G/SPS/GEN/1786  
 
12 June 2020  
(20-4166) Page: 1/3 
Committee on Sanitary and Phytosanitary Measures  Original: English  
 
RULES APPLICABLE TO THE ENTRY OF COMPOSI TE PRODUCTS  
INTO THE E UROPEAN UNION  AS OF 21 APRIL 2021  
COMMUNICATION BY THE  EUROPEAN UNION  
The following communication , received on 10 June  2020, is being circulated at the request of the 
Delegation of the European Union . 
 
_______________  
 
 
Composite products are foodstuffs containing both products of plant origin and processed products 
of animal origin. For the entry of composite products in to the European Union, public health rules 
were established in Commission Delegated Regulation (EU) 2019/6251 and animal health 
requirements in the Commission Delegated Regulation (EU) 2020/6922, the latter supplementing 
rules set in Regulation (EU) 2016/4 293. Rules are due to apply from 21 April 2021 onward.  
 
1  PROCESSED PRODUCTS O F ANIMAL ORIGIN CONT AINED IN THE COMPOSI TE PRODUCT  
1.  The requirements applicable to the processed products of animal origin contained in the 
composite products remain the same as at present . Any processed products of animal origin 
contained in the composite product must be produced in EU approved establishments located either:  
− in EU Member States, or  
− in third countries authorised for the entry into the European Union of those processed 
products of animal origin.  
2.  With regard to the control of residues, the third country manufacturing a composite product must 
be listed in Commission Decision 2011/163/EU4 for each processed product of animal origin 
contained in this composite product.  
3.  In practice this means that the third country manufacturing the composite product must either:  
− have an approved residue monitoring plan for each of the ingredients of animal  origin in 
question (in which case the country is listed in Annex to the above Decision) or  
 
1 Commission Delegated Regulation  (EU) 2019/625 of 4 March 2019 supplementing Regulation (EU) 
2017/625 of the European Parliament and of the Council with regard to requirements for the entry into the 
Union of consignments of certain  animals and goods intended for human consumption OJ L 13 1, 17.5.2019, 
p. 18–30. 
2 Commission Delegated Regulation  (EU) 2020/692 of 30 January 2020 supplementing Regulation (EU) 
2016/429 of the European Parliament and of the Council as regards rules for entry into the Union, and the 
movement and handling after entry of consignments of certain animals, germinal product s and products of 
animal origin OJ L 174, 3.6.2020, p. 379 –520. 
3 Regulation  (EU) 2016/ 429 of the European Parliament and of the Council of 9 March 2016 on 
transmissible animal diseases and amending and repealing certain acts in the area of animal health ( 'Animal 
Health Law ') OJ L 84, 31.3.2016, p. 1 –208. 
4 Commission Decision of 16 March 2011 on the approval of plans submitted by third countries in 
accordance with Article 29 of Council Directive 96/23/EC OJ L 70, 17.3.2011, p. 40 –46. G/SPS/GEN/1786  
 
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  − must source the processed products of animal origin contained in the composite product 
from either an EU member State or a third country which is listed in the abo ve Decision for 
those processed products of animal origin. In that latter case, the country manufacturing 
the composite product must be listed in the Annex to the above Decision with a footnote5 
acknowledging such a sourcing.  
4.  Should a country manufacturin g a composite product wish to source ingredients of animal origin 
from another country or an EU member State it would have to inform the European Commission of 
its intention to source ingredients in accordance with Article 2(1) of Commission Decision 
2011/ 163/EU and address a request to the Director for Health and Food Audits and Analysis. A letter 
was addressed to all countries in that regard on 3 December 2019.  
2  THREE RISK -BASED CAT EGORIES OF COMPOSITE  PRODUCTS  
5.  The way in which composite products are categ orised will however change. Entry requirements 
will no longer be based on percentage  of ingredients of animal origin but rather on the animal health 
or public health risk linked to the composite product itself. Article 12 of Commission Delegated 
Regulation  (EU) 2019/625 establishes three categories of composite products:  
1. non shelf stable composite products,  
2. shelf stable composite products that contain meat products, and  
3. shelf stable composite products that do not contain meat products.  
6.  The requirements applicable to the composite products will be established in accordance with the 
above risk categorisation.  
3  CATEGORY -BASED REQUI REMENTS FOR THE COUN TRY MANUFACTURING CO MPOSITE 
PRODUCTS  
1) Non-shelf-stable composite products shall originate from countries autho rised for entry into 
the European Union, in the relevant legislation on animal health, public health and residues6, 
for each processed product of animal origin contained in the composite product;  
2) Shelf-stable composite products that contain processed meat shall originate from countries 
authorised for the entry into the European Union of those meat products7 contained in the 
composite product  (including for the control of residues);  
3) Shelf-stable composite product s that do not contain processed meat shall ori ginate from 
countries authorised for the entry into the European Union of either  meat products3 or dairy 
products/colostrum -based products8 or fishery products9 or egg products10, including for the 
respective control of residues, independently of them being  included in the composite 
product or not.. 
 
