Shellac Exporter to Germany — E904 & EU Import Guide

Why Germany buys shellac

Germany is one of Europe's most demanding markets for shellac (Schellack). Demand comes from four directions:

• Confectionery and chocolate — glazing of dragées, chocolate lentils, coated nuts and chewing gum.
• Fresh produce — surface treatment of citrus and other authorised fruit.
• Pharma and supplements — moisture-barrier and gastro-resistant tablet coatings.
• Refining, wood finishing and technical coatings — European refiners and traders buy seedlac and lac from India to refine and redistribute across the EU, and the furniture, instrument and restoration trades use flakes and button lac.

The first three are regulated food and pharma uses; the fourth is where most first orders from India start.

E904 changed in 2026 — only wax-free shellac qualifies

Shellac is authorised in the EU as food additive E 904 under Regulation (EC) No 1333/2008, with purity criteria in Commission Regulation (EU) No 231/2012. Commission Regulation (EU) 2026/189 (28 January 2026) made two changes German buyers now check:

• The specification now covers wax-free bleached shellac only, with wax of not more than 0.2%. Wax-containing shellac was removed, because it is not used as a food additive and no safety data were available.
• E 904 is newly authorised as a glazing agent in foods for special medical purposes, in tablet and coated-tablet form only, at up to 46,000 mg/kg.

This followed EFSA's 2024 re-evaluation of shellac. In practice: orange, blonde and garnet flakes, standard bleached shellac and seedlac are technical grades in Germany — fine for wood finishing and coatings, not for food.

Which grade for which German use

Confectionery & fruit glaze (E904)	Wax-free bleached shellac, wax ≤ 0.2%, batch COA against Regulation 231/2012.
Pharma & FSMP tablets	Dewaxed grades specified to the Ph. Eur. monograph Shellac; food E904 status alone does not satisfy a pharma quality agreement.
Refining & further processing	Seedlac or button lac, specified by crop (Kusmi or Baisakhi), colour and impurity.
Wood finishing & restoration	Orange, blonde or garnet flakes and button lac — natural wax is fine.
Technical coatings & inks	Flakes or bleached shellac to an agreed specification.

Documents German QA will ask for

For E904 food use: a batch COA against Regulation 231/2012 (acid value, wax, loss on drying, heavy metals, rosin, identification), a product specification, an E904 compliance declaration citing 1333/2008 and 231/2012 (and 2026/189 for FSMP tablets), an SDS in CLP format, certificate of origin, allergen and GMO statements, and a process declaration stating whether colour was removed physically or by chemical bleaching.

For pharma, in addition: a Ph. Eur. COA, microbiological results, residual solvents where relevant, a TSE/BSE statement, and lot traceability from seedlac to finished bag.

For technical and wood-finishing grades: COA, TDS, SDS and certificate of origin are normally enough. German incoming goods inspection will match the lot number on the bag, invoice and COA — so keep them identical.

Shipping from India to Germany

• Route: FOB Kolkata to Hamburg or Bremerhaven by sea, usually with transshipment, then rail or truck inland. Air freight to Frankfurt suits samples and pharma validation lots.
• Terms: FOB Kolkata, CFR or CIF Hamburg. A retained sample and a pre-shipment COA help avoid disputes on first orders.
• Classification: lac and shellac generally move under HS 1301.90; lac wax may fall under 1521.90. Agree the exact Combined Nomenclature code with the German customs broker before the first shipment.
• Duty: check the live rate for your code in the EU TARIC database. Do not assume India–EU trade-agreement benefits until they are in force for your shipment date.
• Import: the German importer's EORI number goes on the declaration. Invoice, packing list and bill of lading descriptions must match exactly, and food lots must never be declared as "industrial resin".
• Packing: 25 kg bags or fibre drums, kept cool and dry — heat makes shellac block. See why shellac blocks in storage.

What we supply to German buyers

Our strongest fit for Germany today is refining and technical supply: seedlac and button lac for refiners and traders, and shellac flakes for wood finishing and technical coatings — each with a batch COA. Specialty chemical and fragrance companies can also order aleuritic acid, a shellac-derived C16 building block. For E904 food or Ph. Eur. enquiries, state the grade and the document pack you need when you request a quote, and we will confirm what can be supplied and documented before we price it.

Quick answers

Is wax-containing shellac still E904? No. Since Commission Regulation (EU) 2026/189, the E904 specification covers wax-free bleached shellac only, with wax of not more than 0.2%.

Can one shellac lot serve food and pharma in Germany? Yes, if it is specified and tested against both Regulation (EU) No 231/2012 and the Ph. Eur. monograph. Many buyers still keep separate item codes.

Is E904 vegan? No. Shellac is insect-derived. German labels list it as E 904 or Schellack.

This page summarises publicly available EU law and trade practice as of September 2026. Verify the current text of Regulations 1333/2008, 231/2012 and 2026/189, the Ph. Eur. monograph, TARIC duty and your own quality agreement before ordering. It is not legal advice.