What counts as a composite food product

Composite food products are for human consumption only.

They contain a mix of:

• processed products of animal origin (POAO)
• plant products used as a main ingredient – not just added for flavouring or processing

Examples are:

• lasagne
• pork pies
• pepperoni pizza
• cream liqueurs
• chicken burritos

You can continue to export or move some composite products from GB to the EU or NI after 1 January 2021.

What does not count as a composite food product

These products do not count as composite foods:

• food made from unprocessed POAO, such as fresh chicken
• plant-based food products with no POAO content
• food not intended for human consumption

In addition, food with small amounts of plant products, such as oil or herbs, are not composite products.

This is because the oil or herbs are only added for processing purposes or to give extra flavour.

Some examples are:

• cheeses with added herbs
• sausages with garlic
• yogurts with added fruit

These foods would be classed as dairy, meat or plant products. You should use the following guidance to export or move these products to the EU or NI from 1 January 2021:

• animal products
• food made from plants

If a product does not meet the composite product definition but has several types of POAO in its contents, you’ll need an export health certificate (EHC) for each individual POAO component in the product.

How to export or move composite food products GB to the EU or NI from 1 January 2021

Before you start, you’ll need to check if your product is exempt from EU border control posts (BCPs) or NI points of entry.

If you do not have an exemption, you’ll need to follow these steps.

1. Make sure your products meet EU standards.
2. Follow the wider changes for exporting to the EU after 1 January 2021, for example, around tariffs and customs declarations.
3. Follow HMRC guidance for moving goods from GB to NI.
4. Complete the EHC and supporting documents for sending composite products to the EU or NI. Follow the process to get your EHC signed by a vet.
5. You’ll need an additional EHC for composites containing honey, gelatine or snails.
6. Plan your route to get an inspection at an EU BCP or NI point of entry that can accept your type of goods.

Restricted and prohibited goods

EU rules mean you will not be able to export the following goods to the EU:

• chilled minced meat (red meat)
• chilled meat preparations (for example, sausages)
• minced meat (poultry)
• poultry and ratite/game bird mechanically separated meat
• raw milk from TB herds
• ungraded eggs
• composite products containing dairy products made from unpasteurised milk (for example, a ready meal topped with unpasteurised cheese)

You will not be able to re-export certain animal and animal products including:

• fresh meat originally from the EU
• milk not from the UK
• products using products of animal origin from non-EU countries

Movements from GB to NI

You can continue to move the following restricted and prohibited meat products from GB to NI from 1 January 2021:

• frozen or chilled minced meat of poultry, ratites and wild game birds
• chilled minced meat from animals other than poultry
• chilled meat preparations
• any unprocessed meat produced from meat initially imported into GB from the EU

This will be in place for 6 months. The government will continue to explore permanent reciprocal arrangements. You must also make sure the meat products:

• enter NI through a designated point of entry, and follow the channelling procedure applicable from the designated point of entry through to the destination supermarket in Northern Ireland, as directed by the point of entry authority
• are sold exclusively to end consumers in supermarkets located in NI, and they’re not sold to other operators of the food chain
• are accompanied by official certificates issued by the UK competent authorities (based on similar models already existing for fresh meat, minced meat and meat preparations)
• are packed for end consumers and have a label reading “These products from the United Kingdom may not be sold outside Northern Ireland”

Composite foods exempt from inspection at an EU border control post (BCP) or NI point of entry

Some composite products do not need EHCs or inspection at an EU BCP or NI point of entry.

This exemption applies if all of the following apply:

• made without processed meat, or meat extracts or powders
• made with less than 50% of any other processed POAO (any dairy must come from an approved country and have undergone the correct heat treatment for that country)
• labelled for human consumption
• shelf-stable at ambient temperature or have clearly undergone a complete cooking or heat-treatment process throughout, during manufacture, so that any raw product is denatured
• securely packaged or sealed in clean containers

Or if the composite is one of these products:

• confectionery (including sweets) and chocolate, heat-treated and containing less than 50% of processed dairy and egg products
• pasta and noodles not mixed or filled with processed meat product, heat-treated and containing less than 50% of processed dairy and egg products
• bread, cakes, biscuits, waffles and wafers, rusks, toasted bread and similar toasted products, heat-treated and containing less than 20% of processed dairy and egg products
• olives stuffed with fish
• soup stocks and flavourings packaged for the final consumer, heat-treated and containing less than 50% of fish oils, fish powders or fish extracts
• food supplements packaged for the final consumer, containing small amounts (in total less than 20%) of processed animal products (including glucosamine, chondroitin and/or chitosan) other than meat products

