Importing composite products

Monday 29 October 2007

A composite product is defined in European Union (EU) legislation as a foodstuff intended for human consumption that contains both processed products of animal origin and products of plant origin. It also includes foodstuffs where the processing of the primary product is an essential part of producing the final product.

Commission Decision 2007/275/EC sets out import conditions for importing products of animal origin that are subject to veterinary checks at Border Inspection Post (BIPs), including certain composite products from non-EU countries, and those composite products that are not subject to veterinary checks. The decision can be found at the link below. The conditions are summarised below.

When veterinary checks are not necessary

A composite product that contains less than half its substance of processed product of animal origin other than processed meat product, and meets the following requirements of Article 6 of Decision 2007/275/EC.

• shelf-stable at ambient temperature or has clearly undergone in its manufacture a complete cooking or heat treatment process throughout their substance so that any raw product is denatured
• clearly identified for human consumption
• securely packaged or sealed in clean containers
• accompanied by a commercial document and labelled in an official EU language so that document and label together give information on the nature, quantity and number of packages of the composite product, the country of origin, the manufacturer and the ingredients

will not need to be imported through a BIP as no veterinary checks will be necessary.

However, if the composite product contains a milk product, then the milk must only come from an approved country as listed in Annex I of Commission Decision 2004/438/EC, as amended by Commission Decision 2006/295/EC. Both decisions can be found at the links below.

When veterinary checks are necessary

Where a composite product arrives from a non-EU country and contains any amount of processed meat products, or half or more than half its substance of a processed product of animal origin, then this product must be imported through a BIP and is subject to veterinary checks.

Where a composite product which does not meet the requirements of Article 6 of Decision 2007/275/EC arrives from a non-EU country then this product must be imported through a BIP and is subject to veterinary checks. This applies even if it contains no processed meat product, and less than half of its substance is a processed product of animal origin

Other composite products and foodstuffs

Annex II of Decision 2007/275/EC lists some composite products and foodstuffs which are not subject to veterinary checks and these are:

• biscuits
• bread
• cakes
• chocolate
• confectionery (including sweets)
• unfilled gelatine capsules
• food supplements packaged for the final consumer, containing small amounts of animal product, and those including glucosamine, chondroitin or chitosan
• meat extracts and meat concentrates
• olives stuffed with fish
• pasta and noodles not mixed or filled with meat product
• soup stocks and flavourings packaged for the final consumer, containing meat extracts, meat concentrates, animal fats, or fish oils, powders or extracts

Food business operators are reminded that it is their responsibility to ensure any foodstuffs they want to import comply with EU and national rules in place to protect public and animal health. Importers should satisfy themselves that any composite products coming to the UK comply with the import conditions as above and as set out in Decision 2007/275/EC.