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A composite product is a food for human consumption containing processed animal products combined with plant material.
It might be made by combining a previously processed animal product with plant material, e.g. a beef sandwich, or processing the animal origin material during the manufacture of the composite product e.g. a cooked prawn spring roll.
If a product is a composite product, it is still a legal requirement that it complies with any import rules applicable to each of the processed animal products it contains. It must do so even if exempted from official border controls in the manner set out below and it must do so even if the proportion of processed animal product is small.
The product will not be a referred to as a composite product if it contains any raw material of animal origin or if it is not intended for human consumption e.g. it is pet food.
There are two situations where a processed animal product combined with plant material would not be considered a composite product – if the plant material has only a technical role in the processing, or is present only to add a special characteristic e.g. flavour.
In the following examples the products would be considered processed products of animal origin rather than composite products:
Canned tuna in vegetable oil. This is a processed fishery product and not a composite product because the vegetable oil is necessary as part of the manufacturing process of the canned fish.
Where sugar is added for sweetness, herbs and spices are used to add flavour, or plant products are added as a thickening agent or as decoration to products of animal origin, the food would still be considered a product of animal origin and not a composite product
See below for FAQs on composites.
A composite product requires official border controls veterinary checks, unless it meets all of the criteria below.
Products exempt from official border controls must meet all the following criteria:
Additionally, composite products listed in Annex II of Decision 2007/275 are exempt from official border controls provided they do not contain any meat products (including meat extracts and powders) and any dairy content is from an approved source.
It is important to remember that all that ‘exemption from official border controls’ means is that a consignment does not have to be pre-notified on IPAFFS, no CHED need be submitted, and it is not likely to be subject to the intensive levels of documentary, identity and physical checks which official border controls may include. However, exemption from official border controls does not mean that the product is not subject to any other rules applicable to it, and attention is drawn to the paragraphs below as to potential detention of consignments not subject to official border controls.
If you are importing a composite product which is subject to official border controls the following requirements must be met:
The composite products certificate is required if the composite product contains any of the following:
If the product contains 50% or more of any other animal product e.g. gelatine, honey, collagen then the GB health certificate that applies to the pure product is required. Processed animal product content not speifically mentioned above does not have to be certified (although it can be) but must still come from an approved establishment in an approved third country with an approved residue control plan for the product concerned.
Where the composite products health certificate is required, for each section of the certificate that has to be completed there are restrictions on the origin of the animal product ingredients used, as follows: The animal product ingredient must come from the same country that manufactured the composite product if it is approved to produce such animal products or be from GB. In the case of low-risk countries, meat products or dairy products from other low risk countries may also be used. Please contact us for detailed guidance (see below).
Some consignments not subject to official border controls are nonetheless detained by Port Health to check whether they comply with any import rules applicable to them.
If your consignment is detained by Port Health you will need to submit further information (usually by email). Basic information needed for all detained consignments:
Where it is not clear that the goods are exempt from official border controls, further information will be required:
The above information should come from the exporter clearly identifying the consignment concerned, or be from the manufacturer clearly identifying the product concerned and dated less than 6 months from the date of dispatch.
N.B. Even for composite products not subject to checks, all animal-origin ingredients must be GB-compliant i.e. the ingredients must come either from GB or be from a third country on the relevant GB third country list for the animal product concerned, with an approved residue control plan for the product concerned and be from a GB approved establishment.
If there are import rules relating to imports from the country from which you are importing (e.g. the rules on importing from China food or feed containing animal product elements), those will need to be complied with as well.
We are happy to provide advice in cases where you are not sure whether a product is a composite product or not, if you can send us the relevant information:
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