Heat treated means the product either:

• is shelf-stable at ambient temperature
• has undergone complete cooking or heat-treatment during manufacture so that any raw product is denatured

How to export or move these exempt products from 1 January 2021

You’ll:

• need a commercial document instead of an EHC
• be able to send your products through any EU point of entry (you do not need to go through an EU BCP for inspections)
• need to follow the wider changes for exporting to the EU, for example, tariffs and customs declarations or for moving goods from GB to NI

You need to give the following information, either on the product labelling, or in the commercial documents sent with the products, or both:

• the nature, quantity and number of packages of the composite products
• the country of origin
• manufacturer details
• list of ingredients

Contact the point of entry in the EU to find out if your exempt products have to meet any more requirements. For example, to export exempt products to the Republic of Ireland you’ll need to follow the application and pre-notification process.

EU standards for composite products

To export or move composite goods from GB to the EU or NI, they must meet EU standards.

Products with processed meat or more than 50% milk, dairy, egg or fishery products

The unprocessed meat, milk, dairy, egg or fish component in your product must come from:

• a third country approved by the EU
• an EU-approved establishment in that third country (this does not apply to wild-caught fish)

The third country must have a residue plan for the component you’re processing.

The food component must also have undergone heat treatment to meet EU rules. To find out more about these rules, check the details on your EHC or speak with your official vet.

Your composite product can be assembled at a registered establishment rather than an EU-approved establishment.

To export some GB-caught fish and fishery products in composite products, you may need a catch certificate and processing statement or storage document. This applies if you’re exporting a composite product using tariff codes 1604 and 1605 where the fish makes up more than 20% of the content. Exempt species include freshwater fish and aquaculture – check the list of exempt species.

Products made with processed POAO, such as honey, gelatine or snails

To export or move these composite goods from GB to the EU or NI:

• the POAO must come from an approved third country
• this approved third country must have a residue plan for the component you’re processing

The composite goods do not need to be:

• processed in an approved establishment
• heat-treated in line with EU rules

If half or more of the content of a composite product is made up of honey, gelatine or snails, you may need to get 2 types of EHC to send with your consignment. You’ll need:

1. An EHC for the individual product, for example, honey, snails or gelatine.
2. A composite food product EHC if the product also contains meat, fish, dairy or eggs.

If a composite product requires a composite product certificate and less than half of its content is honey, gelatine or snails it may not need an additional health certificate for the honey, gelatine or snail component.

Individual EU BCPs or NI points of entry may apply different rules on this. You, the EU importer or NI trader, should check the requirements with the BCP or NI point of entry to reduce the risk of your products being delayed or rejected.

Exporting composite products from NI to the EU

There will be no new requirements for exports of composite products from NI to the EU.

Grace period for authorised traders moving food from GB to NI

There will be a 3 month grace period from certification through to 1 April 2021 for authorised traders such as supermarkets and their trusted suppliers from 1 January 2021. If you’re moving composite products from GB to NI, you will not require official certification, such as export health certificates, phytosanitary certificates or marketing standards certification.

The UK Government and the Northern Ireland Department for Agriculture, Environment and Rural Affairs will engage in a rapid exercise to ensure that traders who can benefit from these arrangements are identified prior to 31 December. The Government will not discriminate against smaller suppliers or between different companies in implementing these practical measures.

The following conditions will be attached to these arrangements:

• the goods are packaged for end consumers and they bear a label reading “These products from the United Kingdom may not be marketed outside Northern Ireland”
• they are destined solely for sale to end consumers in supermarkets located in Northern Ireland, and they cannot be sold to other operators of the food chain
• they are accompanied by a simplified official certificate globally stating the products meet all the import requirements of EU legislation
• they enter Northern Ireland through a designated point of entry, where they are submitted to a systematic documentary check and to a risk-based identity check on a selection of items in the means of transport
• They are monitored through a channelling procedure applicable from the designated point of entry to the destination supermarket in NI