1. Better Training for Safer Food BTSF
Composite Products
Simon rowell
MOVEMENT AND IMPORT CONTROLS OF FEED,
FOOD AND ANIMALS
Control checks at border inspection posts
Session 7 – 8th to 11th April 2014

2. Be Logical! 1st: Is it a composite product?
Only then decide:
2nd: Is it subject to vet checks?
3rd: What are the import conditions?
When thinking about composite products be very logical! X X X X X

3. Is it a composite product?
Is it subject to veterinary checks?
What are the import conditions?
First you need to decide whether the food is a composite product

4. Definitions Composite product:
A foodstuff intended for human consumption that contains both processed products of animal origin and products of plant origin and includes those where the processing of primary product is an integral part of the production of the final product
Commission Decision 2007/275 article 2
Food only
If any raw animal material is present it cannot be a composite product
The term composite product is defined in Commission Decision 2007/275 as a foodstuff intended for human consumption that contains both processed products of animal origin combined with plant material and includes those where the processing of the animal product takes place during the production of the final composite product.
Note that the term ‘composite product’ applies only to food. It does not apply to feed or animal by-products
So, a composite product contains both processed animal product and plant material. This means that by definition if there is any raw animal material in the foodstuff, the foodstuff cannot be a composite product.

5. Definitions Processed product:
Foodstuff resulting from the processing of unprocessed products.
These products may contain ingredients that are necessary for their manufacture or to give them specific characteristics.
Regulation (EC) No 852/2004 Article 2 point (o)
Processing:
Any action that substantially alters the initial product, including heating, smoking, curing, maturing, drying or a combination of those processes.
Regulation (EC) No 852/2004 Article 2 point (m)
Processed products and processing are defined in Regulation (EC) No 852/2004
Processed product (see slide)
(X) Processing
(X) There are also specific definitions of meat products, dairy products, egg products and processed fishery products in Regulation (EC) No 853/2004
Specific definitions of meat products, dairy products, egg products, processed fishery products, etc. are in Regulation (EC) No 853/2004 Annex I point 7

6. Commission Guidance
Guidance on what is a processed product and what is a composite product can be found in the guidance to Regulation (EC) No 853/2004 issued by the Commission at the web address shown

7. Not a composite product.
Composite product: “A foodstuff intended for human consumption that contains both processed products of animal origin and products of plant origin and includes those where the processing of primary product is an integral part of the production of the final product”
So let’s look at some examples of what are composite products and what are not.
On the left you can see a foodstuff which is not a composite product. This is because the honey is raw so it does not meet the definition of being a processed animal product whereas the example on the right is a composite product because the honey has been processed as the final product has been cooked.
Not a composite product.
Raw honey has been mixed with nuts but the honey has not been processed
Composite product.
Raw honey has been added to mustard & soya bean oil and cooked

8. Composite product: “A foodstuff intended for human consumption that contains both processed products of animal origin and products of plant origin and includes those where the processing of primary product is an integral part of the production of the final product”
Here are further examples of composite products:
Pizza made with previously cooked meat
Sandwich made with processed meat and cheese - which is a processed dairy product
Beef lasagne made with previously cooked meat
Composite products

9. Composite product: “A foodstuff intended for human consumption that contains both processed products of animal origin and products of plant origin and includes those where the processing of primary product is an integral part of the production of the final product”
Prawn spring roll.
If prawns cooked – a composite product
A prawns raw – a fishery product
Here you can see a composite product where the final product contains processed fishery product because the prawns have been cooked.
If it contained raw prawns it would not be a composite product as the definition of a composite product is a foodstuff that contains processed products of animal origin (combined with plant material)

10. Composite product: “A foodstuff intended for human consumption that contains both processed products of animal origin and products of plant origin and includes those where the processing of primary product is an integral part of the production of the final product”
Composite product
Here is some ice cream made with vegetable fat, buttermilk powder and whey protein. This is a composite product because it is primarily material of plant origin – custard powder, vegetable fat, glucose syrup, etc. combined with relatively small amounts of milk powder and whey protein

11. Final product has been cooked
Composite product: “A foodstuff intended for human consumption that contains both processed products of animal origin and products of plant origin and includes those where the processing of primary product is an integral part of the production of the final product”
Vegetable Oil, Water, Whole Egg, Lemon Juice ,
Vinegar, Salt
Final product has been cooked
Mayonnaise:
If egg content cooked – a composite product
If egg content raw egg product
Here is another composite product – mayonnaise containing egg. The final product has been cooked in the jar so this is a composite product. If you have mayonnaise containing raw egg it would be an egg product.

