What falls under “herbal teas & infusions”

• Pure herbal/fruit infusions (no Camellia sinensis) are generally classified as HS 2106.90 (food preparations n.e.s.); U.S. customs rulings explicitly place “herbal teas and herbal infusions comprising mixed herbs” in 2106.90.xx.
  
• Dried herbs used for infusions (e.g., tulsi, lemongrass, chamomile parts) when traded as raw botanicals fall under HS 1211. (EU/UK have also endorsed HS 1211.90 for rooibos-type herbal infusion materials.)
  
• Blends that include tea leaf (Camellia sinensis) are “tea” under HS 0902 (even if flavored).
  

Export snapshot

• India’s exports of HS 1211 botanicals (the raw material base for herbal infusions) were ~US$450 million in 2023; top destinations were the USA (32%), Germany (11%), China (7%), Italy (6%), and the UK (3%).
  
• HS 2106 (food preparations)—the umbrella that includes many herbal/fruit infusion products—accounted for ~US$708 million of Indian exports in 2023 (note: this heading is broader than herbal teas alone). Shipment-based datasets place India among the top three global shippers of herbal teas under HS 2106 in 2024–25 (by shipment count).
  

Quality & compliance—what buyers test for

EU (most specific, product-level limits):

• Pyrrolizidine alkaloids (PAs) in herbal infusions (dried product): 200 μg/kg; a higher limit of 400 μg/kg applies to rooibos, anise, lemon balm, chamomile, thyme, peppermint, lemon verbena and mixtures exclusively of those herbs. Liquid infusions: 1.0 μg/kg for infants/young children products; 0.20 μg/kg for general herbal infusion liquids is listed under tropane section; see consolidated table.
  
• Tropane alkaloids (sum of atropine+scopolamine) in herbal infusions (dried): 25 μg/kg (and 50 μg/kg for exclusively anise seeds).
  
• Lead in tea & herbal/fruit infusions (dried): 0.75 mg/kg.
  
• Aflatoxins in dried herbs: 10 μg/kg (sum).
  
• EU treats herbal infusions as “dried products” for pesticide MRL purposes under Reg. 396/2005 (so processing/drying factors apply).

United States (frameworks you must meet):

• FSVP (FDA): U.S. importers must verify foreign suppliers and the safety of imported foods (includes herbal teas).
  
• Pesticide tolerances are set by the EPA (40 CFR Part 180)—imported botanicals can be refused if residues exceed tolerances.
  
• USDA Organic: From 19 March 2024, every organic shipment must carry an electronic NOP Import Certificate (NOPIC) under the Strengthening Organic Enforcement rule.

India (domestic standards & controls):

• FSSAI explicitly recognizes “herbal and fruit infusions” in labeling regulations; tea with added flavours requires Tea Board registration (relevant if your infusion includes tea leaf).
  

India’s strengths

Deep raw-material bench, organized under AYUSH/NMPB

• India has a coordinated medicinal-plant ecosystem (NMPB, AYUSH). As of 2022-23, ~671,000 ha were under medicinal & aromatic plants (MAPs) cultivation; 2020-21 to 2022-23 production estimates total 3.698 million tonnes.
  

Agro-climatic diversity → varietal advantages for infusion herbs

• Lemongrass (Cymbopogon spp.): multiple CSIR-CIMAP varieties (e.g., Pragati, Nima, CIM-Shikhar, CIMAP-Suwarna) deliver high oil yields and ~80% citral—useful both for flavouring and standalone infusions. These are bred and recommended for Indian plains and water-stressed conditions.
  
• Himalayan herbs (e.g., chamomile, lemon balm, thyme): CSIR-IHBT (Palampur, Himachal Pradesh) supports cultivation and processing technologies adapted to mid-Himalayan zones; community projects in Uttarakhand have established chamomile for infusion use.
  
• Moringa (leaves for herbal blends): traded under HS 1211 when dried/leaf; India is an active exporter of moringa leaf/powder used in wellness infusions.
  

Export orientation and market access

• Raw-botanical exports (HS 1211) already ship heavily to high-compliance markets (U.S., EU, Japan), demonstrating supply that can meet strict contaminant/metals limits—see destination split above.
  
• For finished herbal infusion mixes, India participates materially in global shipments under HS 2106. (Caveat: 2106 also covers many non-tea foods; shipment counts indicate presence, not value share.)
  

What buyers typically request on COAs (and how India meets them)

• PAs / Tropane alkaloids (per EU 2023/915), heavy metals (Pb, Cd where applicable), aflatoxins (dried herb specs), and pesticide MRL screen aligned to destination market (EU Reg. 396/2005).
  
• Microbiology (TPC, yeast/mould, pathogens) and moisture fit for dried herb specs; packaging suitable for infusion applications. (Aligned with FSSAI general contaminant & hygiene chapters).
  
• Organic integrity (if sold organic): NOP-compliant NOPIC attached to each organic shipment to the U.S.

Quick takeaways for the three focus angles you asked for

Exports: India exported ~US$450m of HS 1211 botanicals in 2023 (U.S. the #1 destination). Finished herbal infusion mixes move under HS 2106.90; India ranks among the top global shippers by shipment counts in 2024–25.

Quality: Export lots need to clear EU PA (200–400 μg/kg), tropane (25–50 μg/kg), lead (0.75 mg/kg), aflatoxin (10 μg/kg dried herb), and destination MRLs; U.S. requires FSVP + EPA tolerances.

India/Region-specific strengths: National MAPs programs (AYUSH/NMPB), CSIR-CIMAP and CSIR-IHBT varietal/agrotech support (lemongrass, chamomile, etc.), and broad agro-zones (plains to Himalaya) enable consistent, spec-compliant herbal infusion supply.