New EU rules, on the conditions for import of ‘composite’ food products came into force on 21 April 2021. This impacts UK exporters of certain products to the EU.
Composite products are defined as products containing both processed products of animal origin (e.g. dairy items) and products of plant origin used as a main ingredient. Examples include lasagne and pork pies, as well as many types of confectionery including chocolate bars and cakes.
The new regulation will impact UK food distributors as well as manufacturers. Extensive details on all processed products of animal origin within a composite product must be available. This includes where it was processed and details of the risk-mitigating heat treatment applied.
Previously, products were exempt from veterinary checks upon import if the composite product contained less than 50% of processed products of animal origin and certain conditions were met.
With the new regulation, this threshold has been removed, and all composite products now require some form of additional paperwork, which is dictated by whether the product falls into the ‘higher’ or ‘lower’ risk category.
The ‘higher’ risk category includes composite products containing meat and ‘non-shelf stable’ composite products (products which need refrigeration, for example). The ‘lower’ risk category includes composite products which do not contain meat and are considered ‘shelf-stable’.
Products deemed ‘higher’ risk must have an export health certificate endorsed by a vet, and are subject to checks when entering the EU via a Border Control Post.
Lower risk products do not need a health certificate or to enter via a Border Control Post, but must instead have a ‘private attestation’ document. The EU importer or their agent who completes this will be reliant on the UK exporter to provide them with the necessary supporting information.
If you need help in clarifying the requirements for your product or wish to discuss these changes further, please contact Ian Worth or your usual Crowe contact.