The purpose of this guidance document is to achieve a common understanding in the Member States (MS) on the implementation of the import and transit control procedures for consignments of composite products from third countries. The guidance should clarify the import and transit conditions applicable for certain composite products containing processed products of animal origin and plant products as well as for products containing different products of animal origin and for products containing unprocessed products of animal origin and plant products. This guidance document supplements the information in the following guidance documents: "Key questions related to import requirements and the EU rules on food hygiene and official food controls" published on: http://ec.europa.eu/food/international/trade/interpretation_imports.pdf "Guidance document on the implementation of certain provisions of Regulation (EC) No 853/2004 on the hygiene of food of animal origin" published on: http://ec.europa.eu/food/food/biosafety/hygienelegislation/guide_en.htm For food hygiene purposes, food containing both products of plant origin and processed products of animal origin are called “composite products”, which are covered in Article 1(2) and 6(4) of Regulation (EC) No 853/2004. They are defined in Article 2(a) of Commission Decision 2007/275/EC as: "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". This definition is quite wide and therefore it is necessary to distinguish between composite products, processed products of animal origin (PPAO) and products, which could erroneously be considered as composite products. Processed products of animal origin versus composite products Annex I to this guidance document gives an overview of the scope of Regulations (EC) No 852/2004 and 853/2004. This overview is not exhaustive and therefore purely indicative and it might be subject to review in function of experience gained with the rules. Regulation (EC) No 853/2004 does not apply to the production of food containing both products of plant origin and processed products of animal origin, unless expressly indicated to the contrary. Such exclusion from the scope is based upon the reason that the risk posed by the ingredient of animal origin can be controlled by implementing the rules of Regulation (EC) No 852/2004 without there being a need to apply more detailed
Assembly of food of plant origin with unprocessed food of animal origin further processed together. 853/2004 The risk is identical to the one posed when manufacturing processed food of animal origin, e.g. meat products. This justifies that the rules of Regulation (EC) No 853/2004 should apply. Approval of premises is required by EU rules and an identification mark must be applied to such foods. Canning products made from vegetables and fresh meat Ice cream from raw milk See remarks made under Chapter 2.1 of this guidance document Assembly of food of plant origin with unprocessed food of animal origin and placed on the market as such. 853/2004 The risk is identical to the one posed when handling raw products of animal origin, e.g. fresh meat etc. Approval of premises is required by EU rules and an identification mark must be applied to such foods. Assembling raw meat/fish skewer with vegetables
Final product has been cooked. 1604 Frozen Fried Thai Fish Cake Ingredients: fish fillet (69%), beans (9%), water (7%), tapioca starch (5%), red curry past (5%), sugar (2%), salt (1,5%), flavour enhances (0,9%), kiffir lime leave (0,3%), egg white powder (0,2%), phosphate (0,1%) Fishery product (similar to cooked surimi) as produced from raw fish and plant ingredients add special characteristics. Subject to BIP checks, origin from approved establishment and fishery product certificate is required. The small amount of egg white powder has a technological function, as it is necessary for the manufacture and does not need to be certified, but the food business operator has to ensure that it comes from an approved establishment and third country. 2106 90 98 Paneer Poppers, frozen Ingredients: cheese coated with bread crumbs Paneer is fresh cheese similar to curd, but final product has been cooked. Dairy product, as bread crumbs add special characteristics; subject to BIP checks, approved establishment and dairy certificate depending on heat treatment requirement (B or C) of the third country of origin is required. 2106 90 98 Paneer Bhurji Roll, frozen, filled with vegetables and paneer (a type of fresh cheese similar to cottage cheese). Final product has not been cooked. Composite product, subject to BIP checks, even if it contains less than 50% milk product as cheese is fresh (not shelf stable at ambient temperature). 1602 32 Chicken en croute, frozen: Ingredients: 42% cooked chicken, puff pastry, 9% mango, sugar, 2% pak choi, palm oil, spices. Cooked chicken that Composite product, subject to BIP checks and it can come from registered establishment. If raw chicken has been wrapped with the pastry dough and then backed,