 
5 "Third countries  using only raw material either from member States or from other third countries 
approved for imports of such raw material to the Union, in accordance with Article 2."  
6 Commission Decision No 2011/163/EU of 16 March 2011 on the approval of plans submitted by third 
countries in accordance with Article 29 of Council Directive 96/23/EC OJ L 70, 17.3.2011, p. 40  
7 Please  note that this legal act will be repealed as from 21 April 2021 and will be replaced by legal acts 
based on Regulation (EU) 2016/429 ( "Animal Hea lth Law "). 
Commission Decision 2007/777/EC of 29 November 2007 laying down the animal and public health conditions 
and model certificates for imports of certain meat products and treated stomachs, bladders and intestines for 
human consumption from third co untries and repealing Decision 2005/432/EC OJ L 312, 30.11.2007, p. 49.  
8 Please note that this legal act will be repealed as from 21 April 2021 and will be replaced by legal acts 
based on Regulation (EU) 2016/429 ( "Animal Health Law "). 
Commission Regulati on (EU) No 605/2010 of 2 July 2010 laying down animal and public health and veterinary 
certification conditions for the introduction into the European Union of raw milk and dairy products intended for 
human consumption OJ L 175, 10.7.2010, p. 1.  
9 Please n ote that this legal act will be repealed as from 14 December 2019 and will be replaced by 
Regulation (EU) 2019/626 . 
Commission Decision 2006/766/EC of 6 November 2006 establishing the lists of third countries and territories 
from which imports of bivalve m olluscs, echinoderms, tunicates, marine gastropods and fishery products are 
permitted OJ L 320, 18.11.2006, p. 53.  
10 Please note that this legal act will be repealed as from 21 April 2021 and will be replaced by legal acts 
based on Regulation (EU) 2016/429  ("Animal Health Law") . G/SPS/GEN/1786  
 
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  4  CATEGORY -BASED REQUI REMENTS FOR CERTIFIC ATION AND ATTESTATIO N 
GUARANTEES ACCOMPANY ING THE COMPOSITE PR ODUCTS  
7.  (1) Non -shelf-stable composite products and (2) shelf -stable composite products containing 
processed meat must be accompanied by an official certificate. The model certificate is in discussion 
with EU member States. This official certificate shall be signe d by the competent authorities of the 
country where the composite product is manufactured/produced . 
8.  (3) Shelf -stable composite products not containing processed meat will only have to be 
accompanied by a private attestation provided by the importing food b usiness operator, who is 
expected to provide the information requested in Article 14(3) of Commission Delegated Regulation 
(EU) 2019/625 and the relevant documentation provided for in Commission Delegated Regulation 
(EU) 2020/692. A model attestation has b een prepared and is currently in discussion with EU 
member States.  
5  CONTROLS AT ENTRY IN TO THE UNION  
9.  All composite products will be subject to veterinary controls at the Border Control Posts before 
entry into the European Union .  
10.  However, the European Comm ission will list in a future act those composite products that, due 
to their lower risk, can be granted a derogation from veterinary control at the border and for which 
controls may be carried out at the point of destination. Discussions are ongoing and ba sed on the 
list included in Annex II to Commission Decision 2007/275(EC) concerning lists of composite 
products to be subject to controls at border control posts11. 
 
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Commission Regulation (EC) No 798/2008 of 8 August 2008 laying down a list of third countries, territories, 
zones or compartments from which poultry and poultry products may be imported into and transit through the 
Community and the  veterinary certification requirements OJ L 226, 23.8.2008, p. 1.  
11 OJ L 116 4.5.2007, p. 9 .