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Food Safety

EU import conditions for composite products

Composite products are foodstuffs containing both products of plant origin and processed products of animal origin. In accordance with Articles 1(2) and 6(4) of Regulation (EC) No 853/2004, the composite products must be manufactured with processed products of animal origin produced in EU-approved establishments located either in EU Member States or in third countries authorised for the entry into the European Union of those processed products of animal origin.

Under Regulation (EU) No 2017/625, the framework legislation on official controls that has applied since 14 December 2019, rules for the entry into the Union of composite products were laid down in Articles 12 to 14 of Commission Delegated Regulation (EU) No 2019/625 and these are due to apply on 21 April 2021. Such rules are proportionate to the risk presented by composite products. They are summarised in the table below and in a decision tree.

With a view to smoothen the transition, Article 35 of Commission Implementing Regulation (EU) No 2020/2235 introduces a transitional period of six months for the imports of composite products during which the old certificate will be accepted to enter the Union. Where no certificate was required prior to 21 April 2021, then the new relevant certificate or private attestation must be provided. Implementing Regulation (EU) 2021/1329, in order to avoid any unnecessary disruptions in trade, extends the transitional period to 15 March 2022, provided that the relevant certificate is signed before 15 January 2022 by the person authorised to sign it. The effect of this transition is summarised here.

Member States and the Commission have agreed, in the framework of the PAFF Committee, on a set of transitional practical elements for implementation of the rules for issuing the model private attestation provided for in Annex V to Regulation (EU) 2020/2235. This provides for a transitional solution to the unnecessary potential trade disruptions that provisions laid down in Article 163 of Delegated Regulation (EU) 2020/692 as regards risk-mitigating treatments for dairy products contained in shelf-stable composite products could cause from 21 April 21. They are provided in this Statement.

A compilation of Questions & Answers is available to help clarifying as many issues arising. It will be updated as necessary.

Summary of the requirements applicable to composite products intended to be imported into the EU (pdf printable version)

Requirements

Category of composite product

Non shelf-stable

Shelf-stable

Containing meat products except gelatine, collagen or highly refined products derived from meat

Not containing meat products except gelatine, collagen or highly refined products derived from meat

Ingredients of animal origin

All processed products of animal origin contained in the composite products must come from EU approved establishments located in countries authorised to export such processed products of animal origin to the EU, including as regards the control of residues.

The country of production of the composite product is listed in Commission Implementing Regulation (EU) 2021/404 or Commission Implementing Regulation (EU) 2021/405 as relevant

For each processed product of animal origin contained in the composite product

For the meat product contained in the composite product

Either for meat products, fishery products, dairy products (and colostrum-based) or egg products, be they contained in the composite product or not, with the exception of composite products containing gelatine, collagen or highly refined products, where their country of production has to be authorised for the gelatine, collagen or highly refined products they contain.

The country of production of the composite product has an EU approved plan for monitoring residues (in the species/commodities from which the processed products of animal origin are derived) and is listed in Decision 2011/163/EU

For each processed product of animal origin contained in the composite product exported to the EU*.

Animal health aspects

The processed products of animal origin contained in the composite products comply with the relevant requirements for entry into the EU laid down in Commission Delegated Regulation (EU) 2020/692. They have been produced either in the EU, in the country of production of the composite product, or in another listed country provided that they have not undergone any risk mitigating treatment different from those applicable in the country of production of the composite product

The dairy products and the egg products contained in the composite product have been subjected to a risk mitigation treatment, at least equivalent to those set out in column B of Annex XXVII and Annex XXVIII to Commission Delegated Regulation (EU) 2020/692

Official certificate established in Chapter 50 of Annex III of Commission Implementing Regulation (EU) No 2020/2235

Required and signed by the competent authority of the country of production of the composite product.

Not applicable

Private attestation established in Annex V of Commission Implementing Regulation (EU) No 2020/2235

Not applicable

Required, prepared and signed by the representative of the importing food business operator (in case of exemption from control at the border, it may accompany the products only at the time of the placing on the market)

Control in EU border control posts

Yes

Yes, except when the composite product presents a lower risk as listed in Annex to Commission Delegated Regulation (EU) 2021/630 and is then exempted from the control at the border.

* Should the country of production of the composite product (country A) wish to source processed products of animal origin from outside its territory, its competent authority ensures that such processed products of animal origin come from either EU-approved establishments in EU Member States or in other third countries listed for the relevant species/commodities in Commission Decision 2011/163/EU without a restrictive footnote as provided for in Article 2(2) of that Decision. Country A must also be listed in Decision 2011/163/EU either with or without said footnote.

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