What is a composite product?
Composite products are foods intended for human consumption that contain both products of plant origin and processed products of animal origin.
For example:
- A ham sandwich
- Pepperoni pizza
- Beef lasagne
- Prawn spring roll (where the prawn is cooked)
- Spinach and ham quiche
- Biscuits with egg and butter
What is not a composite product?
A product may only be considered a composite product if the addition of a product of plant origin to a processed animal product is not necessary to manufacture the product. For example, if the plant material is present for technical reasons or is present to add special characteristics such as flavour or thickening.
Examples foods which are not considered to be composite products include:
- Canned tuna in vegetable oil
- Cheeses to which herbs are added
- Yogurts to which fruit is added
- Chicken nuggets (batter or breading adds specific characteristics)
A product is not considered to be a composite product if it contains any unprocessed products of animal origin mixed with products of plant origin, or if it is not intended for human consumption, e.g., Skewers of meat and vegetables, petfood.
Importing Composite Products
The requirements for importing composite products into the EU are based on the risks to public health posed by the composite product. Commission Delegated Regulation (EU) 2022/2292 establishes three categories of composite products, based on risk:
- Non-shelf stable composite products
- Composite products that contain any quantity of colostrum-based products or meat products, except gelatine, collagen and highly refined products
- Shelf stable composite products that do not contain colostrum-based products or meat products, except gelatine, collagen and highly refined products.
Composite products in category 1 and 2 (higher risk categories) must be accompanied by a health certificate, drawn up in accordance with model COMP in Chapter 50 of Delegated Regulation (EU) 2020/2235.
While composite products in category 3 (lower risk category) do not require a health certificate, they must be accompanied by a private attestation, drawn up in accordance with the model private attestation in Annex V of Commission Regulation (EU) 2020/2235.
The private attestation is to be completed by the importer or a representative of the importer.
Composite Products subject to Official Controls at Border Control Posts
Certain consignments of composite products are subject to official controls at the Border Control Post (BCP) and are listed by their CN code in Delegated Regulation (EU) 2022/2292 and on the DAFM website.
Import control requirements:
The operator responsible for consignments of composite products which do not meet the requirements for exemption (detailed below), must:
- Register with the Department of Agriculture and on TRACES-NT. Guidance available at: Register to import.
- Provide 24 hours prior notification of the arrival of the consignment to the Border Control Post through submission of part-I of a CHED-P on TRACES NT.
- Submit relevant documents to the Imports (INIS) Portal.
Composite Products exempt from Official Controls at the Border Control Post
A small number of very low-risk composite products are exempted from official controls at the Border Control Post. Further information on these exempted composite products is available in Delegated Regulation (EU) 2021/630, as amended.
The exempted products must be accompanied by a private attestation to the place of destination, the point of release for free circulation in the Union, or the warehouses/premises of the operator responsible for the consignment. The private attestation does not need to travel with the consignment and does not need to be submitted on the DAFM imports portal (INIS) or TRACES. A CHED-P does not need to be created on TRACES.
Please see the Department of Agriculture, Food and the Marine (DAFM) website for more detailed information on the requirements for importing composite food products.