12. Warning!
Processed animal products can contain some plant material without becoming composite products

13. Commission Guidance If the plant material is:
Commission Guidance on Regulation (EC) No 853/2004:
If the plant material is:
necessary for the manufacture of the product (i.e. there for technical reasons),
or is there to add special characteristics,
it is still a processed animal product and not a composite product
See slide

14. Processed fishery product. (Not a composite)
Canned tuna in sunflower oil:
Vegetable content essential for manufacture + adds special characteristics
Ingredients: Skipjack Tuna (Katsuwonus pelamis), Sunflower Oil
and Salt
This is an example of a foodstuff which is still a processed product, in this case a processed fishery product even though it contains plant oil.
This is because the sunflower oil is necessary for the manufacture of the processed product – you could not make canned tuna without some sort of liquid to fill up the can and the oil is also there to give special characteristics to the tuna – canned tuna made with sunflower oil has a different taste and consistency compared with tuna canned in brine.
Processed fishery product. (Not a composite)

15. Processed meat product. (Not a composite)
Canned minced beef with onions –
vegetable content adds special characteristics
Ingredients: Beef (75%), Water, Onions, Wheat flour, Tomato Puree, Beef Extract, Salt, Corn flour,
Sugar, Natural Colour (Plain Caramel), Natural Onion Flavour, Maltodextrin and White Pepper
(Potatoes shown on label were not present in tin – this is just a serving suggestion)
Here is an example of a foodstuff which is still a meat product. Note that the potatoes shown on the picture are not in the product – the picture on the label is just a serving suggestion. Although it contains onions, they are there to add special characteristics (flavour) to the minced beef and the product is still a meat product. It must therefore meet the import requirements for meat products.
Processed meat product. (Not a composite)

16. Composite product
However this is a composite product. The corned beef is a processed product of animal origin which has been combined with plant material – in this case potato.
It is no longer simply a meat product. The potatoes are not there for technical reasons as part of the manufacturing process of the corned beef, nor are they there to give special characteristics to the corned beef. Therefore this is a composite product – it is simply a mixture of corned beef and potatoes.

17. Is it subject to veterinary checks?
Is it a composite product?
Is it subject to veterinary checks?
What are the import conditions?
So we have decided our food is a composite product. The next step is to consider whether it will be subject to veterinary checks at the EU border

18. Composite products which must be subject to vet checks - Decision 2007/275/EC –Article 4
Some composite products are always subject to veterinary checks. These are listed in article 4 of CD 2007/275/EC
They are
Composite products which contain any amount of processed meat product
Composite products with 50%+ of any one type of processed product of animal origin other than meat product and
Composite products with no meat product content but with a dairy content of <50% and where the requirements of article 6 have not been met.

19. Total animal product content must be <50%
Composite products which must be subject to vet checks - Decision 2007/275/EC –Article 6
Total animal product content must be <50%
For composite products to be exempt from veterinary checks at the BIP the composite product must meet the requirements of article 6. Such composite products
Must not contain any meat product
The total processed animal product content must be less than 50%.
The final product must be either ambient stable, or if it is chilled or frozen the final composite product itself must have been cooked or heat-treated sufficiently so that any raw material is denatured. So where you have a refrigerated product it is the final product that must have been cooked, not just the components
Then it must also meet the requirements of (ii) to (iv) (go through them)
Finally (X) the processed dairy part of the composite product must meet the general requirement in article 6.2 to come from an approved third country and have undergone the relevant treatment required for that country.

20. CD 2007/275 /EC Article 6.2
Any milk product included in any composite products shall only be derived from, and treated as provided for, countries listed in Annex I to Commission Regulation (EU) No. 605/2010
Column A = Raw
Column B = Pasteurised
Column C = Sterilised, double pasteurisation, UHT, pH <6, etc
For any dairy content the list of countries and the treatments required is now in Regulation 605/2010. Here you can see, for example, that Australia is approved in all 3 columns – Column A for raw dairy products, Column B for pasteurised and Column C for sterilised or similar severe treatment. However, if you look at Argentina for example you can see that is not approved to supply raw or pasteurised dairy products to the EU – only sterilised or similarly-treated dairy products are permitted.

