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Introduction to EU compound foods and related regulatory requirements

 Last Update: 2022-12-30
 Source: Internet
 Author: User

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Food Partner Network News Recently received some food industry partners about whether ** food is a compound food, what restrictions on the export of meat products, aquatic products, dairy products, etc.
contained in compound foods to the EU
.
The Food Partner Network sorted out this, mainly including how to determine compound food, and what regulatory requirements companies have when exporting compound food to the EU, for industry reference
.

Complex food determination

"Complex products" are foods that contain both plant-based and animal-derived processed products, such as milk sugar
.
The reason why food is a compound food is that it contains both products of plant origin and products of animal origin, and there is no relationship
with the proportion of products of animal origin contained in the food.

(EU) 2019/625 "Requirements for the entry into the EU of certain animals and goods intended for human consumption" divides complex foods into three main categories:

non-shelf-stable compound foods;

shelf-stable complex foods containing any number of meat products, except gelatin, collagen and highly refined animal ingredients;

shelf-stable complex foods that do not contain meat products, except for gelatin, collagen or highly refined animal ingredients;

When determining whether a product is a compound food, it should be noted that the addition of plant-derived products during the processing of animal products does not mean that the final product is defined as a compound food, and if plant-derived raw materials are added without changing the main characteristics of the final product, it is not a compound food; Adding plant-based ingredients may simply be necessary to add special flavor or to make animal-derived products, such as fruit in yogurt, which is still dairy rather than a compound
.

In addition, non-shelf stable compound foods must be transported or stored at controlled temperatures, while shelf stable compound foods can be kept at
room temperature.

Regulatory requirements for compound foods

2.
1 Hygiene requirements

The hygienic requirements for the production of compound foods shall comply with Articles
3 to 6 of the European Union (EC) No 852/2004 Food Hygiene Regulation.

2.
2 Conditions of Import

The import conditions of compound foods shall comply with Articles
12 to 14 of Regulation (EU) 2019/625.

2.
3 Requirements for products of animal origin in compound foods

Although Regulation (EC) No 853/2004 excludes compound foods from its scope, it is still clearly stated that compound foods can only use animal-derived ingredients manufactured by licensed companies in the EU, and Article 1(2) of Regulation (EC) No 853/2004 clearly states that products of animal origin used in complex foods must be collected and processed in accordance with the requirements of
the Regulation.
This means that products of animal origin in complex foods must be sourced from EU member states or third-country companies licensed by the European Union
.

2.
4 Official certificate or self-declaration document

According to the classification of compound food, an official certificate or self-declaration document is required to accompany the goods, which is specified in Chapter 50 and Schedule V of Schedule III of (EU) 2020/2235 respectively
.

In addition, the Residue Monitoring Scheme in Animals and Animal Products submitted to the European Commission for human consumption by approved third countries is set out in the Annex to Decision 2011/163/EU and is indicated in the Schedule
with an "X".
For low-risk compound foods, Regulation (EU) 2021/630 exempts such products from official controls at border control points, which can take place
at the destination of the product, at the point of release of the product or at the warehouse or premises of the product.

Summary

In summary, compound products in the EU are foods that contain both plant-derived products and animal-derived processed products, and have no relationship
with the proportion of animal-derived products contained in the food.
The list of third countries that are allowed to export complex foods to the EU is based on the list of third countries that can sell meat, aquatic products, dairy and primary dairy products and egg products to the EU
.

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