Export or move composite food products
Find out what a composite food product is, and the rules you need to follow to export or move these products now and from 21 April 2021.
This guidance applies to businesses in Great Britain (England, Scotland and Wales) exporting or moving composite food products to, or through:
- the EU (European Union)
- non-EU countries
- Northern Ireland
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.
The rules for exporting composite food products are changing on 21 April 2021. Follow this guidance to find out what you need to do to export or move composite food products now and from 21 April 2021.
You need to follow different rules to move or export:
- processed food and drinks, including flour and spices
- food or drink that contains meat, fish, dairy and other animal products like honey and gelatine
- vegetables, fruit and other plants used as food
- pet food or animal feed
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 Great Britain to the EU or Northern Ireland
You need an export health certificate (EHC) to:
- export composite food products from Great Britain to the EU
- move them from Great Britain to Northern Ireland
- transit through the EU and Northern Ireland
If you’re moving food or drink that contains animal products to Northern Ireland, 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:
- make sure your products meet EU standards
- get your goods checked at an EU Border Control Post (BCP) or NI point of entry in the first country you enter, unless your product is exempt
- make sure your EU or Northern Ireland-based import agent has notified the BCP or Northern Ireland point of entry that your consignment is arriving - check with the BCP or Northern Ireland point of entry for how much notice needs to be given
- comply with wider HMRC guidance on customs requirements for exporting to the EU
- follow HMRC guidance for moving goods from Great Britain to Northern Ireland
Check what documents you need from 21 April 2021
From 21 April, you’ll need an EHC to export or move composite food products that:
- contain any processed meat
- are chilled or frozen
Your EU or Northern Ireland import agent will need to complete a private attestation for composite food products that:
- are shelf-stable (not chilled or frozen)
- only contain milk, egg or fish products
- meet EU production or processing requirements
You’ll need to give your EU or Northern Ireland import agent information about the products you’re exporting so they can complete this attestation.
Transition arrangements
If you use an existing EHC to export your composite product you can continue to use this EHC between 21 April and August 2021.
Checks at EU Border Control Posts (BCPs) or point(s) of entry in Northern Ireland
You must get your composite food products checked at an EU BCP or point of entry in Northern Ireland, 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 Great Britain 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.
Check the full list of EU BCPs.
Give advance notice to EU BCPs or point(s) of entry in Northern Ireland
You’ll need to give EU BCPs or points of entry in Northern Ireland 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 Northern Ireland 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 Northern Ireland point of entry
Some composite products do not need EHCs or inspection at an EU BCP or Northern Ireland 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% 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% of processed dairy and egg products
- pasta and noodles not mixed or filled with processed meat product, heat-treated and containing less than 50% 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% 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% of fish oils, fish powders or fish extracts
- food supplements packaged for the final consumer, containing small amounts (in total less than 20%) 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
Composite food products exempt from inspection from 21 April 2021
Your composite food product will be exempt from inspection at an EU BCP or Northern Ireland point of entry from 21 April 2021 if it:
- is shelf-stable
- does not contain any processed meat
- can be identified as a product intended for human consumption
- is securely packaged and sealed
- meets EU production or processing requirements, including relevant heat or sterilisation treatment for products containing dairy or egg
It must also be one of the following products:
- confectionery (including sweets), chocolate and other food preparations containing cocoa
- pasta, noodles and couscous
- bread, cakes, biscuits, waffles and wafers, rusks, toasted bread and similar toasted products
- olives stuffed with fish
- extracts, essences and concentrates, of coffee, tea or maté and preparations with a basis of these products or with a basis of coffee, tea or mate
- roasted chicory and other roasted coffee substitutes, and extracts, essences and concentrates thereof
- soup stocks and flavourings packaged for the final consumer
- food supplements packaged for the final consumer, containing processed animal products (including glucosamine, chondroitin or chitosan)
- liqueurs and cordials
Export or move these exempt products
To export or move exempt products you:
- need a commercial document instead of an EHC
- can send your products through any EU point of entry (you do not need to go through an EU BCP for inspections)
- need to follow the wider changes for exporting to the EU, for example, tariffs and customs declarations or for moving goods from Great Britain to Northern Ireland
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.
Export or move exempt products from 21 April 2021
From 21 April the EU or Northern Ireland import agent must complete a private attestation for exports of exempt products.
Exempt products can be sent through any EU or Northern Ireland port of entry.
Prohibited and restricted goods
EU rules mean you will not be able to export composite products containing dairy products made from unpasteurised milk (for example, a ready meal topped with unpasteurised cheese) to the EU.
There are other food products you cannot export to the EU.
Movements from Great Britain to Northern Ireland
You cannot move composite food products containing dairy products made from unpasteurised milk to Northern Ireland.
There is an arrangement in place until 30 June, during which some prohibited and restricted meat products can be moved from Great Britain to 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 Great Britain
The BCP will not usually contact you directly.
Rejected goods from 1 January 2021 to 31 December 2021
From 1 January 2021 to 31 December 2021, consignments of composite food products rejected at EU BCPs may, subject to a risk assessment, re-enter Great Britain 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 Great Britain 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 Great Britain 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 January 2022
Returned goods must enter Great Britain at an appropriately designated BCP for checks on entry from 1 January 2022.
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 Great Britain to the EU or Northern Ireland, they must meet EU standards.
Products with processed meat or more than 50% 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 Great Britain-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% 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 Great Britain to the EU or Northern Ireland:
- 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 2 types of EHC to send with your consignment. You’ll need:
- an EHC for the individual product, for example, honey, gelatine or snails
- composite food product EHC if the product also contains meat, fish, dairy or eggs
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 Northern Ireland points of entry may apply different rules on this. You, the EU importer or Northern Ireland trader, should check the requirements with the BCP or Northern Ireland point of entry to reduce the risk of your products being delayed or rejected.
Products containing honey, gelatine or snails from 21 April 2021
From 21 April 2021 composite food products that contain honey, gelatine or snails will need either:
- a composite product EHC if the product contains meat, or is frozen or chilled
- a private attestation if the product contains dairy, fish or egg and is shelf stable
You will not need an EHC for the honey, gelatine or snails component of your product.
For composite products where the only processed POAO is honey, gelatine or snails you will need either:
- an EHC for the honey, gelatine or snails if the product is chilled or frozen
- a private attestation if the product is shelf stable
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 Northern Ireland to the EU
There are no new requirements for exports of composite products from Northern Ireland to the EU.
Arrangements for authorised traders moving food from Great Britain to Northern Ireland
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 Great Britain to Northern Ireland, 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 Northern Ireland, 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 Northern Ireland 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 Northern Ireland.
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 Great Britain to Northern Ireland, for sale in Northern Ireland. For example, a meat pie supplier that moves its own products from Great Britain to Northern Ireland, 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 Great Britain, which is then moved by the supermarket to Northern Ireland, the producer would not qualify. In this instance, the supermarket would be the authorised trader for that movement into Northern Ireland.
Last updated 31 March 2021 + show all updates
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Added section on certificates and private attestations needed from 21 April 2021. Updated sections on exempt products and section on products made with processed POAO, such as honey, gelatine or snails.
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Updated dates for composite food products rejected or returned from an EU Border Control Post (BCP).
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Updated section on authorised traders moving food from GB to NI.
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First published.
