1. What counts as a composite product if exporting to the EU?
Composite food products are for human consumption only. They contain a mix of processed products of animal origin (POAO) and plant products used as a
Am I allowed to use unprocessed products of animal origin to manufacture a composite product?
You are allowed to start the manufacture of a composite product from an unprocessed product of animal origin as long as the processing of the
Are confectionery products composite products?
Not necessarily. Only those confectionery products that contain both products of vegetable origin and processed products of animal origin are composite products
How are a mix powders of cow’s milk with a small amount of egg’s white powders perceived? Is it dairy or composite product?
Composite food products are for human consumption only. They contain a mix of processed products of animal origin (POAO) and plant products used as a
How can I differentiate processed products of animal origin with vegetable content from composite products containing processed products of animal origin?
The addition of a plant product to a processed animal product does notautomatically mean that the final food is a composite product. As long as
I am adding a plant compound to a processed animal product. Is the final product always considered as a composite product?
The addition of a product of plant origin during the processing of an animal product does notautomatically mean that the final product is a composite.
I export composite products, do the transitional arrangements for new EHCs on April 21 2021 apply to me?
Yes. If you currently export a composite product that requires an EHC you will be able to continue to use the current EHC until August
I mix an unprocessed product of animal origin and technological ingredients derived from a processed product of animal origin (e.g. albumin binder), do I make a composite product?
No. The final product is not a composite product for two reasons: 1) it does not contain any product of plant origin and 2) it
I want to export a non shelf-stable composite product that contains gelatine (or collagen or highly refined product) and other meat products. Which certificate is required?
Non-shelf-stable composite products must be accompanied by an EHC.
I want to export to the EU a shelf-stable composite product that contains gelatine. What needs to accompany the product?
Shelf-stable composite products that contain meat products must be accompanied by an EHC. However, in the case where the shelf-stable composite product contains no meat
If I mix unprocessed products of animal origin and products of plant origin, do I make a composite product?
No. This is not a composite product as it contains an unprocessed product of animal origin
In the case of non shelf-stable products containing fresh meat (or meat preparations) but not processed animal products, how should such products be certified?
A product containing fresh meat is not a composite product. The certificate for composite products is therefore not to be used in such cases. An
Is it required to only include processed products of plant origin in a composite product?
No. A composite product contains both products of plant origin and processed products of animal origin, but there is no requirement to use only processed
My composite product is shelf-stable, and does not contain meat, but the dairy elements do not meet the heat treatment requirements for the private attestation (e.g. chocolate that contains pasteurised milk). What do I do?
Shelf-stable composite products containing no meat require the private attestation under the EU rules introduced from April 2021. This attestation requires the dairy and egg
My composite products contain honey, gelatine, collagen, snails or highly refined products. What do I do?
If the only processed products of animal origin in a composite product are honey, collagen, gelatine or snails, and the composite produce is shelf stable,
The composite product I manufacture contains very small amounts of processed products of animal origin, essentially present for technological reasons. Does it have to fulfil all of the relevant requirements for composite products?
Yes. The percentage of ingredients of animal origin in the composite product is irrelevant when determining which rules apply to a composite product
What are private attestations?
The private attestation is laid down in EU law. It must be prepared and signed by the importing food business operator (FBO) in the EU.
What are the border control checks for composite products?
Unless specifically exempt from border checks, all consignments of composite products exported to the EU will be subject to veterinary checks at an EU Border
What are the foods listed in the legislation as exempt from certification and exempt from BCP checks?
These foods include: Confectionery (including sweets), chocolate and other food preparations containing cocoa Pasta, noodles and couscous Bread, cakes, biscuits, waffles and wafers, rusks, toasted
What are the requirements to export products that contain 50% or more of an animal product to the EU?
If a product contains 50% or more of an animal product*, it may be a composite product. Please find further information on exporting composite products
What are the rules for exporting composite products
There are different decision trees developed by the Irish government for composite products containing meat and POAO, milk and dairy, fish and eggs which may
What are the rules for exporting composite products to the EU?
Guidance for what constitutes a composite product and how to export these, to the EU can be found here. *Important Note: Many new EU Export
What checks will be needed on chocolate/biscuits/pasta etc?
Provided that these are shelf stable and do not include meat products (other than gelatine, collagen or highly refined products) these require a private attestation
What is the difference between non shelf stable and shelf stable composite products and what is controlled temperature?
Shelf stable animal composite products are products that do not need to be transported or stored under controlled temperatures e.g. chilled or frozen. Controlled temperature
Which composite products need an EHC?
Shelf stable and non-shelf stable composite products for human consumption containing processed meats need an EHC (gelatine, collagen and highly refined products are not included