Importing composite products

What is a composite product
Categories of composite products
Import requirements 
Transition period
Further Information 

What is a composite product

A composite product is defined in legislation as a foodstuff intended for human consumption that contains both processed products of animal origin and products of plant origin, examples of composite products include cheese and ham pizza, salmon and broccoli quiche, mayonnaise (made with pasteurised egg).  If the animal product ingredient is not processed (e.g. raw meat in a pie, honey with nuts), then the food is not a composite product but is a food of animal origin.

Import requirements for composite products changed on 21 April 2021. Previously the rules were based on the percentage of the processed products of animal origin in the composite product but are now based on the animal health or public health risk linked to the ingredients of animal origin and whether the composite product needs to be transported or stored under controlled temperature conditions.

Categories of composite products

Three categories of composite products are established  in EU legislation  (Regulation (EU) 2019/625):

(1) non shelf-stable composite products,

(2) shelf-stable composite products that contain any quantity of meat products, except gelatine, collagen and highly refined products, and

(3) shelf-stable composite products that do not contain meat products, except gelatine, collagen and highly refined products.

 

Import requirements
 
Composite products are subject to import requirements which include registering as an importer and submitting import documentation. Depending on the content and shelf-stability of the composite product, its import into Ireland requires either

  •  a composite product health certificate (issued by the relevant competent authority in the UK)
    or
  •  a private attestation (from the importer). Composite products subject to veterinary checks at import must enter through a Border Control Post.

 
The legislation contains a list of composite products that are exempted from veterinary checks on import into Ireland. For composite products that do not require a veterinary check at import, the private attestation must accompany the composite product to the point of placing on the market.

Transition Period

The EU legislation (Regulation (EU) 2020/2235) includes a transition period in regard to composite products that required a health certificate prior to 21 April 2021, by permitting the use of existing certificates that are issued prior to 21 August 2021 to be used until 20 October 2021. For products where no certification was previously required the new rules apply in full since 21 April 2021.

The EU Commission have developed a comparative table that illustrates the transition period and the effect on the certification requirements on the imports of composite products into the EU after 21 April 2021 and until 20 October 2021.

 Further Information on importing composite products

 

 


 

 


Last reviewed: 30/5/2021

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