1. Composite Products FVO cross-unit project 2015-2016 Izaskun El Busto
F5, FVO (Grange)

2. Definition of composite product:
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
They are defined in Article 2(a) of Comm. Decision 2007/275/EC.

3. Legal background Regulations (EC) No (EC) No 178/2002 (EC) No 882/2004
(EC) No 853/ Articles 1(2) and 6(4)
(EU) No 28/2012
Commission Decision 2007/275/EC

4. For the production of composite products, Reg
For the production of composite products, Reg. (EC) No 853/2004 does not cover it directly, because
ingredients of animal origin are controlled under Reg. (EC) No 852/2004, and
processed products of animal origin are obtained and handled in accordance with the requirements of Regulation (EC) No 853/2004
Regulation (EC) No 853/2004 does not apply to the production of food containing both products of plant origin and processed products of animal origin, unless expressly indicated to the contrary. Such exclusion from the scope is based upon the reason that the risk posed by the ingredient of animal origin can be controlled by implementing the rules of Regulation (EC) No 852/2004 without there being a need to apply more detailed specific requirements. However, Article 1(2) of Regulation (EC) No 853/2004 clearly spells out that the processed products of animal origin used to prepare composite products shall be obtained and handled in accordance with the requirements of Regulation (EC) No 853/2004

5. Not all composites need to be controlled at the borders
For the import of composite products, in accordance with Dec 2007/275/EC composite products are subject to controls at the BIPs, if they contain meat products, dairy/fish/eggs >50%, or if they require refrigeration.
Not all composites need to be controlled at the borders

6. Different risk assessment applied by Member States or Third countries
Lack of information of the Comm. about official controls done in establishments producing the composite products
High amounts of composite products imported from Third countries
Limited controls of imported goods at market level

7. Import controls at BIPs
MS/TC raw materials
EU production
Market
TC1 / TC2 production COM-PRO
Import controls at BIPs
TC1 / TC2 Production COM-PRO
Non- BIP
Import controls

8. Objectives of the project
Produce an overview of the measures implemented by MS covering composite products intended for EU market
Assess if those measures ensure that only composite products in compliance with AH and PH requirements are put in the market
Identify areas where legislation / guidelines could be simplified
Contribute to the development of EU legislation

9. Scope Legislation (EU and national) Composite products
Production in Member States
Production in Third Countries
Import controls following EU legislation
Import controls following national legislation

10. The team FVO: F1,F2,F3,F4,F5,F6,F7 Brussels: G2, G4, G6
National Experts

11. Road map
Questionnaire to Member States and some Third Countries 1st quarter 2015
Desk Study 1st half 2015
MS Annual Reports
Country Profiles
Other sources
Overview report 2nd half 2015
Decision which Member States and third countries to be visited

12. Audits to Member States: O'C system
Road map
Audits to Member States: O'C system
Different levels of the CAs, different authorities
Different steps of the control system, focusing on the planning and implementation of the controls at production, marketing and import level
Different establishments involved with composite products line including importers and producers
Could include visits to BIPs

13. Audits to third countries
Road map– 2016 (cont.)
Audits to third countries
Implementation of the controls at production and export level, including traceability (specific attention to sourcing of raw materials), laboratory testing,…
Guarantees provided by the certification activity
Different establishments involved in the production of composite products

14. Road map of the Project – 2016 (final)
Overview report. Recommendations.
Identification of the need to review/simplify guidelines
Presentation to Member States

15. Questions
- how does your MANCP reflect the controls on composite products? How are the controls planned?
- does it include a risk-evaluation?