has been wrapped in pastry dough and backed in the oven. the processing establishment needs to be approved. 1602, if meat content is more than 20% 2106, if meat content is less than 20% Hamburger with beef burger, cheese, tomato and salad Composite product, subject to BIP checks, composite product certificate filled in for meat and dairy part. If produced from raw meat, it needs to come from an approved establishment and approved third country with required treatment (Decision 2007/777/EC). 1605 Breaded King Prawns raw prawns, frozen, battered with bread crumb coating; Fishery product, as the prawns are raw, subject to BIP checks and certificate for fishery products is required. 1603 00 10 Granulated Chicken Bouillon Ingredients: food additives (monosodium glutamate, nucleotide seasonings, food flavour, vitamin B2), salt rice powder, chicken meat, egg, curry powder (contains turmeric), chive, garlic, white dextrin. Shelf stable No pieces of meat, just granules which dissolve in hot water. Composite product, but not subject to BIP checks as in Annex II to Decision 2007/275/EC. However, general food hygiene requirements such as approved third country approved residue control plan and approved establishment for the chicken meat contained in the bouillon need to be respected. Contains two sachets of cod roe seasoning and two packets of dried seaweed Shelf stable 2103 90 90 Sauce Cod Roe: Ingredients of sauce packet: salted cod roe; shortening (canola oil, palm oil), salt, monosodium glutamate, sugar, hydrolysed protein (soybean, wheat, corn, fish), cochineal Composite product, not subject to BIP checks, as shelf stable at ambient temperature and less than 50% of PPOAO. The fish and milk used in the composite product need to come from approved third countries, which also have
extract, disodium guanylate, disodium inosinate, lactose (milk) approved residue control plans, and from approved establishments. 2106 90 98 Instant drink powder, shelf stable Contains 48% milk solids, sugar, peanut oil, maltodextrin, caramel, mineral mix and other ingredients. Dairy product, as plant ingredients add special characteristics; subject to BIP checks, origin from approved establishment and approved third country including approved residue control pan and appropriate heat treatment is required. 2202 90 99 Coffee-Drink: Ingredients: water, sugar, skim milk powder (2%), whole milk powder (3,7%), coffee-extract (0,6%, 6,0 g/l), vanilla extract, E473, E475, E322, E407, increased caffeine contents: 30 mg/100 ml; Composite product and not subject to BIP checks, as dairy content below 50% and shelf stable at ambient temperature. However, origin of the dairy content from approved third country and approved establishment including approved residue control plan is required. 2105 00 Vanilla flavoured ice cream with wafer and hazelnuts Ingredients: water, sugar, milk solids, refined palm kernel oil, glucose syrup, hazelnuts, emulsifier, stabilizers, artificial flavouring, chocolate compound, wafer Composite product, if produced without involving a heat treatment, may origin from registered establishment, subject to BIP checks, as not shelf stable. Dairy product, if processed involving a heat treatment, origin from approved establishment, subject to BIP checks and certificate for dairy products is required. In both cases, dairy content from approved third country and
approved establishment including approved residue control plan is required. 2208 70 Cream liqueurs Ingredients: usually made with fruits, coffee, alcohol, milk, milk powder, egg yolk and/or cream Shelf stable at ambient temperature Composite product and the dairy part included shall only be derived from, and be treated as provided for in the list of approved third countries for dairy products. Not subject to BIP checks, if less than 50% of animal origin content. 2103 90 90 Fish sauce: Codex Standard: STAN 302/2011 defines fish sauce as obtained from fermentation of a mixture of fish and salt (and water). Fishery product with fishery product certificate, subject to BIP checks independent from amount of fish. 2103 90 90 Flavouring containing e.g. 40% fish sauce and water Fishery product, subject to BIP checks, fishery product certificate is required. It would be a composite product, if also vegetable parts are added. Adding only water does not make it a composite product. 2103 90 90 Oyster sauce Ingredients: oyster extract, 30% soy sauce, brine and seasonings Composite product under Annex II to Decision 2007/275/EC and not subject to BIP checks. 1517 90 99 Food additive, microencapsulated tuna oil powder Ingredients: containing 48% highly refined and deodorized tuna oil, 15% casein, dextrose, dried glucose syrup, Composite product, subject to BIP checks, dairy and fish part of the composite certificate needs to be filled in and third country of origin of the composite product approved for both.
sodium ascorbate, lecithin and others. Shelf stable 2106 90 92 Tablets, not packaged for the final consumer Ingredients for each tablet: Glucosamine sulphate (wild fish origin): 34.6% of total ingredients Chondroitin (poultry origin): 27.7% of total ingredients ~38% of the tablets consist of plant materials. Composite product, subject to BIP checks, meat and fish part of the composite certificate needs to be filled in and third country of origin of the composite product approved for both. If originating from China, attestation for Chloramphenicol etc. as provided for in Decision 2002/994/EC is required. 1602 Ingredients: meat marinated in yoghurt, milk, salt, spices, olive oil, then roasted, charcoal grilled and frozen Meat product, subject to BIP checks, meat product certificate required and food business operator to ensure milk and yoghurt from approved establishments/third countries. 1602, if meat content is more than 20% 2106, if meat content is less than 20% Egg and bacon breakfast burrito: Ingredients: filling with scrambled egg, bacon, cream, cheese, honey Tortilla made of flour, milk powder etc. If raw eggs are used, PPOAO as the tortilla wrap was not heat treated with the PPOAO. The burrito has to originate from an approved establishment with health certificates for all different animal product ingredients used. If egg products are used, composite product and the burrito may originate from a registered establishment with the composite product certificate filled in for all animal product ingredients used. In both cases subject to