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Composite Food Products

1. A composite product is a foodstuff intended for human consumption that contains both processed product of animal origin and product of plant origin.

2. Composite products are foods for human consumption. They do not include petfood or animal feed.                                                                            

3. A composite product does not include any product that has raw (unprocessed) animal material.

4. Not all foodstuffs containing processed product of animal origin and product of plant origin are composite products e.g the plant material is present for technical reasons (it is required for the manufacture of the product e.g. cheese made with rennet) or to add specific characteristics (colour, flavour, texture).

5. The following composite products are subject to veterinary checks without exception:

Composite products containing processed meat product

Composite products containing ≥ 50% of their substance of any one processed product of animal origin other than a processed meat product

Composite products containing no processed meat product and < 50% of their substance of processed milk product where the final products do not meet the requirements for derogation

6. Consignments of composite products subject to veterinary checks should be accompanied by the relevant health certificate and fulfill all other import conditions associated with importation for animal products.

1. Composite products may be derogated from veterinary checks if they comply with all the conditions below, as laid down in Article 6 of Commission Decision 2007/275/EC:

The composite product contains < 50% of its total food product derived from animal origin

Is clearly identified as being for human consumption

Is securely packaged or sealed in clean containers

Is either: shelf stable at ambient temperature                                                    

OR                                                                                                             

Has undergone during its manufacturing a complete cooking or denaturing process throughout its substance so that any raw product is denatured

Is accompanied by a commercial document, labelled in an official language of a Member State stating:

  • the nature, quantity and number of packages of the composite products
  • the country of origin
  • the manufacturer
  • the ingredients

 

2. Any milk product included in a composite product must originate from an approved Third Country and from an establishment approved to export milk into the EU and be treated as provided for in Annex I to Commission Regulation (EU) 605/2010.

3. Furthermore, any milk product included in a composite product must come from a country with an approved residue plan for milk as outlined in Commission Decision (EU) 2011/163/EU.

1. The following products are exempted from veterinary checks, as listed in Annex II of Commission Decision 2007/275/EC:

CN Code

Explanation

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

1. Prior to the importation of a composite product, the following information should be provided to the BCP:

The name of the product

The name of the manufacturer

The CN Code

A list of all raw materials used to manufacture the product

The proportion of each raw material in the final product

The country and establishment of origin of any milk product

Whether the final product is ambient, chilled or frozen

Unless ambient – a detailed description of the manufacturing process including a production flow chart

Labelling details of the product

Any other relevant details associated with the product

 

2. Please use the form below to outline this information, and send to the relevant Border Control Post (BCP):

a. Dublin Port: Bips.DubPort@agriculture.gov.ie

b. Shannon Airport: Bips.ShanAirport@agriculture.gov.ie

c. Application for Derogation of a Composite Product (pdf 200Kb)    

3. This will allow the inspectors to decipher whether or not the product will be subject to veterinary controls at the Border Control Post (BCP).

4. Composite products requiring veterinary controls must be accompanied by the relevant veterinary health certificate,  the models of which are laid down in EU legislation.

5. Composite products (those not derogated from veterinary checks) shall be presented at a Border Control Post accompanied by a veterinary health certificate, drawn up in conformity with the Model in Annex I to Commission Implementing Regulation (EU) 2019/628.

a. Part II of the heath certificate should be completed in accordance with the specific European Union health requirements relating to the animal species or to the nature of the products and as defined in the equivalence agreements with certain third countries or in other European Union legislation, such as that for certification.

b. The certifying veterinarian should ensure that only the relevant paragraphs and, where appropriate, additional guarantees and/or special conditions applicable to exporting country are included.

6. This will allow the inspectors to decipher whether or not the product will be subject to veterinary controls at the Border Control Post (BCP).

7. Composite products requiring veterinary controls must be accompanied by the relevant veterinary health certificate, the models of which are laid down in EU legislation.

1. The person responsible for the load being imported (the importer or a customs agent acting on their behalf) must give the BCP at the intended point of entry advance notification of the arrival of the consignment

2. There is a required minimum pre-notification notice period of at least 24 hours notice in advance of the consignment’s arrival

3. Failure to submit documentation within this timeline may result in significant delays in the consignment being processed through the Border Control Post.

4. Pre-notification is given by the submission of Part 1 of the Common Health Veterinary Document (CHED-P) through the online TRACES NT system

5. Copies of other supporting documentation associated with the consignment should be submitted at this time as well - such as the Health Certificate, Invoice, Packing list etc.

a. Consignments of composite products entering the EU must be inspected at an EU-approved Border control Post (BCP) where Member States' official veterinarians ensure they fulfil all the requirements provided for in the EU legislation.

b. The person responsible for the load being imported (the importer or a customs agent acting on their behalf) must give the BCP at the intended point of entry advance notification of the arrival of the consignment.

c. There is a required minimum pre-notification notice period of at least 24 hours’ notice in advance of the consignment’s arrival.

d. Failure to submit correct documentation within this timeline may result in significant delays in the consignment being processed through the Border Control Post.

e. Pre-notification is given by the submission of Part 1 of the Common Health Entry Document (CHED-P), as is laid down in Commission Implementing Regulation (EC) No. 2019/1715, through the online TRACES NT

f. Copies of other supporting documentation associated with the consignment should be submitted at this time as well - such as the health certificate, invoice, packing list etc.

1. Providing all the documentation has been submitted correctly and within the correct timeframes, a large proportion of the documentary check can be commenced in advance of the consignment’s arrival. This includes the following processes, for composite products not derogated from veterinary checks:

a. Checking the CHED was correctly filled out

b. Checking the commercial documentation, packing list etc.

c. Ensuring the health certificate is the appropriate model for the product being imported, that it has been correctly filled out and that there is no sign of forgery/fraudulence

d. The original hard copy of the health certificate must travel with the consignment, and will be checked and held at the BCP at the point of entry into the EU

2. Provided all is in order with the documentary check, the consignment will then be subject to an identity check at the BCP to ensure it identifies with the consignment that was declared in the documentation

3. A proportion of consignments will be selected for a full physical inspection with/without sampling as appropriate

4. Following satisfactory checks at the BCP, consignments may then circulate freely within the EU.  If the consignment does not meet the import requirements, the consignment may be rejected and either re-exported or destroyed.