Import of composite products

Veterinary border control: determining factors and requirements

The new Regulation 28/2012 on composite products has entered into force from 1 March 2012. The health certificate model can be found in the implementing regulation 468/2012.

All importers must complete "Content of composite products " -form in the link on the right before asking Customs or Evira (rajatarkastus at-merkki-kapea.gif : 0 kB evira.fi) about the veterinary border control requirements entailed by these instructions. Without the form, with the details of each product to be imported properly completed in each column, Evira cannot state what products are subject to veterinary border control.

Importers must enter their estimate of whether veterinary border control will be required in the column at the end of the form. A definitive estimate of what veterinary border control will be required can often only be given at the veterinary border inspection post. To be 100% certain, importers can send their consignment directly to the BIP. Evira shall not be liable to importers for costs arising from incomplete preliminary information. You must first save the form on your own computer before sending it.

The importer shall be liable for all costs of the consignment, including the storage and holding costs of such consignments for which veterinary border control is pending, or for which establishment of the border control requirement is pending. Consignments such as the above shall if necessary be held at the border inspection post.

Border control or not

The instructions "Exceptional products not subject to veterinary checks irrespective of the concentration of raw materials of animal origin" is at the bottom of the page.

Subject to BIP controls or not - EU Commissions scheme - see the right column.

Composite products containing meat products

- all composite products containing even small amounts of meat are checked at the border

  • the composite products and the meat product used in it must originate from an EU-approved establishment i.e. must be in the list of “Commission-approved establishments”. Further details given in section "Approved establishment".
  • the composite product and the meat product used in it must come from a country approved for imports of meat products (list in Commission Decision 2007/777/EC,  Annex II – but for control purposes it is sufficient for the country and establishment to be in the list of "Commission-approved establishments", because the conditions of  2007/777/EC must be met for an establishment to be included in the list)
  • model health certificate in accordance with Annex I of the Regulation 28/2012  - certificate includes inter alia  BSE requirements, link to Decisions 2007/453 and 999/2001 relating to the BSE requirement in the health certificate on the right

Third countries may use meat  products produced in the EU or in another third country, provided that those are listed for the same group (A) for meat in Regulation (EU) No 206/2010 as the third country producing the composite product.. For this type of trade, only the treatment groups guaranteeing the highest health status have been agreed to avoid that meat  products with a lower health status are introduced into third countries with a higher health status and later on imported into the EU as they could present an animal health risk.

Composite products including fishery products

- if the fish is unprocessed, the product is subject to veterinary border control even if it consists of less than 50% fish/fish product. E.g. sushi

- If over 50% fish/fish product veterinary border control, and the following requirements must be met:

  • the consignment must be accompanied by a health certificate in accordance with Annex I
  • the establishment having produced the composite product and the fishery product contained must be Commission-approved i.e. in the list of  " Commission-approved establishments". Further details given in section "Approved establishment".
  • country of origin must be approved i.e.listed in Commission Decision 2006/766/EC. For control purposes it is sufficient for the establishment to be in the list of "Commission-approved establishments" because the countries and establishments in the list meet the requirements of the above Decision.

- if processed fishery product makes up less than half of the content of the product , veterinary border control is not performed

  • The consignment must also meet the conditions in the section in “Veterinary border control not performed if these general requirements met”

Composite products containing dairy products

- If the dairy product content is over half, or if the final composite product is not shelf-stable at ambient temperature and processed, even if the composite product has a dairy product content of less than half , the product is subject to veterinary border control (e.g. ice cream and frozen cheesecakes are always subject to veterinary border control irrespective of the percentage by weight of dairy product)

  • the consignment must be accompanied by a health certificate in accordance with Annex I
  • the establishment producing the composite product and the milk product contained must be approved i.e.in the list "Commission-approved establishments". Further details given in section "Approved establishment ".
  • the country of origin must be approved i.e. listed in Annex I of Commission Regulation 605/2010. For inspection purposes it is sufficient for the establishment to be in the list of "Commission-approved establishments" because the countries and establishments in the list meet the requirements of Regulation 605/2010

Third countries may use milk products produced in the EU or in another third country, provided that those are listed  for the same group (A and B) for milk products in Regulation (EU) No 605/2010 as the third country producing the composite product. For this type of trade, only the treatment groups guaranteeing the highest health status have been agreed to avoid that milk products with a lower health status are introduced into third countries with a higher health status and later on imported into the EU as they could present an animal health risk. The country of origin indicated in box I.7 must be listed in Annex I to Regulation (EU) No 605/2010 and the treatment applied must be conform to the treatment provided for in that list for the relevant country.