21. CD 2007/275/EC Article 6
So, we have seen that Article 6.1a (X) allows for some composite products to be exempt from veterinary checks.
The other way that composite products and some foodstuffs can be exempt from veterinary checks is if they are listed in Annex II of CD 2007/275 (X)
Let’s look at that Annex II

22. CD 2007/275/EC - Annex II
Composite products and foodstuffs exempt from veterinary checks:
Biscuits, Bread, Cakes, Chocolate, Confectionery (including sweets)
Unfilled gelatine capsules
Food supplements packaged for the final consumer, containing small amounts of animal product, and those including glucosamine, chondroitin, or chitosan.
Meat extracts and meat concentrates.
Olives stuffed with fish.
Pasta and noodles not mixed or filled with meat product.
Soup stocks and flavourings packaged for the final consumer, containing meat extracts, meat concentrates, animal fats, or fish oils, powders or extracts.
These composite products listed in Annex II and these are always exempt from veterinary checks. Note that there are also some foodstuffs in the list which are not composite products in this list such as unfilled gelatine capsules and meat extracts
(Go through list. Cakes with cream fillings not included)

23. Summary: Is it subject to veterinary checks?
Work on the basis it is subject to veterinary checks and then try to exempt it ……
Does it meet the requirements for exemption in article 6?
Is it listed in Annex II?
So in summary, when considering whether a composite product is subject to veterinary checks, work on the basis that it is and then see if you can exempt it either because it meets all the requirements for exemption in article 6 or it is listed in Annex II

24. Composite products which are exempt from veterinary checks
Must still meet EU requirements.
Derogation is from vet checks at the BIP.
Official controls can still be done inland at any point in the distribution chain if necessary
However, even composite products outside vet checks must meet the EU requirements and if they do not, such products must be rejected. Rejection would be under general food hygiene rules.
If composite products are found inland which do not comply with EU requirements, they must also be rejected or recalled from the market. It is up to the MS to organise this and to designate which competent authority in their MS is responsible.

25. Composites Questionnaire
Divide into groups (Groups on next slide)
Examples of products of animal origin and you have to decide whether they are composite products
All ingredients are from the country stated on the questionnaire. CN codes are for information only and all the CN codes stated are in Annex I to CD 2007/275/EC
(Groups on next slide). Appoint spokesman for each group

26. GROUPS

30. Made with salted cod roe.
All ingredients from Japan

32. Curd is a type of cheese

38. What are the import conditions?
Is it a composite product?
Is it subject to veterinary checks?
What are the import conditions?
So remember – be logical. You have decided it is a composite product, you have decided it is subject to veterinary checks. Only now do you decide what are the import conditions

39. 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
As a general principle, composite products must meet both animal and public health requirements, so (see slide)

40. 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)
The processed animal product content must meet the animal health requirements laid down in Dir /99/EC. This means the processed animal product content must come from an approved country. (X)
In addition, any dairy content of the composite product must have undergone the required treatment for country of origin of the dairy products concerned, which may be just pasteurisation or may be sterilisation or similar severe treatment. (X)
The same principle applies for any meat product content. As well as coming from an approved third country, the meat product content must also have undergone the required heat treatment for the species concerned. These treatments are laid down in CD 2007/777/EC (see next slide)
– Meat product content must have undergone required treatment for country of origin of the meat product. (Commission Decision 2007/777/EC)

41. Commission Decision 2007/777 /EC -
Meat products 3rd country & treatment list
This shows part of the third country list for meat products. E.g. Australia is approved for meat products of bovines which have undergone only treatment A whereas poultrymeat from Australia can be used only if it has undergone treatment D. (describe A, B, C, D)
Some countries are divided into regions.

42. 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 (where required) (Dir.96/23/EC).
(List is in Decision 2011/163/EU as amended)
So those are the animal health requirements for the processed animal product content. Let’s now look at the public health requirements.
On public health grounds, the processed animal product content must (see slide)

43. 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
Finally, the finished composite product itself (see slide)

44. 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.
The import conditions for some composite products are fully harmonised. These fully harmonised composite products are those with:
Any meat product content, or
50%+ dairy content or any amount of dairy product if the final composite product is not cooked and requires refrigeration or in any cases where the requirements of article 6 for exemption have not been met or
50%+ egg content or
50%+ fishery product content (X)
For these harmonised composite products, the finished composite product can come only from a country which is on the third country list for the animal product components which have to be certified
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 (article 3.1)

