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Importing Composite Products
From Department of Agriculture, Food and the Marine
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A composite product is a foodstuff intended for human consumption that contains both processed products of animal origin and products of plant origin and includes those where the processing of primary product is an integral part of the production of the final product.
Examples of composite products include:
- Beef lasagne
- Pepperoni pizza
- Prawn spring roll (where the prawn is cooked)
- Chicken salad wrap
- Chicken curry (pieces of cooked chicken combined with vegetables in a sauce)
The addition of a product of plant origin to a processed animal product that is not necessary for the manufacture of the product does not automatically mean the finished food product is a composite product. For example, if the plant material is present for technical reasons or is present to add special characteristics such as flavour, sweetness or thickening.
Examples of processed animal products which are not considered to be composite products include:
- Canned tuna in vegetable oil;
- Cheeses to which herbs are added
- Yogurts to which fruit is added
- Chicken nuggets (batter or breading adds specific characteristics)
A product is not a composite product if it contains any raw material of animal origin or if it is not intended for human consumption .
Examples include:
- Skewers of meat and vegetables
- Breaded prawns (uncooked)
- Petfood
The EU Commission have developed a decision tree to guide importers as to the rules applicable to their composite product - available here
Where a health certificate had been required for a certain composite product prior to 21 April 2021, a transition period is provided by Article 35 of Commission Regulation (EU) 2020/2235. This allows for existing certificates to be used until 15 March 2021. These certificates must have been issued prior to 15 January 2022. For products where no certification was previously required the new rules apply in full from 21 April 2021.
The requirements for the entry of composite products into the EU are no longer based on the percentage of ingredients of animal origin, but rather on the risks to public health posed by the composite product.
Article 12 of Commission Delegated Regulation (EU) 2019/625 establishes three categories of composite products based on risk:
1. Non-shelf stable composite products
2. Composite products that contain any quantity of meat products, except gelatine, collagen and highly refined products, or contain any quantity of colostrum based products
3. Shelf stable composite products that do not contain meat products, except gelatine, collagen and highly refined products.
Composite products that fall into the higher risk categories (categories 1+2 above) must be accompanied by a health certificate, drawn up in accordance with model COMP in Chapter 50 of Commission Regulation (EU) 2020/2235. For products previously requiring a health certificate the transition period applies.
Composite products that fall into the lower risk category (category 3 above) do not require a health certificate. However they must be accompanied by a private attestation drawn up in accordance with the model private attestation in Annex V of Commission Regulation (EU) 2020/2235. The private attestation is to be completed by a representative of the importer.
Shelf-stable composite products that contain dairy, the dairy must have been subjected to a treatment which is relative to the country of origin of the composite product and the country of origin of the milk in the dairy product.
1. If the country of origin of the composite product (as indicated in box 1.7 of Part I of the attestation) and the country of origin of the milk/dairy product (i.e. country where the approved establishment of origin is) are listed either in;
i. column A and B of the table set out in Annex I to Regulation (EU) No 605/2010
or
ii. Annex XVII to Implementing Regulation (EU) 2021/404
Point 10 of Part II of the attestation may be deleted
2. If the country of origin of the composite product (as indicated in box 1.7 of Part I of the attestation) and the country where of origin of the milk/dairy product (i.e. country where the approved establishment of origin is) are listed in;
i. column C of the table set out in Annex I to Regulation (EU) No 605/2010
or
ii. Annex XVIII to Implementing Regulation (EU) 2021/404
then the reference to Column B in point 10 of the PA can be changed to Column A (Columns relate to Table 1 below)
3. If shelf-stable composite products containing dairy products are imported from a third country which is not listed for the import of dairy into the Union then the content of point 10 must be kept as is – i.e. those dairy products contained in the composite product must have been subjected to a treatment equivalent to UHT or sterilisation (i.e. as per Column B in table 1 below).
Shelf-stable composite products that contain egg, the egg must have been subjected to a treatment as detailed in Annex XXVIII of Regulation 2020/692 (Table 2).
