Export or move composite food products after 1 January 2021

Guide

Last updated 4 March 2021

This guidance applies to businesses in Great Britain (England, Scotland and Wales) exporting or moving composite food products to, or through:

  • the EU
  • non-EU countries
  • Northern Ireland (NI)

In most cases, you need an export health certificate (EHC) to export or move composite food products. However, there are some composite food products you cannot export or move.

Follow the rules in this guidance to find out what you need to do.

You need to follow different rules to move or export:

What a composite food product is

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

What is not a composite food product

These products are not composite foods:

  • food made from unprocessed POAO, such as fresh chicken
  • plant-based food products with no POAO content
  • food not intended for human consumption

In addition, food with small amounts of plant products, such as oil or herbs, are not composite products. This is because the oil or herbs are only added for processing purposes or to give extra flavour.

Some examples are:

  • cheeses with added herbs
  • sausages with garlic
  • yogurts with added fruit

These foods would be classed as dairy, meat or plant products. You should use the following guidance to export:

If a product does not meet the composite product definition but contains several types of animal product, you’ll need an export health certificate (EHC) for each type of animal product your product contains.

Export or move composite food products from GB to the EU or NI

You need an export health certificate (EHC) to:

  • export composite food products from GB to the EU
  • move them from GB to NI
  • transit through the EU and NI

If you're moving food or drink that contains animal products to NI, 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.

You'll also need to:

Checks at EU Border Control Posts (BCPs) or point(s) of entry in NI
You must get your composite food products checked at an EU BCP or point of entry in NI, unless your product is exempt.

These checks are made to protect:

  • animal health and welfare
  • public health

Your goods may be refused entry, seized, destroyed or returned to GB if they arrive at:

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

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

You'll need to consider how to redirect your trade route if needed.

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

The most frequently used are:

You can check the full list of EU BCPs.

Give advance notice to EU BCPs or point(s) of entry in NI
You'll need to give EU BCPs or points of entry in NI advance notice of goods arriving.

Check with the BCP or point of entry you're planning to use for how much notice is needed.

Contact your import agent in the EU or NI to make sure they notify the BCP through TRACES of the arrival of the consignment.

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

Composite foods exempt from inspection at an EU border control post (BCP) or NI point of entry

Some composite products do not need EHCs or inspection at an EU BCP or NI point of entry.

This exemption applies if all of the following apply:

  • made without processed meat, or meat extracts or powders
  • made with less than 50 per cent of any other processed POAO (any dairy must come from an approved country and have undergone the correct heat treatment for that country)
  • labelled for human consumption
  • shelf-stable at ambient temperature or have clearly undergone a complete cooking or heat-treatment process throughout, during manufacture, so that any raw product is denatured
  • securely packaged or sealed in clean containers

Or if the composite is one of these products:

  • confectionery (including sweets) and chocolate, heat-treated and containing less than 50 per cent of processed dairy and egg products
  • pasta and noodles not mixed or filled with processed meat product, heat-treated and containing less than 50 per cent of processed dairy and egg products
  • bread, cakes, biscuits, waffles and wafers, rusks, toasted bread and similar toasted products, heat-treated and containing less than 20 per cent of processed dairy and egg products
  • olives stuffed with fish
  • soup stocks and flavourings packaged for the final consumer, heat-treated and containing less than 50 per cent of fish oils, fish powders or fish extracts
  • food supplements packaged for the final consumer, containing small amounts (in total less than 20 per cent) of processed animal products (including glucosamine, chondroitin and/or chitosan) other than meat products

Heat treated means the product either:

  • is shelf-stable at ambient temperature
  • has undergone complete cooking or heat-treatment during manufacture so that any raw product is denatured

How to export or move these exempt products
To export or move exempt products you:

You need to give the following information, either on the product labelling, or in the commercial documents sent with the products, or both:

  • the nature, quantity and number of packages of the composite products
  • the country of origin
  • manufacturer details
  • list of ingredients

Contact the point of entry in the EU 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.

Restricted and prohibited goods

EU rules mean you will not be able to export the following goods to the EU:

  • chilled minced meat (red meat)
  • chilled meat preparations (for example, raw sausages)
  • minced meat (poultry)
  • poultry and ratite/game bird mechanically separated meat
  • raw milk from TB herds
  • ungraded eggs
  • composite products containing dairy products made from unpasteurised milk (for example, a ready meal topped with unpasteurised cheese)

You will not be able to re-export certain animal and animal products including:

  • fresh meat originally from the EU or non-EU countries
  • milk not from the UK
  • products using products of animal origin from non-EU countries that are not listed by the EU for the purpose of imports into the EU

Movements from GB to NI
You can move the following 'restricted and prohibited' meat products from GB to NI:

  • frozen or chilled minced meat of poultry, ratites and wild game birds
  • chilled minced meat from animals other than poultry
  • chilled meat preparations
  • any unprocessed meat produced from meat initially imported into GB from the EU

This will be in place for six months. The government will continue to explore permanent reciprocal arrangements.

