Composite Products

Legal definition: Article 2 of Commission Decision 2007/275/EC-

A composite product is a food for human consumption containing processed animal products combined with plant material.

• It might be made by combining a previously processed animal product with plant material, e.g. a beef burger, or processing the animal origin material during the manufacture of the composite product e.g. Prawn spring roll containing 50%+ cooked prawn.

The product will not be referred to as a composite product if it:

1. contains any raw material of animal origin g. it is seasoned raw meat, seasoned raw fish, flavoured milk for human consumption or
2. if it is not intended for human consumption (Does not cover petfood or animal feed) e.g. dog, cat food.

There are some situations where a processed animal product combined with plant material would not be considered a composite product:

1. It the plant ingredient has only a technical role in the processing. For technical reason i.e. it is required for manufacture of the product e.g. cheese made with vegetarian rennet) or
2. Is present only to add a special characteristic (e.g. colour, flavour, sweetness, texture e.g. strawberry yogurt).

In the following examples the products would be considered processed products of animal origin rather than composite products:

• Canned tuna in vegetable oil. This is a processed fishery product and not a composite product because the vegetable oil is necessary for conservation and flavouring purpose of the canned fish.

• Where sugar is added for sweetness, herbs and spices are used to add flavour, or plant products are added as a thickening agent or as decoration, they would also be considered products of animal origin. e.g. milk powder with 50% of sugar is a dairy product and not a composite product

In general, any foodstuff containing product of animal origin requires official border controls, unless the composite product meets all of the below criteria.

Products exempt from veterinary checks must meet all the following criteria:

1. There is no meat product (including no meat extracts or powders present), regardless of the percentage of it in the composite product.
2. There is no meat product but other product of animal origin (dairy, fish, egg, honey, etc.), and the total product/s of animal origin content is less than 50% in weight.
3. The composite product is shelf stable at ambient temperature or, if refrigerated, the final composite product has clearly undergone during its manufacture a complete cooking or heat treatment process throughout its substance, so that any raw product is denatured.
4. The composite product is clearly identified as for human consumption.
5. The composite product is securely packaged or sealed in clean containers.
6. The composite product is accompanied by a commercial document and labelled in English, so that the document and labelling together give information on the nature, quantity, number of packages, country of origin and manufacturer of both the composite product and its ingredients.
7. Any dairy content is from an approved source. This can be found clicking here for Non-EU Countries and HERE for EU countries.

Additionally, composite products on the Annex II of Decision 2007/275/EC clicking here are also exempt, provided that the final composite products is treated as provided in Article 6(1)(a) of Decision 2007/275/EC.-“The composite product is shelf stable at ambient temperature or if refrigerated the final composite product has clearly undergone during its manufacture a complete cooking or heat treatment process throughout its substance, so that any raw product is denatured.”

Summary – to be outside official border controls: Article 6.1 (a) & Article 6.2 of Decision 2007/275/EC

• No raw animal origin material
• No meat product
• <50% total animal product content
• Shelf stable, or if requires refrigeration final composite product has been cooked
• For human consumption
• Securely packaged in clean containers
• Labelling / commercial documents provide all required information on the composite product and its ingredients
• Dairy content from approved 3rd country & undergone required treatment prior to inclusion (Article 6.2)

Please see the additional documents section where you will find the decision tree which will help you to determine if your Composite Product is exempt of official border controls .

Other additional controls -

All animal origin content must come from a country with an approved residue control plan. The enforcement will be completed at the border under general food hygiene legislation (OVS/2017/08)

If your consignment is detained by Port Health Authority you will need to submit further information (usually by email).
Basic information needed for all detained consignments:

• a copy of the invoice
• a copy of the packing list
• a copy of the bill of lading

Where it is not clear that the goods are subject or exempt from official border controls, further information will be required:

• The ingredients list including the % of any animal product present. (This should be a list of the actual ingredients and not nutritional information such as amount of protein or carbohydrates present).
• For any animal origin content in the product, the species from which the product is derived.
• The country of origin of any animal product present.
• Where dairy ingredients are present, details of the heat treatment(s) (with pH) the raw milk underwent during the manufacture of the dairy ingredients.
• The brand.
• For refrigerated products, details of the manufacturing process of the composite product, ideally in the form of a flowchart, clearly showing the points at which the animal-origin ingredients were added and any subsequent heat-treatment of the final composite product including details of the time, temperature applied and core-temperature achieved.

The above information should come from the exporter clearly identifying the consignment concerned, or from the manufacturer dated less than 6 months from the date of dispatch.

If you are importing a composite product which is subject to Official border controls the following requirements must be met:

Health Certificate

A health certificate is required if the composite product contains any of the following:

• Any amount of processed meat (including meat powders and meat extracts)
• Any processed dairy product where the final composite product has not been cooked and requires refrigeration
• 50% or more dairy content if shelf stable
• 50% or more processed fishery products
• 50% or more processed egg products
• 50% or more of all the different POAO present in the composite product.

If the product contains 50% or more of any other animal product e.g. gelatine, honey, collagen, then the Export Health Certificate that applies to the processed product is required. Processed animal product content not mentioned above does not have to be certified (although it can be) but must still meet the general requirements to come from an approved establishment in an approved third country with an approved residue control plan for the product concerned.

General principles:

• POAO content: must meet the GB animal and public health requirements that apply to POAO concerned.

And

• Finished composite product: must meet general food hygiene requirements.

Where the composite products health certificate is required, for each section of the certificate that must be completed there are restrictions on the origin of the animal product ingredients used, as follows:

The animal product ingredient must come from the same country that manufactured the composite product if it is approved to produce such animal products or to be from GB or from countries with same health status for meat or dairy than the country producer of the composite product.

“Similar high health status” means:

Meat product content:

• Meat products can only go from one Treatment A country to another Treatment A country (treatment applicable to the species concerned) Please see:

HERE for non-EU country

HERE for EU and EFTA countries

Dairy product content:

• Dairy products can only go from

1. from one Column A country to another Column A country
2. from one Column B country to another Column B country
3. but cannot move from a Column C country to another country. Please see:

HERE for non-EU country

HERE for EU and EFTA countries

Country of origin.

The country where the composite product is manufactured must be on the third country list for each POAO section of the certificate that has to be completed.