New EU import rules for entry of composite products in effect from April 21

Filipino manufacturers and exporters should take note that from April 21, 2021, new requirements for the entry into the European Union (EU) of composite products will be applied.

The composite products legislation is laid down in Commission Decision 2007/275/EC, Regulation (EU) No 28/2012, and Regulation (EU) No 468/2012.

A composite product is defined 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.”

This definition is contained in Commission Decision 2007/275/EC, according to Paolo Caricato, deputy head of unit within the Health and Food Safety Directorate General of the European Commission during a recent e-forum organized by the Philippine trade, agriculture, and foreign affairs departments.

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

Jerome Bunyi, agriculture counselor of the Philippine Embassy in Brussels, in the same forum said the rationale for the new regulation is the concern that the animal ingredients in the composite products could carry avian influenza, foot and mouth disease or other animal-borne illnesses that could be brought into the EU.

According to Tradeline Philippines, the animal-based component present in the composite product must come from a third country whose residue monitoring plan has been approved by the EU and is listed in Commission Decision 2011/163/EU.

A third country importing a specific animal-based component, like milk or eggs, from another country whose residue monitoring plan has been approved by the EU, will have to notify the EU so that said third country will appear in a footnote on the specific animal-based component in the list contained in Decision 2011/163/EU, added Tradeline, the Department of Trade and Industry’s business intelligence platform.

The new regulation sets out the conditions for importing composite products from non-EU countries and will apply from April 21. From this date onwards, Commission Delegated Regulation (EU) 2019/625 will use three categories for composite products:

  1. Non-shelf stable composite products
  2. Shelf-stable composite products that contain meat products
  3. Shelf-stable composite products that do not contain meat products

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.

An official certificate will be required for composite products within categories 1 and 2. Meanwhile, a company private attestation will be required for category 3, attesting that the dairy products and egg products contained in the composite products have undergone at least the risk-mitigating treatment.

Category 3 can further be divided into products that will be subject to control at the border, and products that will be subject to control at the destination within the EU.

To be eligible to export composite products to the EU, a country must have:

o An approved residue monitoring plan for each of the ingredients of animal origin in question, in which case the country is listed in the Annex to Commission Decision 2011/163/EU; or
o It must source the animal ingredients either from an EU member state or a third country which is listed for those commodities

The Philippines, being accredited as an exporter of fishery products to the EU, has an approved residue monitoring plan for aquaculture products. For milk products, Australia and New Zealand have approved residue monitoring plans, to name a few. For eggs, China, Japan and India are included in the list of third countries having an EU approved residue monitoring plan, according to Tradeline.

Composite products listed as lower risk products will be established before April 21 by a Commission Delegated Regulation, and these products will be exempted from veterinary control at the EU border but may be controlled at destination.

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