Some pigs will fly before you can import certain foods into the EU. Let's explore the rules.
Composite goods are commodities that comprise both plant-based and animal-based processing ingredients. For these products, you may need export health certifications to get into the EU. In this blog, you can find a guide, a decision tree, timeframes, requirements, and exemptions. Let's go!
When goods containing animal and plant products enter the EU, they are subject to extra paperwork controls and veterinary tests.
What are composite products?
Composite food and beverage items are made up of a combination of plant and processed animal components. Lasagne, ham pizza, and cream liqueurs are among examples. Many of these items coming into the EU from other countries are subject to inspection to ensure they fulfil EU food safety regulations. The danger caused by composite goods to human and animal health is determined by the type of components used, as well as the storage and packing circumstances.
However, there are few exceptions, most notably where the public health risk is deemed to be small. The EU has created a list of such items that are excluded from these inspections.
What are the EU rules and requirements on composite products?
Requirements will no longer be dependent on the amount of meat, milk, and other animal-derived components in processed food preparations. This indicates that the percentage of animal-derived processed products in the composite product is unimportant.
Instead, they will be determined by the animal or public health risk associated with certain animal-derived products, as well as the manner in which they are transported or kept. If this occurs at a regulated temperature, these are now referred to as "non-shelf-stable" composite items. They are said to as "shelf-stable" if they can be stored at room temperature.
EHC
Third-country firms fulfil these standards by submitting an export health certificate (EHC). This is a formal document confirming that the export fulfils the EU's health regulations. If a company transports food manufactured from animal products from a third nation to the EU, it must normally apply for an EHC.
This means that if a shelf-stable product has no processed meat, it is immediately lower in danger.
Exemptions
Certain sweets, chocolate, pasta, bread, cakes, biscuits, waffles, and soups may be excluded from official restrictions at the EU's border checkpoints. However, in order for this to happen, the food must be manufactured in EU factories or situated in other countries but authorised for import into the EU. At the moment, all food outlets in the United Kingdom are certified for EU imports.
What challenges do they pose for food manufacturers?
The new legislation means that new EHCs have been introduced and some existing EU EHCs will be replaced. Unless, of course, they are exempted. Knowing whether they need an EHC, selecting the right and most up to date one, completing and certifying it correctly confuses many businesses. Yet, much depends on getting this right.
Third country food exporters need to use the correct new export health certificate (EHC) to ensure not being stopped at the border and potentially turned around or the food destroyed.
So, make sure you get this right, if you are an exporter of composite products you will need to use the new certificate.
How can food manufacturers navigate the changes, and what advice would you give them?
Step 1 Identify which of the categories your product falls: Shelf-stable or no shelf-stable.
Step 2. Check if meat or meat products are present.
Step 3. Check if you could be exempt from an EHC. If you are exempted, remember to still follow the traditional export rules and consider providing the driver with some evidence.
Step 4 Identify the right EHC. You can find the new and old set of certificates here: https://www.gov.uk/export-health-certificates?keywords=composite+product
Step 5 Ensure it is completed correctly and properly certified by a veterinarian
Step 6 Before shipment, ensure the movement is registered in the EU Commission’s Trade Control and Expert System (TRACES).
Step 7 Ensure the transport operator exporting the goods out of the UK has the complete and correct paperwork when arriving at the UK border.
What other documentation is required for composite products that are exempt from certification?
Make sure you don’t forget that you still need to follow the traditional export formalities, too. So, besides your export health licence, you must file an accurate customs' declaration, issue the correct invoice for international trade, ideally with a statement of origin (to claim preferential duty), have the right packing list alongside transportation documentation, e.g. a CIM consignment note. You may need to provide proof of insurance, too.
Summary of changes
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