Importing Composite Products

A composite product is 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.

Examples of composite products include:

• Beef lasagne
• Pepperoni pizza
• Prawn spring roll (where the prawn is cooked)
• Chicken salad wrap
• Chicken curry (pieces of cooked chicken combined with vegetables in a sauce)

The addition of a product of plant origin to a processed animal product that is not necessary for the manufacture of the product does not automatically mean the finished food product is a composite product. For example, if the plant material is present for technical reasons or is present to add special characteristics such as flavour, sweetness or thickening.

Examples of processed animal products which are not considered to be composite products include:

• Canned tuna in vegetable oil;
• Cheeses to which herbs are added
• Yogurts to which fruit is added
• Chicken nuggets (batter or breading adds specific characteristics)

A product is not a composite product if it contains any raw material of animal origin or if it is not intended for human consumption.

Examples include:

• Skewers of meat and vegetables
• Breaded prawns (uncooked)
• Petfood

The EU Commission have developed a decision tree to guide importers as to the rules applicable to their composite product - available here.

The requirements for the entry of composite products into the EU are based on the risks to public health posed by the composite product.

Article 20 of Commission Delegated Regulation (EU) 2022/2292 establishes three categories of composite products based on risk:

Category 1. Non-shelf stable composite products

Category 2. Composite products that contain any quantity of colostrum-based products or meat products, except gelatine, collagen and highly refined products

Category 3. Shelf stable composite products that do not contain colostrum-based products or meat products, except gelatine, collagen and highly refined products.

Composite products that fall into the higher risk categories (categories 1+2 above) must be accompanied by a health certificate, drawn up in accordance with model COMP in Chapter 50 of Commission Regulation (EU) 2020/2235.

Composite products that fall into the lower risk category (category 3 above) do not require a health certificate. However they must be accompanied by a private attestation drawn up in accordance with the model private attestation in Annex V of Commission Regulation (EU) 2020/2235. The private attestation is to be completed by the importer or a representative of the importer.

1. If the country of origin of the composite product (as indicated in box 1.7 of Part I of the attestation) and the country of origin of the milk/dairy product (i.e. country where the approved establishment of origin is) are listed in Annex XVII to Implementing Regulation (EU) 2021/404 (entry into the Union of raw milk and dairy products not requiring a risk-mitigating treatment) or an EU country then the first option at point 10 of the private attestation can be retained

2. If the country of origin of the composite product (as indicated in box 1.7 of Part I of the attestation) and the country where of origin of the milk/dairy product (i.e. country where the approved establishment of origin is) are listed in Annex XVIII to Implementing Regulation (EU) 2021/404 or an EU country, then the second option at point 10 of the private attestation can be retained

3. If shelf-stable composite products containing dairy products are imported from a third country which is not listed for the import of raw milk or dairy products into the Union (i.e. not listed in in Annexes XVII or XVIII to Implementing Regulation (EU) 2021/414) and the approved establishment of origin of the dairy product is located in a listed third country/an EU country, then those dairy products contained in the composite product must have been subjected to a treatment equivalent to UHT or sterilisation and the third option at point 10 of the private attestation can be retained.

Shelf-stable composite products that contain egg, the egg must have been subjected to a treatment as detailed in Annex XXVIII of Regulation 2020/692 (Table 2).

Regulation 2022/2292 provides that consignments of composite products referred to by the following CN codes are subject to official controls at the Border Control Post (BCP): 1517, 1518, 1601 00, 1602, 1603 00, 1604, 1605, 1702, 1704, 1806, 1901, 1902, 1904, 1905, 2001, 2004, 2005, 2008 2101, 2103, 2104, 2105 00, 2106, 2202, or 2208 [CN codes available in Annex I to Regulation (EEC) No 2658/87]

A small number of very low-risk composite products are exempted from official controls. Please see the section Composite Products exempted from official controls for more information.

The operator responsible for consignments of composite products referred to by the CN codes above, which do not meet the requirements for exemption, must;

- Register with the Department of Agriculture and on TRACES-NT (IMSOC) Guidance available at:Register to import

- Provide 24 hours prior notification of the arrival of the consignment to the Border Control Post through submission of part-I of a CHED-P on TRACES NT

- Submit relevant documents to INIS Portal.

Consignments of certain very low risk composite products may be exempted from official controls at the Border Control Post as long as they are;

- Listed in the Annex to regulation 2021/630 (Table 3)

- shelf-stable

- do not contain meat

- for products under these CN codes that contain dairy or egg, the dairy and egg must have been subjected to a treatment at outlined in the section Shelf stable composite products not containing meat but containing dairy +/or egg

These exempted products must be accompanied by a private attestation to the place of destination, the point of release for free circulation in the Union, or the warehouses/premises of the operator responsible for the consignment. The private attestation does not need to travel with the consignment

For exempted composite products, the private attestation does not need to be submitted on the DAFM imports portal or TRACES. A CHED does not need to be created on TRACES. Submission of a CHED for such exempted products will create delays in the port as your product will be routed to DAFM for inspection, and a fee may be charged.

In cases where composite products that require official controls are travelling on the same load as composite products that are exempted from official controls, a separate private attestation needs to be completed for the exempted products. The exempted products should be stored separate from the composite products requiring official controls. This will facilitate the performance of controls at the BCP.

Further detail can be found on the Commission’s website here: Commission guidance on Composite Products:

A link to the Commission Questions and Answers document is available at EU Commission Questions and Answers Document

Trader Notices relating to the change in rules can be found at gov.ie - Import of Animals and Animal Products (www.gov.ie)

For additional queries please contact