Anyway, not shelf stable composite products, which contain less than 50 % of milk products do not need to be presented for veterinary checks, if they were heat treated throughout their substance, so that any raw product is denatured.

- if the dairy product content is less than half AND the product is shelf-stable at ambient temperature AND is processed – veterinary border control is not performed

  • The consignment must additionally meet the conditions in the section “Veterinary border control not performed if these general requirements met”. If necessary,the process diagram of the processed product is checked for decision-making purposes, no veterinary border control, but Customs checks that the import conditions are met
  • the consignment does not need to be accompanied by a health certificate but  a commercial certificate indicating the treatment is sufficient (more detailed instructions on commercial certificates below)
  • the establishment does not need to be approved ; further details given in section"Approved establishment".
  • the country of origin must be approved i.e. listed in Annex I of Commission Regulation 605/2010.

All composite products containing milk (even if they are not subject to veterinary border control, such as milk chocolate with a dairy content of less than half and shelf-stable at ambient temperature) must originate from a country approved for imports of dairy products; further details given in section " Treatment must be indicated for exempt composite products containing dairy products" .

Composite products containing egg products    

- When the egg product content is over half by weight veterinary border control is performed

  • the consignment must be accompanied by a  health certificate in accordance with Annex I
  • the country of origin must be approved i.e. listed in Regulation 798/2008.
  • the egg products were produced from eggs coming from an establishment which satisfies the requirements of Section X of Annex III to Regulation (EC) n° 853/2004.

- if egg product content is less than half AND product is shelf-stable at ambient temperature AND processed, veterinary border control is not performed

  • The consignment must additionally meet the conditions in the section “Veterinary border control not performed if these general requirements met ”

- When egg product content is less than half by weight and the product is not shelf-stable at ambient temperature or is unprocessed (i.e. section "Veterinary border control not performed if these general requirements met" is not fulfilled), veterinary border control is performed

  • no  health certificate requirement
  • country of origin requirement based on risk assessment  

Honey

  • composite products containing honey are not inspected

Veterinary border control is not performed if these general requirements are met:

  • the product contains less than half fishery, dairy or egg product
  • the product is shelf-stable at ambient temperature 
  • the product is processed: it has clearly undergone in its manufacture a complete cooking orheat treatmentprocess throughout its substance, so that any raw product is denatured 
  • the product is clearly identified as intended for human consumption 
  • the product is securely packagedor sealed in clean containers
  • the product isaccompanied by a commercial document and labelled in an official language of the country of destination, so that the document and labelling together give information on the nature, quantity and number of packages of the composite products, the country of origin, the manufacturer and the ingredients

General import conditions for composite products

  • Composite products must come from a country (exceptions in section "Veterinary border control or not from 1 March 2012) that is approved for imports to the EU for the product of animal origin concerned. Approved countries and establishments are given in the link on the right "Commission-approved establishments". 
  • The processed animal product used in all composite products has to come from a third country with an approved residue control plan (listed in Decision 2011/163/EU), even if the composite product is listed in Annex II to Decision 2007/275/EC and excluded from veterinary checks in BIPs (Minutes of Expert Group on Veterinary Checks 03.07.2013) 
  • processed meat products and dairy products in composite products, regardless of their percentage by weight (i.e. whenever the percentage by weight is between 0-100), as well as fish products and egg products, only where the fish product or egg product content is over 50 per cent by weight, must originate from an establishment approved in accordance with Article 6.1(b) of Commission Regulation (EC) N°853/2004, i.e. the establishment is in the list of "Commission-approved establishments". Composite products with a dairy product content of less than half that are shelf-stable at ambient temperature are an exception, however.
  • composite products, half or more of the content of which is products of animal origin other than those mentioned above (mainly applies to processed frog’s legs and snails), must come from a third country that is approved for imports to the EU of the product of animal origin concerned.
  • composite products as described above that are subject to veterinary border control must be accompanied at the border inspection post by a health certificate in accordance with Annex I of the Composite Product Regulation or, if a health certificate is not required, by a commercial document, and fulfilment of the conditions is confirmed by correct completion of the form (new Regulations in the link on the right in English and Finnish: including model health certificates). Further details given in section " Veterinary border inspection or not".
  • The requirements for commercial documents are listed separately in these instructions