45. 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)
Must meet the requirements of the health certificate which has to be certified
These harmonised composite products must also have the health certificate laid down in Regulation (EU) No 28/2012
(X) must meet the requirements of the health certificate.
(X) The certificate covers the animal and public health requirements for relevant meat product, dairy, fish, egg content which has to be certified
The certificate covers the animal and public health requirements for relevant meat product, dairy, fish, egg content which has to be certified

46. Requirements laid down in certificate
Meat product and dairy product content
Must come from:
– Same country as the composite product, or
– EU, or
– Another third country with similar high health status
The certificate requires that the meat and dairy products used in composite products must come from … (see slide)

47. 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]
So, in the case of the meat product content, composite products made in one country can use meat products from another country only if both the country manufacturing the composite product and the country supplying the meat product are listed in CD 2007/777 as requiring only treatment A for the species concerned
(X) Similarly composite products can be made with dairy products from another country only if both countries are listed in column A or B of Reg 605/2010 as being approved to supply raw or pasteurised dairy products to the EU.
If the country where the composite products is made is listed only in column C it cannot use dairy products from another third country. For such column C countries the only options for the dairy content are for it to come either from the same country or from the EU

48. 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)
The specimen certificate runs to several pages.
With the certificate it is worth checking the notes in particular.
(X) The note for box I.7 (X) makes clear that the composite product can come only from third countries which are on the relevant third country list for the processed animal product content which is certified in the health certificate.
(X) The note for box I.11 (X) requires the name, address and approval number if any of the premises where the composite product was produced to be stated. The note goes on to state that the country must be the same as the country of origin in box I.7 which means that the composite products can be exported only from the same country in which they were manufactured.
Place of origin of the composite product must be in the same country where the composite product was produced. (Note to box I.10)

49. 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)

50. 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
So what is being certified? The attestations start with a general attestation by the person signing the certificate that they are aware of the EU food hygiene legislation and that the composite products meet those requirements, in particular that the processed animal product content came from approved establishments.

51. Meat products certification
Products meet animal health requirements of CD 2007/777/EC
Country of origin
Establishment of origin
Various BSE attestations
For the meat product component, the species, the heat treatment required, the country and establishment of origin of the meat product component are stated along with any required BSE attestations.

52. 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
The dairy section must be completed for composite products where the dairy content is 50% or more and for not shelf-stable composite products where there is any amount of dairy content.
The country and establishment of origin of the dairy content are certified and also that the animals come from inspected holdings not under subject to animal health restrictions. The type of processing the dairy component has undergone also has to be stated.

53. Fishery products certification Egg products certification
Approved country
Approved establishment
Egg products certification
Approved country
HPAI and ND free
or heat treated
Finally there is a very brief section for the fishery products component which requires only the country and establishment of origin to be certified. This section has to be certified only where the fishery product content is 50% or more
Where there is an egg content of 50% or more, the egg products section must be completed, certifying that the third country of origin is free of HPAI and ND at the time the certificate was issued or there are various heat treatment alternatives.
Note that if only the egg or fishery content has to be completed, the composites product certificate can be signed by an official inspector. However if the meat or dairy sections have to be certified the certificate must be signed by a vet.
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

54. Example certificate for composite product from Vietnam containing processed fishery product and no other animal product
So although the specimen certificate in Reg 468/2012 looks very long, the result can be a very brief certificate as in this example for composite products from Vietnam containing just processed fishery product.

55. 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/ (Reg (EU) No 1079/2013)
So that is the certificate required for harmonised composite products. However there are some composite products which contain processed POA other than meat, dairy, fish or egg - such as composite products with 50% or more honey or gelatine. For these the certificates required are laid down in article 3.3.
Such composite products can come only from countries approved for the import of the animal product concerned and they must have the relevant animal health certification laid down in EU legislation. If there is no such certificate laid down, it is up to the MS of destination to specify the animal health conditions, i.e. national rules.
Public health import conditions are not yet agreed at EU level so the public health conditions for these types of composite product remain under national rules until This means the import conditions for these product may vary by MS.

56. Be Logical! 1st: Is it a composite product?
Only then decide:
2nd: Is it subject to vet checks?
3rd: What are the import conditions?
Finally, just a reminder - when thinking about composite products be logical! X X X X X

57. Thanks for listening!