Composites – SCPHA

Importing Composite Products of Animal Origin

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Please see detailed guidance for the following:

List of foodstuffs exempt from veterinary checks

COMPOSITES UPDATES

What are composite products?

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.

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, they would also be considered products of animal origin.

See below for FAQs on composites.

Which products require a veterinary check?

In general, any composite food product that contains a product of animal origin requires a veterinary check, unless it meets all of the criteria below.

Products exempt from veterinary checks must meet all the following criteria:

There is no meat product (including no meat extracts or powders present)
The total animal origin content is less than 50% by weight
The product is shelf stable at ambient temperature or if refrigerated the final composite product has clearly undergone during its manufacture a complete cooking or heat treatment process throughout its substance, so that any raw product is denatured
The composite product is clearly identified as for human consumption
The composite product is securely packaged or sealed in clean containers
The composite product is accompanied by a commercial document and labelled in an official language of a member state, so that the document and labelling together give information on the nature, quantity, number of packages, country of origin and manufacturer of both the composite product and its ingredients.
Any dairy content is from an approved source.

Additionally, composite products on the following list are also exempt, provided they do not contain any meat products (including meat extracts and powders) and any dairy content is from an approved source. View the list of exempt products and find out more about products that are subject to checks.

Import requirements for products subject to veterinary checks

If you are importing a composite product which is subject to veterinary checks the following requirements must be met:

Health Certificate

A health certificate is required if the composite product contains any of the following:

processed meat (including meat powders and meat extracts)
any processed dairy product where the final composite product has not been cooked and requires refrigeration
50% or more dairy content if shelf stable
50% or more processed fishery products
50% or more processed egg products

If the product contains 50% or more of any other animal product e.g. gelatine, honey, collagen then the EU health certificate that applies to the pure product is required. Processed animal product content not mentioned above does not have to be certified (although it can be) but must still meet the general requirements to come from an approved establishment in an approved third country with an approved residue control plan for the product concerned.

Ingredients

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 the EU. 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 products are detained even if not subject to veterinary checks

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:

a copy of the invoice
a copy of the packing list
a copy of the bill of lading

Where it is not clear that the goods are exempt from veterinary checks, further information will be required:

The ingredients list including the % of any animal product present. (This should be a list of the actual ingredients and not nutritional information such as amount of protein or carbohydrates present)
For any fishery product content, the species from which the product is derived
The country of origin of any animal product present
Where dairy ingredients are present, details of the heat treatment(s) (with starting pH) the raw milk underwent during the manufacture of the dairy ingredients before they were incorporated into the final product
The brand
For refrigerated products, details of the manufacturing process of the composite product, ideally in the form of a flowchart, clearly showing the points at which the animal-origin ingredients were added and any subsequent heat-treatment of the final composite product including details of the time, temperature applied and core-temperature achieved
The above information should come from the exporter clearly identifying the consignment concerned, or 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 EU-compliant i.e. the ingredients must come either from the EU or be from a third country on the relevant EU third country list with an approved residue control plan for the product concerned and be from an EU approved establishment

FAQs

What kind of composite products are subject to veterinary checks?

Meat pie (containing cooked meat)
Canned tuna salad (contains tuna combined with vegetables to make a salad)
Chicken curry (pieces of cooked chicken combined with vegetables in a sauce)
Prawn spring roll containing 50%+ cooked prawn
Pizza containing uncooked pasteurised cheese, (because it requires refrigeration, and the final product not cooked)
Gateau with a layer of pasteurised cream (because requires refrigeration and final product with cream in place has not been cooked).
Cup noodle containing meat powder
Biscuits, confectionery, butter toast with a dairy content from an unapproved country

What kinds of composite products are not subject to veterinary

Fully cooked pizza with less than 50% cheese and no meat(providing dairy content is from an approved source)
Fully cooked prawn spring roll with less than 50% prawn
Mayonnaise with less than 50% pasteurised egg content
Biscuits, confectionery, butter toast with a dairy content from an approved country (provided there is no meat product content and the combine egg and dairy content is <20%)

Can you give me some examples of foodstuffs containing plant material which are not composite products but are processed animal products containing plant material?

Uncooked meat pie containing raw meat (not a composite product because meat is raw)
Breaded raw prawns (not a composite product because prawns are raw)
Honey with nuts (not a composite product because honey is raw)
Canned tuna in oil (plant material essential for manufacture)
Cooked tuna fillets in a chilli marinade (marinade adds specific characteristics – flavour, texture – to the tuna)
Cooked breaded fish or prawns (bread coating gives specific characteristics to prawns)
Surimi/crab sticks (a small amount of plant product is sometimes added to give specific characteristics to the fish content)
Battered chicken nuggets (batter gives specific characteristics – flavour, texture – to the chicken)
Corned beef containing glucose or small amounts of onions (glucose/onions give specific characteristics to corned beef)
Strawberry yoghurt (strawberries give specific characteristics – flavour, texture – to the yoghurt)
Milk-based dessert with a fruit topping (fruit topping adds specific characteristics – flavour, texture – to the milk dessert)
Battered cooked cheese e.g. ‘paneer poppers’ (batter gives specific characteristics – texture – to the cheese)
Fish sauce with 10% fishery product content, other ingredients are sugar and water. This is a fishery product (no relevant plant material to make it a composite product). Subject to vet checks as a fishery product – the 50% rule applies only to composite products
Yogurt drink like Yakult containing water, 2% skimmed milk powder and sugar. This is a dairy product. There is no relevant plant material to make it a composite product
Gulab Jamun, Rasgulla and similar canned products from India. These consist of cottage cheese balls (@5%) in syrup in a can. These are dairy products (no relevant plant material) and cannot be imported from India

Further guidance

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:

The ingredients list including the % of any animal product present. (This should be a list of the actual ingredients and not nutritional information such as amount of protein or carbohydrates present)
For any fishery product content, the species from which the product is derived
The country of origin of any animal product present
Where dairy ingredients are present, details of the heat treatment(s) (with starting pH) the raw milk underwent during the manufacture of the dairy ingredients before they were incorporated into the final product

The brand

For refrigerated products, details of the manufacturing process of the composite product, ideally in the form of a flowchart, clearly showing the points at which the animal-origin ingredients were added and any subsequent heat-treatment of the final composite product including details of the time, temperature applied and core-temperature achieved
Photographs of the product and packaging showing the ingredients listed on the label also help