“Regulation 2019/625 (Amended by Regulation 2021/573) provides that consignments of composite products referred to by the following CN codes are subject to official controls at the Border Control Post (BCP): 1517, 1518, 1601 00, 1602, 1603 00, 1604, 1605, 1702, 1806, 1901, 1902, 1904, 1905, 2001, 2004, 2005, 2103, 2104, 2105 00, 2106, 2202, 2208 [CN codes available in Annex I to Regulation (EEC) No 2658/87]
A small number of very low-risk composite products are exempted from official controls. Please see the section Composite Products exempted from official controls for more information
The operator responsible for consignments of composite products referred to by the CN codes above, which do not meet the requirements for exemption, must;
- Register with the Department of Agriculture and on TRACES-NT (IMSOC) Guidance available at: Register to import
- Provide 24 hours prior notification of the arrival of the consignment to the Border Control Post through submission of part-I of a CHED-P on TRACES NT
- Submit relevant documents to INIS Portal
Consignments of certain very low risk composite products may be exempted from official controls at the Border Control Post as long as they are;
- Listed in the Annex to regulation 2021/630 (Table 3)
- shelf-stable
- do not contain meat
- for products under these CN codes that contain dairy or egg, the dairy and egg must have been subjected to a treatment at outlined in the section Shelf stable composite products not containing meat but containing dairy +/or egg
These exempted products must be accompanied by a private attestation to the place of destination, the point of release for free circulation in the Union, or the warehouses/premises of the operator responsible for the consignment. The private attestation does not need to travel with the consignment
For exempted composite products, the private attestation does not need to be submitted on the DAFM imports portal or TRACES. A CHED does not need to be created on TRACES. Submission of a CHED for such exempted products will create delays in the port as your product will be routed to DAFM for inspection, and a fee may be charged.
In cases where composite products that require official controls are travelling on the same load as composite products that are exempted from official controls, a separate private attestation needs to be completed for the exempted products. The exempted products should be stored separate from the composite products requiring official controls. This will facilitate the performance of controls at the BCP.
Table 3: List of CN codes where products may be exempted from official controls at the BCP
Under the transition period, composite products that previously required certification for import into the EU can continue to be imported on the relevant health certificate as per Regulation 28/2012 (PDF below), under the previous rules.
For composite products where no certification was previously required the new rules apply.
Import requirements for composite products subject to official controls at border control posts
The following composite products must be presented for official controls at border control posts**:
- Composite products containing processed meat products
- Composite products containing processed milk products , other than those which contain less than half of their substance of processed milk product and meet the requirements of Article 6 of Commission Decision 2007/275/EC
- Composite products containing half or more of their substance of processed fishery products
- Composite products containing half or more of their substance of processed egg products
- Consignments of composite products containing half or more of their substance of any one processed product of animal origin other than those referred to above
Consignments of composite products subject to official controls at border control posts must comply with the following requirements:
- enter the EU through border control posts designated for the approved categories of goods;
- undergo official controls at the border control post including mandatory documentary and identity checks , as well as physical checks at the appropriate frequency;
- be accompanied by the relevant health certificate as indicated in the Composite products subject to official controls at border control posts section above:
Model health certificate for the import into the EU of composite products intended for human consumption
- the operator responsible for the consignment of composite products subject to official controls at border control posts must give prior notification of the arrival of the consignment at least 24 hours before the expected arrival by submitting Part I of the Common Health Entry Document (CHED) in TRACES-NT.
Composite products not subject to official controls at border control posts
1. Consignments of composite products which do not contain more than half of their substance of any one processed product of animal origin, other than processed meat products and processed milk products , must comply with the following requirements:
(a) The composite product must be accompanied by a commercial document indicating the nature, quantity and number of packages of the composite products, the country of origin, the manufacturer and the ingredient.
(b) The product of animal origin must come from a country with an approved residue plan in accordance with Commission Decision 2011/163/EC.
(c) The composite product does not require be presented for official controls at a border control post . However, risk based checks may be carried out at the point of entry
2. Consignments of composite products which contain less than half of their substance of processed product of animal origin other than processed meat products, but which contain processed milk products , must comply with the requirements of Article 6 of Commission Decision 2007/275/EC Commission Decision 2007/275/EC as follows:
(a) shelf-stable at ambient temperature or have clearly undergone in their manufacture a complete cooking or heat treatment process throughout their substance, so that any raw product is denatured;
(b) clearly identified as intended for human consumption ;
(c) securely packaged or sealed in clean containers;
(d) accompanied by a commercial document and labelled in an official language of a Member State, so that that document and labelling together give information on the nature, quantity and number of packages of the composite products, the country of origin, the manufacturer, and the ingredient ;
(e) milk product included in any composite products shall only be derived from countries listed in Annex I to Commission Regulation (EU) No 605/2010, and treated as indicated in that Annex.