You must also make sure the meat products:

  • enter NI through a designated point of entry, and follow the channelling procedure applicable from the designated point of entry through to the destination supermarket in Northern Ireland, as directed by the point of entry authority
  • are sold exclusively to end consumers in supermarkets located in NI, and they're not sold to other operators of the food chain
  • are accompanied by official certificates issued by the UK competent authorities (based on similar models already existing for fresh meat, minced meat and meat preparations)
  • are packed for end consumers and have a label reading "These products from the United Kingdom may not be sold outside Northern Ireland"

What happens if your goods fail inspection at a BCP

If your goods fail inspection because of risks to animal or public health, they will be destroyed immediately. If the goods fail for other reasons, the BCP will:

  • notify your importer or agent
  • ask them to decide whether your goods should be destroyed or returned to GB

The BCP will not usually contact you directly.

Rejected goods from 1 January to 30 June 2021
From 1 January to 30 June 2021, consignments of composite food products rejected at EU BCPs may, subject to a risk assessment, re-enter GB through any point of entry.

Consignments rejected for commercial reasons cannot be returned as rejected goods.

There are certain documentary requirements to return rejected goods to GB from the EU. The Animal and Plant Health Agency (APHA) will notify you if the returned consignment needs to enter through a BCP or can enter through any point of entry.

Document requirements for rejected composite products from 1 January
Email APHA Centre for International Trade (CIT) at imports@apha.gov.uk to return a consignment. In the title of the email state clearly 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 for refusal of entry
  • full details of destination in GB and the intended use or destruction of the returned consignment from the person responsible for the consignment
  • the original export certificate for the returned product

If the consignment did not require a veterinary certificate or did not have a certificate for export you must present a commercial invoice or similar that verifies the returned consignment corresponds with the one that was exported

If the consignment was not originally exported in a sealed container or where 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
  • effective measures were put in place to avoid the contamination of the POAO 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 good was 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 will have 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).

Returned goods procedure for composite food products rejected from an EU BCP from 1 July 2021
Returned goods must enter GB at an appropriately designated BCP for checks on entry from 1 July 2021.

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.

EU standards for composite products

To export or move composite goods from GB to the EU or NI, they must meet EU standards.

Products with processed meat or more than 50 per cent milk, dairy, egg or fishery products
The unprocessed meat, milk, dairy, egg or fish component in your product must come from:

  • a third country approved by the EU
  • an EU-approved establishment in that third country (this does not apply to wild-caught fish)

The third country must have a residue plan for the component you're processing.

The food component must also have undergone heat treatment to meet EU rules. To find out more about these rules, check the details on your EHC or speak with your official vet.

Your composite product can be assembled at a registered establishment rather than an EU-approved establishment.

To export some GB-caught fish and fishery products in composite products, you may need a catch certificate and processing statement or storage document.

This applies if you're exporting a composite product using tariff codes 1604 and 1605 where the fish makes up more than 20 per cent of the content. Exempt species include freshwater fish and aquaculture - check the list of exempt species.

Products made with processed POAO, such as honey, gelatine or snails
To export or move these composite goods from GB to the EU or NI:

  • the POAO must come from an approved third country
  • this approved third country must have a residue plan for the component you're processing

The composite goods do not need to be:

  • processed in an approved establishment
  • heat-treated in line with EU rules

If half or more of the content of a composite product is made up of honey, gelatine or snails, you may need to get two types of EHC to send with your consignment. You'll need:

If a composite product requires a composite product certificate and less than half of its content is honey, gelatine or snails it may not need an additional health certificate for the honey, gelatine or snail component.

Individual EU BCPs or NI points of entry may apply different rules on this. You, the EU importer or NI trader, should check the requirements with the BCP or NI point of entry to reduce the risk of your products being delayed or rejected.

Export composite food products to non-EU countries

You'll usually need to complete an export health certificate (EHC) and some supporting documents to export composite food products.

Check the export health certificate (EHC) finder to see if a certificate exists for your animal or product.

If you find an EHC, follow the EHC process to export.

If you cannot find an EHC for your product, you'll need to contact the competent authority in the EU country you're exporting to, in advance, to find out what:

  • paperwork you'll need to fill in
  • rules you need to comply with

If the competent authority says that you need an EHC, you'll need to get their import conditions. Email the conditions to APHA at exports@apha.gov.uk who'll arrange an EHC for you.

Exporting composite products from NI to the EU

There are no new requirements for exports of composite products from NI to the EU.

Arrangements for authorised traders moving food from GB to NI

An arrangement is in place which allows authorised traders such as supermarkets and their trusted suppliers to move some goods without the need for official certification until 1 October 2021.

If you're moving composite products from GB to NI, you do not need official certification, such as export health certificates, phytosanitary certificates or marketing standards certification.

The government will not discriminate against smaller suppliers or between different companies in implementing these practical measures.

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 NI, 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 NI 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 channeling procedure applicable from the designated point of entry to the destination supermarket in NI.

Authorised traders

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.

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

However, a meat pie supplier that delivers products to a supermarket distribution centre in GB, which is then moved by the supermarket to NI, 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