European Union (EU) - Export requirements for composite products

Commission Decision 2007/275/EC defines a composite product (CP) as a foodstuff intended for human consumption that contains both processed products of animal origin and products of plant origin and include those where the processing of primary product is an integral part of the production of the final product.

Eligible/ineligible product

EU export certificates for CPs refer to a list of HS code(s). This list is non exhaustive. CPs containing meat products are currently not affected by this directive. Also, additional certification may be required for processed products of animal origin (PPAO) (example honey, gelatin, snails, etc.) other than those on the current EU CP certificate. It is the responsibility of the exporter to ensure that the product being exported will be covered by the certificates issued by the CFIA.

Eligible

• Example of composite products (CPs) with associated HS codes on the EU certificate:
  • 1601, 1602, 1603, 1604, 1605, 1901, 1902, 1905, 2004, 2005, 2103, 2104, 2105, 2106.

Ineligible

• Information not available.

Pre-export approvals by the competent authority of the importing country

Establishments

• The CPs manufacturing establishments must operate using HACCP principles (see Preventive control plan (PCP) for domestic guidance) as stipulated in Commission Regulation (EC) No 852/2004 of the European Parliament and of the Council.
• The processed ingredients of animal origin (example processed dairy, egg products, fishery products) used in the composite product must come from an establishment on the list administered by the Directorate-General of Health and Food Safety (DG-SANTE). The third country lists are available on the EU website, Third Country Establishments - List per Country. Please click on "Canada" to see the associated documents.

Production controls and inspection requirements

Manufacturer's certificate

• All final export requests for CPs must be accompanied by a Manufacturer's certificate issued and signed by an authorized person of the licensed establishment where the product was manufactured or prepared.
• The product(s) must be clearly identified on the Manufacturer's certificate and match exactly the product(s) that are part of the export shipment. In the case where a large number of different products are being shipped, a computerized printout containing all the required information may be attached to the Manufacturer's certificate if it contains all the required information.
• Original signed Manufacturer's certificates are to be kept on file at the establishment. These files may be verified during preventive control inspections (PCI).

Microbiological requirements

• Composite products requiring certification, destined for human consumption, must meet the relevant microbiological criteria set out in the Commission Regulation (EC) No 2073/2005 of 15 November 2005 on microbiological criteria for foodstuffs with amendments.
• The CFIA must receive a signed copy of a laboratory report indicating that each lot of the shipment has been analyzed by an officially accredited laboratory before issuing the health certificate.
• Compositing the samples (multiple lots) is not acceptable for the analysis when it is a multi-lot shipment.

Imported ingredients of animal origin

• If imported ingredients of animal origin (example dairy products and/or egg products and/or fishery products) are used in the CP, the competent authority of the exporting foreign country must provide a certificate attesting to the statements as written on the CP certificate.
• If foreign animal ingredients are used, the Imported ingredients section of the Manufacturer's Certificate must be completed.

Particular requirements of certain composite products

Canadian or imported ingredients of animal origin used in the manufacture of a CP that requires an export certificate must meet the requirements as described on the model health certificate of the EU for CPs. To this end, it is important to refer to the health information in the Annex I of the Regulation (EU) No 28/2012 of the Commission as well as to the Decision 2007/275 of the Commission which provide important details on the following:

• The percentage (more than 50% or less than 50%) of certain ingredients of animal origin contained in the CP
• The storage temperature of the CP
• The applicable heat treatments to the ingredients of animal origin
• The origin of the ingredient of animal origin (approved country and, if applicable, an establishment listed on the EU list
• The list of certain composite products to be subject to veterinary checks at BCP of the EU
• Others

Composite products in transit by the EU

CPs for which the final destination is a third country and that transit through the EU or stored in its territory, must come from a country authorized to export to the EU and be accompanied by the transit export certificate of the EU.

Export documents available upon request

The certificate models are not available in all the languages of the member states of the Union. The CFIA may add other certificate models in additional languages of the Union as required. A reasonable delay is to be expected. However, a member state could accept a certificate which is not issued in its official language. It is the responsibility of the exporter to ensure that the certificate issued meets the requirements of the border control post (BCP)/member state of destination in terms of official language.

Certificate

• Model health certificate for import into the European Union of composite products intended for human consumption CFIA/ACIA 5819.
• Model health certificate for transit through or storage in the European Union of composite products intended for human consumption CFIA/ACIA 5820.

Additional information

Samples (personal or commercial) of composite products may be subject to the same requirements as regular shipment. It is strongly recommended that the exporter verify these requirements with his importer and / or at the EU border inspection post where the products will be shipped.

• Link to the list of the Member countries of the European Union (EU). Please note that the EU has international agreements with some countries (example Switzerland, Norway, Iceland and Liechtenstein), which means that they implement EU veterinary legislation with regard to movement of animal products.
• Link to the list of the EU Veterinary border control - (English only).
• Link to the EU models of health certificates for import and transit of CPs, see Commission Regulation (EU) No 28/2012.
• Link to the list of the composite products that are subject to checks at BCP, see Commission Decision 2007/275/EC.
• Link to the list of third countries or part thereof authorised for the introduction into the EU of consignments of raw milk and dairy products and indicating the type of heat treatment required for such commodities, see Commission Regulation (EU) No 605/2010.
• Link to the relevant microbiological criteria for foodstuffs, see Commission Regulation (EC) No 2073/2005 of November 2005 with amendments.
• Link to the list of third countries, territories, zones or compartments from which poultry and poultry products may be imported into and transit through the Community as well as the rules on veterinary certification, see Commission Regulation (EC) No 798/2008.