replacement followed, and then a new set of 10 to 12.5% surcharges took effect on July 24, 2026 for roughly sixty trading partners, this time tied to child-labor compliance criteria. Tunisian business press (La Presse, Kapitalis, Managers.tn, late July 2026) reports that Tunisia is not on that list: its olive oil exports keep moving under the ordinary tariff regime, a relative edge over direct competitors like Morocco, Algeria, Egypt or Turkey, who are subject to the surcharge. That status is worth re-checking before every shipment — US tariff policy has shifted more than once in eighteen months — via the USITC portal or a US customs broker.

FDA: facility registration, US agent, Prior Notice

Separately from customs, any olive oil sold in the United States falls under FDA food regulation, with three distinct obligations:

1. Foreign facility registration. The site that manufactures, packs or holds the oil bound for the US market — mill or bottling site — must register with the FDA, renewed every two years, and name a US agent reachable by the FDA. A trading company that neither manufactures nor stores the oil itself does not need to register, but must confirm that each supplying site does.
2. Prior Notice. Every shipment needs a Prior Notice filed before the container arrives — product, quantity, origin, shipper, importer. A missing notice holds the lot at the port of entry.
3. Foreign Supplier Verification Program (FSVP). This obligation sits with the US importer, not the exporter: verifying that the foreign supplier operates under conditions equivalent to US food-safety requirements. In practice, that means the importer will request a quality file from the supplier — COA, test methods, traceability — going well beyond the standard food-grade COA used in Europe.

None of these three pieces replaces the usual chemistry (acidity, peroxide value, K232/K270). They sit on top of it, with tighter documentation expected on the US side.

USDA organic: why the EU certificate alone isn't enough

A common trap for a US buyer discovering Tunisian organic olive oil: the equivalence arrangement between the US and EU organic standards, administered by USDA's Agricultural Marketing Service, only covers products of EU origin and EU processing. A Tunisian oil certified organic under EU rules (Regulation (EC) 834/2007, now 2018/848) does not automatically become "USDA Organic" on arrival in the US, even if it transits through a European port. To carry the organic claim on the US market, the Tunisian operator needs a direct NOP certificate issued by a USDA-accredited certifier operating in Tunisia — Ecocert, among others, already certifies several Tunisian mills under both the Tunisian organic standard and NOP. A US buyer should therefore ask explicitly for the lot's NOP certificate, separate from the EU organic certificate, before promising an organic label.

Tariff codes and practical reference points

Category	HTS code	Base duty (column 1)	Typical packaging
Virgin / extra virgin, bulk ≥ 18 kg	1509.10.40	≈ 3.4 cents/kg	Flexitank, ISO tank, 200 L drums
Virgin / extra virgin, retail < 18 kg	1509.10.20	≈ 5 cents/kg	Bottles, cans
Refined / blended olive oil	1509.90	Similar schedule, by weight	Bulk or packaged
Olive pomace oil	1510.00.40	≈ 5 cents/kg	Bulk or packaged

Logistics and Incoterms: what changes versus Europe

The Radès-to-US-East-Coast route generally runs past fifteen days in transit, against three to five days to Marseille or Genoa — a gap that needs to be built into cargo insurance cover and into the Incoterm chosen. FOB Radès deals remain possible, but a US buyer meeting a new supplier often prefers CIF or DAP to the port of entry while the relationship gets established; our guide to FOB and CIF Incoterms for olive oil walks through where risk shifts under each formula. The 24,000 L flexitank remains the dominant format on this route, though an ISO tank is sometimes preferred for recurring volumes given the longer transit and the risk of the oil setting at low temperature crossing the North Atlantic in winter.

What still decides the sale: traceability and authenticity on a watched market

The US olive oil market has lived under active scrutiny from trade associations and specialist press since the blending-fraud scandals exposed over the past decade. A buyer meeting a new Tunisian supplier routinely asks for a lot COA independent of the supplier's own certificate, with authentication testing when volume or price justifies it. That is precisely where the gap with Spain and Italy — covered in our comparison of Tunisian, Spanish and Italian olive oil — plays out less on price than on the documentary proof supplied lot by lot.

Preparing a first US shipment with Virginia

Virginia is a trading and packing house built on a network of partner mills across Tunisia — we own no mill of our own, which leaves us free to source by variety and grade across more than 30,000 tonnes available per season. Every lot travels with its COA (acidity, peroxide value, K232/K270, polyphenols on request), a systematic tasting panel and traceability back to the originating mill, with independent SGS counter-analysis available before loading — the documentary base a US importer builds its FSVP file on. Tell us your volume, port of entry, and any organic requirement: we scope the request within 24 business hours from our Paris and Sfax/Sahel offices. Request a quote or start from a sample before committing, and flag that the shipment is bound for the US market.