3. In addition, the product of animal origin must come from a country with an approved residue plan in accordance with Commission Decision 2011/163/EC.
Import requirements for composite products not subject to official controls at border control posts
The following composite products are not subject to official controls at border control posts :
- Consignments of composite products not containing half or more of their substance of any one processed product of animal origin other than processed meat milk products .
- Consignments of composite products which contain less than half of their substance of processed product of animal origin other than processed meat products, but which contain processed milk products and meet the requirements of Article 6 of Commission Decision 2007/275/EC. Such consignments must be accompanied by a commercial document and labelled in an official language of a Member State, so that that document and labelling together give information on the nature, quantity and number of packages of the composite products, the country of origin, the manufacturer, and the ingredient .
- Composite products listed in Annex II of Commission Decision 2007/275/EC, as follows:
List of composite products not subject to official controls as referred to in point (b) of Article 6(1)
| CN Codes | Explanations | |
| 1704, 1806 20, 1806 31, 1806 32, 1806 90 11, 1806 90 19, 1806 90 31, 1806 90 39, 1806 90 50 | Confectionery (including sweets) and chocolate, containing less than 50 % of processed dairy and egg products and treated as provided for in Article 6(1)(a) of this Decision. | |
| 1902 19, 1902 30, 1902 40 | Pasta and noodles not mixed or filled with processed meat product; containing less than 50 % of processed dairy and egg products and treated as provided for in Article 6(1)(a) of this Decision. | |
| 1905 10, 1905 20, 1905 31, 1905 32, 1905 40, 1905 40 10, 1905 90 10, 1905 90 20, 1905 90 30, 1905 90 45, 1905 90 55, 1905 90 60, ex 1905 90 90; | Bread, cakes, biscuits, waffles and wafers, rusks, toasted bread and similar toasted products; containing less than 20 % of processed dairy and egg products and treated as provided for in Article 6(1)(a) of this Decision. 1905 90 covers only dry and brittle products. | |
| ex 2001 90 65, ex 2005 70 00 ex 1604 | Olives stuffed with less than 20 % fish, Olives stuffed with more than 20 % fish | |
| ex 2104 10 and ex 2104 20 | Soup stocks and flavourings packaged for the final consumer, containing less than 50 % of fish oils, fish powders or fish extracts and treated as provided for in Article 6(1)(a) of this Decision. | |
| ex 2106 10, ex 2106 90 | Food supplements packaged for the final consumer, containing small amounts (in total less than 20 %) of processed animal products (including glucosamine, chondroitin and/or chitosan) other than meat products. |
Importers may , as part of a risk based control, be requested to provide supporting information (e.g. ingredient list, production flow chart) to the border control post to assist in verifying exemption from controls. A template is provided below to assist in providing such information. However this template is not mandatory , and, if the information is requested by the BCP, it may be presented in another format.
Declaration for a composite product in compliance with Article 6 of Commission Decision 2007/275/EC
Legislation
- Commission Decision 2007/275/EC concerning lists of composite products to be subject to controls at border control posts
- Commission Regulation (EU) 28/2012 laying down requirements for the certification for imports into and transit through the Union of certain composite products and amending Decision 2007/275/EC and Regulation (EC) No 1162/2009
- Commission Regulation (EU) 2017/185 laying down transitional measures for the application of certain provisions of Regulations (EC) No 853/2004 and (EC) No 854/2004 of the European Parliament and of the Council
- Commission Regulation (EU) 2019/759 laying down transitional measures for the application of public health requirements of imports of food containing both products of plant origin and processed products of animal origin (composite
- Commission Implementing Regulation (EU) 2019/626 concerning lists of third countries or regions thereof authorised for the entry into the European Union of certain animals and goods intended for human consumption, amending Implementing Regulation (EU) 2016/759 as regards these lists
- Commission Implementing Regulation (EU) 2019/628 concerning model official certificates for certain animals and goods and amending Regulation (EC) No 2074/2005 and Implementing Regulation (EU) 2016/759 as regards these model certificates
- Regulation (EU) 2017/625 laying down specific rules for the organisation of official controls on products of animal origin intended for human consumption; and on official controls performed to ensure the verification of compliance with feed and food law, animal health and animal welfare rules.
Further detail can be found on the Commission’s website here: Commission guidance on Composite Products :
A link to the Commission Questions and Answers document is available at EU Commission Questions and Answers Document
Trader Notices relating to the change in rules can be found at gov.ie - Import of Animals and Animal Products (www.gov.ie)
