Breaking the Ice and Building Barriers in Technical Trade | The EU Revises Import Conditions and Regulatory Requirements for Certain Composite Foods!

The EU updates import and regulatory requirements for certain composite foods, affecting technical trade by creating both opportunities and obstacles

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On June 7, 2022, the Official Journal of the European Union published Regulation (EU) 2022/887, which revised certain provisions of Regulations (EU) 2019/625, (EU) 2019/2122, and (EU) 2021/630 related to the import conditions and regulatory requirements of composite foods. The regulation will come into effect on June 27, 2022.

Q: What are composite foods?

A: Composite foods refer to foods that contain both plant-based and processed animal-based ingredients.

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Regulation (EU) 2019/625 on composite foods (the terms of which came into effect on April 21, 2021) abandoned the previous practice of classifying composite foods based on the proportion of animal-based ingredients and instead used a comprehensive assessment of the risks of animal-based ingredients to animal and public health, transportation, and storage temperatures, etc. to classify composite foods into three categories: “shelf-stable foods with meat”, “shelf-stable foods without meat”, and “non-shelf-stable foods”.

Q: How can we determine whether a food is a composite food?

A: There are two key points! First, whether the animal-based ingredients have been processed, such as meat-filled buns; second, whether the function of the plant-based ingredients in the food has changed the main characteristics of the product. If the plant-based ingredients are only used to add a certain characteristic to the animal-based ingredients and are in a subordinate position, the product belongs to processed animal-based food, such as cooked steak with added herbs or other seasoning plant-based ingredients.

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Q: What are the revisions to the import conditions and regulatory requirements for composite foods in the EU this time?

A: Let me compare the revisions to and before Regulation (EU) 2019/625 “Requirements for certain animal and goods entering the EU”:

Before the revision:

Shelf-stable composite foods containing colostrum products were classified as shelf-stable composite foods without meat (except for gelatin, collagen, and highly refined animal-derived ingredients), and their regulatory requirements were as follows:

(1) Processed animal-based ingredients in composite foods should come from EU member states or third countries (regions) approved by the EU;

(2) Processed animal-based ingredients in composite foods should be produced and processed in enterprises registered with the EU in EU member states or third countries (regions) approved by the EU;

(3) Submit an importer’s self-declaration as a quarantine-related document;

(4) Submit a declaration proving that the dairy products or eggs used in the product have undergone risk mitigation treatment.

After the revision:

(1) Considering the animal health risks of colostrum products and the lack of effective mitigation measures, colostrum products in shelf-stable composite products should come from third countries (regions) approved to export colostrum products to the EU, and official certificates are required for their import instead of importers’ self-declarations.

(2) Gelatin, collagen, and highly refined products, including when used as composite food ingredients, do not require the submission of a residual monitoring plan from the exporting country (region). However, the exporting country (region) of these products must be included in the list of third countries (regions) approved to export to the EU.

(3) If the animal-based products in a shelf-stable composite product are only food enzymes, food additives, certain food flavorings, or vitamin D3, the exporting country (region) of these animal-based ingredients does not need to be included in the list of third countries (regions) approved to export to the EU, and no residual monitoring plan from the exporting country (region) is required.

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Q: Is there anything worth paying attention to?

A: Reminder from Customs: The new EU regulation on composite foods requires that for shelf-stable composite foods containing colostrum products, the colostrum products must come from countries approved to export colostrum products to the EU and from enterprises approved by the EU, and official certificates are required.

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Chinese companies exporting composite foods containing colostrum products to the EU need to actively review and inspect whether their suppliers of dairy products, eggs, and honey are registered with the EU. If not, they should replace them as required. There are two methods to verify the supplier’s qualifications: directly ask the supplier whether they have EU registration qualifications, or search and query the following website databases:

EU-approved third-country animal material list: zllp.myy?iwd?j_?iwkpr_?iy?d=yv?oq=gpdy2021y800yku

EU-approved registered enterprise database: TRACES NT

Source: 12360 Customs Hotline

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