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 productThey 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 28/2012Commission 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, becauseingredients of animal origin are controlled under Reg. (EC) No 852/2004, andprocessed products of animal origin are obtained and handled in accordance with the requirements of Regulation (EC) No 853/2004Regulation (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 productsHigh amounts of composite products imported from Third countriesLimited controls of imported goods at market level
7 Import controls at BIPs MS/TC raw materialsEU productionMarketTC1 / TC2 production COM-PROImport controls at BIPsTC1 / TC2 Production COM-PRONon- BIPImport controls
8 Objectives of the project Produce an overview of the measures implemented by MS covering composite products intended for EU marketAssess if those measures ensure that only composite products in compliance with AH and PH requirements are put in the marketIdentify areas where legislation / guidelines could be simplifiedContribute to the development of EU legislation
9 Scope Legislation (EU and national) Composite products Production in Member StatesProduction in Third CountriesImport controls following EU legislationImport controls following national legislation
10 The team FVO: F1,F2,F3,F4,F5,F6,F7 Brussels: G2, G4, G6 National Experts
11 Road mapQuestionnaire to Member States and some Third Countries 1st quarter 2015Desk Study 1st half 2015MS Annual ReportsCountry ProfilesOther sourcesOverview report 2nd half 2015Decision which Member States and third countries to be visited
12 Audits to Member States: O'C system Road mapAudits to Member States: O'C systemDifferent levels of the CAs, different authoritiesDifferent steps of the control system, focusing on the planning and implementation of the controls at production, marketing and import levelDifferent establishments involved with composite products line including importers and producersCould include visits to BIPs
13 Audits to third countries Road map– 2016 (cont.)Audits to third countriesImplementation of the controls at production and export level, including traceability (specific attention to sourcing of raw materials), laboratory testing,…Guarantees provided by the certification activityDifferent 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 guidelinesPresentation 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?