Import from countries outside the EU – composite products

Composite products are foodstuffs containing both products of plant origin and processed products of animal origin.

In accordance with Articles 1(2) and 6(4) of Regulation (EC) No. 853/2004, the composite products must be manufactured with processed products of animal origin produced in EU-approved establishments located either in EU Member States or in third countries authorised for entry into the EU of those particular processed products of animal origin.

Import requirements for composite products

Rules for the entry of composite products into the EU are laid out in Articles 20 to 22 of Regulation (EU) 2022/2292. The rules are proportionate to the risk presented by composite products and are no longer based on the amount of processed products of animal origin in the final product.

More information on the entry conditions for composite products can be found on the website of the European Commission.

EU entry conditions for composite products - European Commission

For shelf-stable composite products only containing processed honey or other apiculture products as an animal ingredient, no private attestation is required. Instead, you as an importer need to provide supporting documents confirming that all import conditions are met.  The following documents need to be available at the time of border control and should be attached to the CHED in TRACES NT:

• A commercial document proving the details of the consignment, such as exporter, importer, number of packages and weight. This can be, for example, an invoice, packing list and/or a transport document.
• Documents proving the processing and origin of the honey, including the establishment number which can be checked against the lists in TRACES NT. Note that establishments for honey and other apiculture products are required to be listed in TRACES NT as of 29 November 2024. Examples of documents that may contain this information are a product specification, a declaration from the honey establishment or similar.

Please note that if your product contains unprocessed honey, it is not a composite product, but considered as a product of animal origin. It has to comply with the import requirements for honey, including being accompanied by an official certificate for honey.

Import of honey and other apiculture products

Composite products exempted from border control

Shelf-stable composite products that present a lower risk are exempted from border control. Those products are listed in the Annex to Regulation (EU) 2021/630. The products listed still need to fulfil the requirements and be accompanied by a private attestation, but do not need to be presented to an EU border control post when imported.

Regulation (EU) 2021/630 - EUR-Lex

Shelf-stable composite products only containing additives, enzymes or flavorings as its animal content, or where the only animal ingredient is vitamin D3, do not require border control or a private attestation. This is stated in Article 3(1) b in Regulation (EU) 2021/630.