Approved establishment:  Products of animal origin contained in composite products must meet the requirements of Regulation 853/2004. Thus the establishment requirement (establishment approved by the EU for imports of the product concerned) will in future also apply (see following section) in all cases to composite products containing dairy products (with the exception of composite products with a dairy product content of less than half that are shelf-stable at ambient temperature) and composite products containing fishery products and egg products with a fish or egg percentage of over half by weight.

Approved country of origin: The section “Details of dispatched consignment” on the first page of the model health certificate in accordance with the new Regulation, required for consignments of products with a content of animal origin of over half, and section I on page 2 apply to the end product, i.e. the composite product containing processed meat product, dairy product, fishery product or egg product. Thus the information in the above sections applies to the country and the establishment in which the composite product is produced, therefore the final product containing meat, milk fish or egg must originate from a Commission-approved establishment.

The processed product of animal origin contained in a composite product is often produced outside of the establishment intended in section 1.11. of the certificate, and the final production, in which the ingredients are mixed, takes place in the above establishment in section 1.11.

If a composite product containing meat or milk produced in non-EU country A is transported to non-EU country B, importation from country B is not authorised, because the health certificate may only be issued in country A. 

Reference (8) in Part II on fish provides the possibility for fish to be processed in EU-approved country A in a Commission-approved establishment and be shipped to EU-approved country B to be manufactured into a composite product in a Commission-approved establishment from which it is authorised to import it to the EU. For egg, in accordance with reference 9, it is sufficient for the egg products to originate from an approved country, thus a processed egg product produced in a non-EU, EU-approved country may be used to produce a composite product even if the establishment producing the egg product is not Commission-approved. The end composite product containing egg product must, however, originate from an EU-approved country and establishment.

Conditions for transit or interim storage of composite products prior to onward export:

  • composite products containing meat products and dairy products which are subject to veterinary border control must come from a country that is approved for imports to the EU of the product of animal origin concerned contained in the composite product, and they must meet the proper conditions regarding treatment applying to the products concerned, as set out – for meat products - in Commission Decision  2007/777/EC and – for dairy products -  in Commission Regulation 605/2010
  • composite products as above must be accompanied by a health certificate in accordance with Annex II of the Regulation (the new Regulations are given in the link on the right in English and Finnish: including model health certificates) 
  • as regards products of animal origin, the products meet the animal health requirements in the health certificate
  • the products are intended for transit or interim storage and have undergone veterinary border control at the border inspection post of entry to the EU
  • a health certificate is, therefore, not required for composite products containing fishery products or egg products, even though they must be checked at the border if, in accordance with these instructions, they are products subject to veterinary border control.

Requirements for consignments exempt from veterinary border control as per these instructions

Listed below are the general requirements, in addition to what is stated above, regarding processing in the case of fish, milk and egg, when the consignment is not subject to veterinary border control. The requirements in this section also apply where relevant to the products in the section "Exceptional products not subject to veterinary checks irrespective of the concentration of raw materials of animal origin" (products in Annex II of Commission Decision 2007/275)  -especially the country of origin and treatment requirements  for dairy products

An example: if the country of import is Ukraine , milk or milk-based products in a composite product may not be imported at all with model A and B, if treated in accordance with either of those models, because below them there is a “0” in the column. Imports are possible with model C, because there a “+” in column C .

To access Regulation 605/2010 in Finnish, select "FI". Scroll down to "consolidated versions" for the most recent version arranged by date.  The three columns on the right in Annex I of the Regulation are interpreted as follows:  “+”indicates that the country is authorised and “0”that the country is not authorised. The letter A, B or C in the column indicates the model health certificate used. For column A countries such as the USA, the treatment does not need to be indicated in the commercial document, because even raw milk with no treatment may be imported from the USA. Model B or C is designed for treated dairy products, so the commercial health certificate must prove that the dairy product concerned has been treated using a procedure in accordance with model B or C. Instructions for indicating treatment are given in the section "Treatment must be indicated for exempt composite products containing dairy products"

Treatment must be indicated for exempt composite products containing dairy products

