Consumers, Health And Food Executive Agency

Better Training for Safer FoodInitiative

Terespol, 1-3 July 2014

Simon Rowell

Composite ProductsImport RequirementsThis action/ training/ seminar is carried out by JVL

Consulting under the contract no 2012.96.02 with the Consumers, Health and Food Executive Agency (former

Executive Agency for Health and Consumers).

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• IS IT A COMPOSITE PRODUCT?

• IS IT SUBJECT TO VETERINARY CHECKS?

• WHAT ARE THE IMPORT CONDITIONS?

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Import Conditions - General principles

Processed POAO content: Must meet the EU animal and public health requirements that apply to processed POAOs

and

Finished composite product: Must meet EU animal and public health requirements

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Processed POAO content: Animal Health requirements

Processed animal product content must come from an approved third country (Council Directive 2002/99/EC)

– Dairy product content must have undergone the relevant treatment (e.g. pasteurisation, sterilisation) for country of origin of the dairy product. (Regulation (EU) No 605/2010)

– Meat product content must have undergone required treatment for country of origin of the meat product. (Commission Decision 2007/777/EC)

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Commission Decision 2007/777 /EC - Meat products 3rd country & treatment list

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Processed POAO content: Public Health requirements

The processed animal product content of a composite product: 1.Must come from an approved third country

(Reg. (EC) No 852/2004)

2.Must come from an approved establishment (Reg. (EC) No 853/2004)

3.Must come from a country with an approved residue control plan for the product concerned

(Dir.96/23/EC). (List is in Decision 2011/163/EU as amended)

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The Finished composite product

Must meet EU general food hygiene provisions (same as for any food)

• The composite product can be made in a registered establishment – i.e. it does not have to be made in an EU-approved establishment

• The composite product does not need to be marked with an ID mark

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Harmonised composite productsas listed in Regulation (EU) No 28/2012

(a) composite products containing processed meat products, as referred to in Article 4(a) of Decision 2007/275/EC;

(b) composite products containing processed milk products and covered by Article 4(b) and (c) of Decision 2007/275/EC;

(c) composite products containing half or more of their substance of processed fishery or egg products and covered by Article 4(b) of Decision 2007/275/EC.

• Third country where the final composite product was made must be on the relevant third country list(s) for the POAO content(s) that has to be certified (art. 3.1)

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• Must have the health certificate laid down in Regulation (EU) No 28/2012 (article 3.2)

Harmonised composite productsas listed in Regulation (EU) No 28/2012

• Must meet the requirements of the health certificate (article 3.2)

The certificate covers the animal and public health requirements for relevant meat product, dairy, fish, egg content components which have to be certified

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Requirements laid down in certificate

• Meat product content + Dairy product content

• Must come from: - Same country as the composite product, or

- EU, or

- Another third country with similar high health status

•

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Similar high health status means:• Meat product content:• Meat products can only go from one Treatment A

country to another Treatment A country (treatment applicable to the species concerned)

[ref: Commission Decision 2007/777/EC]

• Dairy product content:• Dairy products can only move from one Column A

country to another Column A country or one Column B country to another Column B country

• Dairy products cannot move from a Column C country to other countries

[ref: Regulation (EU) No 605/2010]

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• Place of origin of the composite product must be in the same country where the composite product was produced. (Note to box I.10)

•Country where composite product was produced must be on the relevant third country list for the POAO content(s) which has to be certified (Note to box I.7 reflecting article 3.1)

Requirements laid down in certificate

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What POAO content has to be certified?

• Any meat product content

• Dairy content where: • Dairy product content is 50%+ • Not shelf stable – Any %

• Fishery product content if 50%+

• Egg product content if 50%+

(‘Cooked’ = heat-treated sufficiently to denature any raw animal product)

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I am aware of Regulations (EC) No 178/2002, (EC) No 852/2004and (EC) No 853/2004 …… and that the composite products were produced in accordance with the above legislation

Health certificate- Compliance with food hygiene package

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Meat products certification

•Products meet animal health requirements of CD 2007/777/EC

•Country of origin

•Establishment of origin

•Various BSE attestations

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Dairy products certification

• Country of origin

• Establishment of origin

•Animals under control of veterinary services and from inspected holdings not under restrictions

•Milk from cows, ewes, goats buffaloes – pasteurised, sterilised, UHT etc•Milk from other animals – sterilised or UHT only

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Egg products certification

•Approved country•HPAI and ND free or heat treated

Note: In the case of composite products where only the fishery and/or egg sections have to be certified, the certificate can be signed by an official inspector rather than an official veterinarian

Fishery products certification

•Approved country•Approved establishment

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Example certificate for composite product from Vietnam containing processed fishery product and no other animal product

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• AH conditions = EU (or national rules if no EU rules)

• PH conditions = EU general food hygiene rules + any specific national rules.

• Transitional measures until 31/12/2016 (Reg (EU) No 1079/2013)

Non-harmonised composite productsRegulation (EU) No 28/2012 article 3.3

e.g. containing honey / gelatine / snails etc.

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Be Logical!• 1st: Is it a composite product?

• Only then decide:

• 2nd: Is it subject to vet checks?

• Only then decide:

• 3rd: What are the import conditions?

Consumers, Health And Food Executive Agency

Thanks for listening!

Consumers, Health And Food Executive Agency

Better Training for Safer Food

BTSF

JVL Consulting s.a.Rue Jean Matagne 15B-5020 VedrinBelgium

AESA Consortium

This action/ training/ seminar is carried out by JVL Consulting under the contract no 2012.96.02 with the Consumers, Health and Food Executive Agency (former Executive Agency for Health and Consumers).

• European CommissionConsumers, Health and Food Executive Agency

DRB A3/042L-2920 Luxembourg