Export or move composite food products after 1 January 2021

Guide

Last updated 2 July 2021

This guidance applies to businesses in Great Britain (England, Scotland and Wales) that export or move composite food products:

  • from Great Britain to the EU
  • from Great Britain to Northern Ireland
  • through the EU and Northern Ireland (known as transiting)

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

The following products are not composite products:

  • food made from unprocessed POAO, such as fresh chicken
  • plant-based food products with no POAO content
  • food not intended for human consumption
  • food with small amounts of plant products, such as oil or herbs added for processing or extra flavour (for example, cheeses with added herbs, sausages with garlic, yogurts with added fruit)

You need to follow different rules to move or export:

You should follow other export rules that may apply - for example, tariffs and customs declarations or for moving goods from Great Britain to Northern Ireland.

Check what documents you need to export or move composite food products to the EU and Northern Ireland

You must have a composite export health certificate (EHC) to export or move composite food products that either:

  • contain processed meat
  • need to be transported and stored chilled or frozen

You do not need a composite EHC if the only processed meat in the product is gelatine, collagen or highly refined products such as chondroitin, glucosamine or rennet.

If a product is not a composite food product but contains several types of animal product, you must have an EHC for each type of animal product your product contains.

EHCs you can use
You can use certificate number:

  • 8350 to export or move your composite food product to the EU and Northern Ireland
  • 8351 to transit through, or store your composite food product in the EU or Northern Ireland

You must use these EHCs if your product did not require an EHC before 21 April 2021.

If you used the following certificates to export your products before 21 April 2021, you can continue to use them until August 2021:

Private attestations
Your EU or Northern Ireland importer or agent must complete a private attestation for composite food products if both of the following apply:

  • the products are shelf-stable (not chilled or frozen)
  • the products do not contain processed meat

You need to give your EU or Northern Ireland import agent information about the products you’re exporting so they can complete and sign the attestation. A certifying officer does not need to sign the attestation.

Documents for products containing honey, gelatine or snails
Composite food products that contain honey, gelatine or snails as well as other processed POAO must have either of the following documents:

  • a composite EHC - if the product also contains meat, or is frozen or chilled
  • a private attestation - if the product also contains dairy, fish or egg and is shelf stable

In these cases, you do not need an EHC for the honey, gelatine or snails component of your product.

Composite food products where honey, gelatine or snails is the only processed POAO must have either of the following documents:

  • an EHC for the honey, gelatine or snails - if the product is frozen or chilled
  • a private attestation - if the product is shelf stable

Catch certificates for composite food products containing fish and fishery products
You may need a UK catch certificate and processing statement or storage document if your composite food product:

  • contains 20% or more marine-caught fish or fishery products caught in Great Britain
  • will be exported using tariff codes 1604 or 1605

Freshwater fish and aquaculture are exempt and do not need a catch certificate - check the list of exempt species.

Movement Assistance Scheme
If you’re moving food or drink that contains animal products to Northern Ireland, you do not need to pay for them to be inspected and certified. The certifier invoices the government for these costs as part of the Movement Assistance Scheme.

Prohibited and restricted composite products

You cannot use a composite EHC to export composite food products containing unpasteurised dairy products(for example, a ready meal topped with parmesan cheese) to the EU and Northern Ireland.

To export these products, the composite food product must be cooked (or treated in a way that’s equivalent to pasteurisation) after the unpasteurised dairy product has been added (for example, a ready meal with parmesan cheese that’s been cooked after the cheese was added).

Residue plans
Some countries must have residue plans for certain products they export (for example, meat, dairy, eggs, fish and honey). You should check if there’s a residue plan for the components in the product you’re processing, if you’ve imported them from another country. You cannot export or move your product to the EU and Northern Ireland if the country you’re importing from does not have a residue plan.

Checks at EU border control posts or point(s) of entry in Northern Ireland

Your composite food product will be checked at an EU border control post (BCP) or point of entry in Northern Ireland, unless your product is exempt.

These checks are made to protect:

  • animal health and welfare
  • public health

Your products may be refused entry, seized, destroyed or returned to Great Britain if they arrive at a:

  • port in the EU without a BCP where checks cannot be carried out
  • BCP that cannot check your type of product
  • BCP without the correct documentation

Find the correct BCP for your products
You must find a BCP that accepts your type of products as not all BCPs accept all products.

If a BCP does not accept your product, you may need to redirect your trade route.

There are more than 400 BCPs in the EU and they’re usually at EU ports and airports.

Give advance notice to EU BCPs or point(s) of entry in Northern Ireland
You’ll need to give EU BCPs or points of entry in Northern Ireland advance notice of products arriving. Check how much notice is needed with the BCP or point of entry you’re planning to use.

Contact your import agent in the EU or Northern Ireland to make sure they notify the BCP through the trade control and expert system (TRACES) of the arrival of the consignment.

