What counts as a composite food product?
Composite food products are for human consumption only.
They contain a mix of:
- processed products of animal origin (POAO)
- plant products used as a main ingredient – not just added for flavouring or processing
- pork pies
- pepperoni pizza
- cream liqueurs
- chicken burritos
You can continue to export these composite products to the EU after 1 January 2021.
What does not count as a composite food product?
These products do not count as composite foods:
- food made from unprocessed POAO, such as fresh chicken
- plant-based food products with no POAO content
- food not intended for human consumption
In addition, food with small amounts of plant products, such as oil or herbs, are not composite products.
This is because the oil or herbs are only added for processing purposes or to give extra flavour.
Some examples are:
- cheeses with added herbs
- sausages with garlic
- yogurts with added fruit
These foods would be classed as dairy, meat or plant products. You should use the following guidance to export:
If a product does not meet the composite product definition but has several types of POAO in its contents, you’ll need an export health certificate (EHC) for each individual POAO component in the product.
How to export composite food products from 1 January 2021?
Before you start, you’ll need to check if your product is exempt from EU border control posts (BCPs), previously known as border inspection posts.
If you do not have an exemption, you’ll need to follow these steps.
- Make sure your products meet EU standards.
- Follow the wider changes for exporting to the EU after 1 January 2021, for example, around tariffs and customs declarations.
- Complete the EHC and supporting documents for sending composite products to the EU. Follow the process to get your EHC signed by a vet.
- You’ll need an additional EHC for composites containing honey, gelatine or snails.
- Plan your route to get an inspection at an EU BCP that can accept your type of goods.
Composite foods exempt from inspection at an EU border control post (BCP)
Some composite products do not need EHCs or inspection at a BCP.
This exemption applies if all of the following apply:
- made without processed meat, or meat extracts or powders
- made with less than 50% of any other processed POAO (any dairy must come from an approved country and have undergone the correct heat treatment for that country)
- labelled for human consumption
- shelf-stable at ambient temperature or have clearly undergone a complete cooking or heat-treatment process throughout, during manufacture, so that any raw product is denatured
- securely packaged or sealed in clean containers
Or if the composite is one of these products:
- confectionery (including sweets) and chocolate, heat-treated and containing less than 50% of processed dairy and egg products
- pasta and noodles not mixed or filled with processed meat product, heat-treated and containing less than 50% of processed dairy and egg products
- bread, cakes, biscuits, waffles and wafers, rusks, toasted bread and similar toasted products, heat-treated and containing less than 20% of processed dairy and egg products
- olives stuffed with fish
- soup stocks and flavourings packaged for the final consumer, heat-treated and containing less than 50% of fish oils, fish powders or fish extracts
- 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
Heat treated means the product either:
- is shelf-stable at ambient temperature
- has undergone complete cooking or heat-treatment during manufacture so that any raw product is denatured
How to export these exempt products from 1 January 2021
- will need a commercial document instead of an EHC
- can send your products through any EU point of entry (you do not need to go through an EU BCP for inspections)
- need to follow the wider changes for exporting to the EU, for example, tariffs and customs declarations
Your goods also need to be labelled in an official EU language, with the:
- nature, quantity and number of packages in the composite products
- country of origin
EU standards for composite products
To export composite goods to the EU, they must meet EU standards.
Products with processed meat or more than 50% milk, dairy, egg or fishery products
The unprocessed meat, milk, dairy, egg or fish component in your product must come from:
- a third country approved by the EU
- an EU-approved establishment in that third country (this does not apply to wild-caught fish)
The third country must have a residue plan for the component you’re processing.
The food component must also have undergone heat treatment to meet EU rules. To find out more about these rules, check the details on your EHC or speak with your official vet.
Your composite product can be assembled at a registered establishmentrather than an EU-approved establishment.
To export some UK-caught fish and fishery products in composite products, you may need a catch certificate. This applies if you’re exporting a composite product using tariff codes 1604 and 1605 where the fish makes up more than 20% of the content. Exempt species include freshwater fish and aquaculture – check the list of exempt species.
Once you’ve got a catch certificate, email it to your importer in the EU, who’ll need to send it to their import control authority.
If the fish is imported from a third country and then stored or processed in the UK before it’s exported to the EU, you’ll need to show storage documents or processing statements as well as the original catch certificate used to import the fish into the UK.
Products made with processed POAO, such as honey, gelatine or snails
To export these composite goods to the EU:
- the POAO must come from an approved third country
- this approved third country must have a residue plan for the component you’re processing
The composite goods do not need to be:
- processed in an approved establishment
- heat-treated in line with EU rules
If half or more of the content of a composite product is made up of honey, gelatine or snails, you may need to get 2 types of EHC to send with your consignment. You’ll need:
- An EHC for the individual product, for example, honey, snails or gelatine.
- A composite food product EHC if the product also contains meat, fish, dairy or eggs.
If a composite product requires a composite product certificate and less than half of its content is honey, gelatine or snails it may not need an additional health certificate for the honey, gelatine or snail component.
Individual EU BCPs may apply different rules on this. You, or the EU importer, should check the requirements with the BCP of entry to reduce the risk of your products being delayed or rejected at the border.
Source: HMRC Guidance published 11 October 2019
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