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 20 to 22 of Commission Delegated Regulation (EU) No 2022/2292 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.
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
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Requirements |
Category of composite product |
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Non shelf-stable |
Shelf-stable |
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Containing colostrum-based products or meat products except gelatine, collagen or highly refined products derived from meat |
Not containing colostrum-based products or meat products except gelatine, collagen or highly refined products derived from meat |
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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. |
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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 colostrum-based product or/and 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. |
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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/or is listed in Annex I of Implementing Regulation (EU) 2021/405. |
For each processed product of animal origin contained in the composite product exported to the EU*. |
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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 Commission Delegated Regulation (EU) 2020/692. |
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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. |
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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). |
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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. |
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* 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 Annex I of Implementing Regulation (EU) 2021/405.