They must do this within the time limits set out by the BCP or point of entry.

What happens if your composite food products are rejected at a BCP

If your composite food products are rejected at a BCP because they pose a risk to animal or public health, they will be destroyed immediately. If the products are rejected for other reasons, the BCP will:

  • notify your importer or agent
  • ask your importer or agent to decide whether your products should be destroyed or returned to Great Britain The BCP will not usually contact you directly.

Return rejected products from until 31 December 2021
Until 31 December 2021 you must email APHA Centre for International Trade (CIT) at imports@apha.gov.uk to return a consignment.

You should state that the message relates to the return of a consignment.

Attach these documents to the email:

  • a declaration from the EU BCP describing the reason why the products were rejected
  • a declaration from the person responsible for the consignment that gives full details of the destination in Great Britain and confirms how the returned consignment will be used, or if it will be destroyed
  • the original export certificate for the returned product

If the consignment does not have a veterinary certificate or EHC you must have a commercial invoice or similar document that verifies the returned consignment is the same one that was exported.

If the consignment was not originally exported in a sealed container or the seal is broken for official control purposes, you must have an official declaration from the EU BCP stating the:

  • place and date of unloading and reloading of the consignment
  • consignment did not undergo any handling other than unloading, storage and reloading
  • products were handled only to the extent necessary for the purposes of official controls at the appropriate temperature
  • unloading and reloading of the consignment was handled hygienically to avoid cross-contamination
  • consignment was stored under hygienic conditions at the required temperature and not at risk of cross contamination
  • products were protected from contamination with disease agents which cause transmissible animal diseases during the unloading, storage and re-loading in the EU country
  • place of any unloading, storage and re-loading in the EU country was not subject to animal health movement restrictions due to transmissible animal diseases during the unloading, storage and re-loading

If the rejected products were originally exported in a sealed container and maintained an intact original seal, you must have a declaration by the person responsible for the consignment stating:

  • since the product was originally exported, the storage and transport conditions have been complied with
  • that the content of the consignment has not been altered

APHA will assess this information to decide the conditions of import and if the consignment can be returned through any point of entry or if it needs to enter through a BCP.

APHA will issue you with a written authorisation. The consignment cannot be returned until you have received this authorisation. You must comply with the conditions of the authorisation.

The imports@apha.gov.uk email address is monitored Monday to Friday, 8:30am to 5pm (excluding public holidays).

Return rejected products from 1 January 2022
Rejected composite food products returning to Great Britain must enter through a UK BCP for checks on entry from 1 January 2022.

You must notify on IPAFFS and present the relevant documentation to the BCP as set out in the returned goods processes for animal products and live animals.

Composite food products exempt from border controls

Your composite food product is exempt from controls if it:

  • is shelf-stable
  • does not contain any processed meat
  • can be identified as a product intended for human consumption
  • is securely packaged and sealed
  • meets EU production or processing requirements, including relevant heat or sterilisation treatment for products containing dairy or egg

It must also be one of the following products:

  • confectionery (including sweets), chocolate and other food preparations containing cocoa
  • pasta, noodles and couscous
  • bread, cakes, biscuits, waffles and wafers, rusks, toasted bread and similar toasted products
  • olives stuffed with fish
  • extracts, essences and concentrates, of coffee, tea or maté and preparations with a basis of these products or with a basis of coffee, tea or maté
  • roasted chicory and other roasted coffee substitutes, including extracts, essences and concentrates of these
  • soup stocks and flavourings packaged for the final consumer
  • food supplements packaged for the final consumer, containing processed animal products (including glucosamine, chondroitin or chitosan)
  • liqueurs and cordials

To export or move your exempt product, you:

  • need a private attestation instead of a composite EHC
  • can send your products through any EU or Northern Ireland point of entry

Contact the EU BCP or Northern Ireland point of entry 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.

Arrangements for authorised traders moving food from Great Britain to Northern Ireland

An arrangement is in place which allows authorised traders to move some products without the need for official certification, such as EHCs, phytosanitary certificates or marketing standards certificates until 1 October 2021.

Authorised traders are supermarkets and their trusted suppliers. The UK government will not discriminate against smaller suppliers or between different companies in recognising traders as authorised for the purpose of this arrangement.

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 Northern Ireland.

Trusted suppliers
A trusted supplier is any business that independently moves its products from Great Britain to Northern Ireland, for sale in Northern Ireland. For example, a meat pie supplier that moves its own products from Great Britain to Northern Ireland, which delivers directly to a store for sale within Northern Ireland only, would be eligible for authorised trader status.

However, if a meat pie supplier delivers products to a supermarket distribution centre in Great Britain, that are then moved by the supermarket to Northern Ireland, then the producer would not qualify. In this instance, the supermarket would be the authorised trader for that movement into Northern Ireland.


First published 4 February 2020