Better Training for Safer Food Initiative

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Better Training for Safer FoodInitiative

• Composite Products
• Import Requirements

• Simon Rowell

• 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).

Terespol, 1-3 July 2014
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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
• Must come from an approved third country
  (Reg. (EC) No 852/2004)
• Must come from an approved establishment
  (Reg. (EC) No 853/2004)
• 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 products as listed in
Regulation (EU) No 28/2012

• composite products containing processed meat
  products, as referred to in Article 4(a) of
  Decision 2007/275/EC
• 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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Harmonised composite products as listed in
Regulation (EU) No 28/2012

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

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

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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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Requirements laid down in certificate

• 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)

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

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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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Health certificate - Compliance with food hygiene
package
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
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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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• Fishery products certification
• Approved country
• Approved establishment

• 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
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Example certificate for composite product from
Vietnam containing processed fishery product and
no other animal product
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Non-harmonised composite products Regulation
(EU) No 28/2012 article 3.3
e.g. containing honey / gelatine / snails etc.

• 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)

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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?

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Thanks for listening!
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• 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).

• JVL Consulting s.a.
• Rue Jean Matagne 15
• B-5020 Vedrin
• Belgium
• AESA Consortium

• European CommissionConsumers, Health and Food
  Executive AgencyDRB A3/042L-2920 Luxembourg