The country-specific processing requirements must be met in accordance with the commercial document unless subject to veterinary border control; products subject to veterinary border control require a health certificate. The country requirement and the country-specific processing requirement therefore also apply to the products in the section " Exceptional products not subject to veterinary checks irrespective of the concentration of raw materials of animal origin". Although products in that section are completely exempt from veterinary border control, Evira or Customs are entitled at any time to order a consignment to be checked or to require further information on the fulfilment of the above conditions

The treatment applied to dairy products must be indicated on the commercial document in accordance with one of the following paragraphs in the model certificate in Annex I of the new Regulation (numbering only for the purposes of these instructions and completing the form): 

  II.2.B.1.     either          [ derived from cows, ewes, goats or buffaloes , and,prior to being imported to the European Union,these dairy productshave undergone, or been produced from raw milk which has undergone

  II.2.B.1.1. either           [pasteurisation treatment, including one heat treatment with a heating effect equivalent at least to that achieved by a pasteurisation process, with heating of at least 72 °C for at least 15 seconds and, if required, sufficient to ensure a negative reaction to an alkaline phosphatase test immediately following heat treatment.]

  II.2.B.1.2 . or         [a sterilisation process, to achieve an F 0 value equal to or greater than three.]

  II.2.B.1.3. or           [an ultra high temperature (UHT) treatment of at not less than 135 °C in combination with a suitable holding time.]

  II.2.B.1.4. or               [ High Temperature Short Time (HTST) treatment at 72 °C for 15 seconds, or treatment with an equivalent pasteurisation effect applied to milk with a pH below 7.0 and, if required, sufficient to ensure a negative reaction to an alkaline phosphatase test.]

  II.2.B.1.5. or         [High Temperature Short Time (HTST) at 72 °C for 15 seconds, or treatment with an equivalent pasteurisation effect applied twice to milk with a pH equal to or greater than 7.0 and, if required, sufficient to ensure a negative reaction to an alkaline phosphatase test, after which one of the following is performed immediately:

(1)    either       [lowering the pH below 6 for one hour.]

(1)    or         [additional heating to 72 °C or more combined with desiccation.]]

Composite products containing several ingredients derived from different animals with the exception of meat products, but each less than half by weight:

add together the percentages by weight of products of animal origin, and if they total more than half, the product undergoes veterinary border control, unless it is exempted by virtue of other sections in these instructions (for products containing meat, however, as in the section "meat", i.e. this section can only be applied to composite products with contents other than meat).

  • model health certificate in accordance with Annex I
  • establishment requirement for final composite products based on which product predominates and what establishment the composite product was produced in

Exceptional products not subject to veterinary checks irrespective of the concentration of raw materials of animal origin (products in Annex II of Commission Decision 2007/275):

  • Biscuits
  • Bread
  • Cakes
  • Chocolate
  • Confectionery (including sweets)
  • Unfilled gelatine capsules
  • Food supplements packaged for the final consumer, containing small amounts of animal productand those including glucosamine, chondroitin, or chitosan
  • Meat extracts and meat concentrates
  • Olives stuffed with fish
  • Pasta and noodles not mixed or filled with meat product 
  • Soup stocks and flavourings packaged for the final consumer, containing meat extracts, meat concentrates, animal fats, or fish oils, powders or extracts

In practice all food supplements packaged for the final consumer meet the requirement “Food supplements packaged for the final consumer containing small amounts of animal product and thoseincluding glucosamine, chondroitin, or chitosan”, if they are oral capsules or tablets, therefore they are not subject to veterinary border control. A 0.5 litre bottle of food supplement may be considered an example of what constitutes more than a “small amount”. However, food supplements no longer pose a risk from the point of view of the spread of animal diseases, so interpreting whether they should be subject to veterinary checks is at the discretion of the border veterinarian.

None of the requirements regarding countries of origin authorised for imports to the EU or treatment apply to composite products containing products other than dairy products in accordance with Annex II as listed in section 3.2.. However, the country of origin of composite products containing dairy products (e.g. chocolate) must be approved, i.e. listed in Annex I of Regulation 605/2010, and the treatment must be in accordance with Commission Regulation 605/2010/EU.

Safeguard measures

Safeguard measures must always be observed. At present a number of safeguard measures are in force concerning Chinese foodstuffs, for example.

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