Exporters, manufacturers should prepare now for EU composite products regulation

Philippine exporters and manufacturers would do well to prepare ahead of time for the implementation next month of the European Union’s (EU) new regulation on composite products (CPs), advises an agriculture expert.

Jerome Bunyi, agriculture counselor of the Philippine Embassy in Brussels, said in a recent info session that Filipino companies have to make the necessary preparations now to ensure they are compliant with the EU’s amended CP regulation when it enters into force on April 21, 2021.

A composite product is defined by the European Commission as “a foodstuff intended for human consumption that contains both processed products of animal origin and products of plant origin and includes those where the processing of primary product is an integral part of the production of the final product.”

Under the new rule, entry into the EU of composite products will no longer be based on the percentage of the animal-based ingredients but on the public health risk linked to the composite product itself.

Bunyi explained that the new regulation is being implemented due to concern that the animal ingredients in the CPs could be carrying animal-borne illnesses such as avian influenza and foot and mouth disease.

Thus, the CP rule prescribes that the animal-based component present in the composite product should come from a third country that is accredited by the EU.

Bunyi underscored that the most significant change for composite products from previous regulatory requirements is the requirement that all processed products of animal origin-meat, dairy, eggs, and fish-regardless of their percentage as an ingredient in the product, are required to be sourced from EU-listed establishments to be eligible for import.

He advises Filipino exporters and manufacturers to talk to their importers before April 21 to ensure that their composite products are compliant so their exports will not encounter any issues.

And since some Philippine manufacturers may not be aware of the new regulation, Bunyi also enjoined exporters and consolidators to discuss with them the need for traceability or segregation measures to ensure that only animal ingredients from EU-approved countries are used.

For example, manufacturers can source raw milk and dairy products from approved third countries such as Argentina, Australia, Canada, Israel, New Zealand, Singapore, Turkey and the United States.

For egg and egg products, they can source from suppliers in third countries authorized to export these to the EU, like Argentina, Canada, China, India, Turkey and the US.

Bunyi said it is likewise important that Philippine companies make a statement notifying the European Commission that they are using animal products from EU-approved countries.

Moreover, it is vital that manufacturers apply the EU-prescribed risk-mitigating treatment for milk and eggs, which involves “cooking at a certain temperature and a certain duration.”

Bunyi emphasized that under the new CP rules, the Philippines, though not EU-accredited for milk and eggs, can source these ingredients from the EU or other accredited third country suppliers. This is provided that the EU notification and other requirements are complied with.

Meanwhile, for composite products containing processed fish, he said the Philippines will not have any compliance issues since the country is already EU-accredited for this.

“We just have to make sure that the fishery products we use comes from the accredited facility or approved by BFAR [Bureau of Fisheries and Aquatic Resources], being the competent authority to be used in the processing of those composite products,” he said.

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