A composite product is a foodstuff, intended for human consumption, that contains both processed products of animal origin (POAO) and products of plant origin, for example a cheese and pepperoni pizza, or a tuna pasta salad. Read the definition of composite products.
If the animal product ingredient is not processed (e.g. contains raw animal material), then it is not a composite product but is considered POAO. In the case of fishery POAO you should follow FSA Guidance on fishery products, for other POAO you should use DAERA's guidance.
However, there are two cases where the addition of a product of plant origin to processed POAO does not make it a composite product, these are:
i. When the plant product adds special characteristics, e.g. flavour, sweetness or acts as thickening/decorative agent. Some examples would be a cheese to which herbs are added or a yogurt to which fruit is added, in both instances these remain dairy products, as the plant products add flavour; or
ii. When the plant product is necessary for the manufacture of the POAO, e.g. for technical reasons. For instance, canned tuna to which vegetable oil is added remains a fishery product, as the vegetable oil is present to help preserve the tuna. Plant products may also be used to aid the processing of the product of animal origin or as an emulsifier (to stabilise the final product).
Moving composite products to Northern Ireland
i. composite products stored/transported under controlled temperatures, e.g. chilled or frozen products;
ii. composite products, that do not need to be stored/transported under controlled temperatures, that contain any quantity of meat products, except gelatine, collagen and highly refined products; and
iii. composite products, that do not need to be stored/transported under controlled temperatures, that do not contain meat products, except gelatine, collagen and highly refined products.
For products in categories i. and ii. a composite products export health certificate (EHC) must be attached to the CHED P to enter NI.
Products in category iii. only require a private attestation (Model Private Attestation), to accompany their CHED P and no longer need an EHC.
Products not subject to border checks
The following exempt composite products that do not need to be stored/transported under controlled temperatures no longer require BCP checks (provided they meet these requirements) and only a Private Attestation is required to accompany these products, which may be checked inland:
- confectionery (including sweets), chocolate and other food preparations containing cocoa (CN Codes - 1704, ex 1806 20, ex 1806 31 00, ex 1806 32, ex 1806 90 11, ex 1806 90 19, ex 1806 90 31, ex 1806 90 39, ex 1806 90 50, ex 1806 90 90)
- pasta and noodles and couscous (CN Codes - ex 1902 19, ex 1902 30, ex 1902 40)
- bread, cakes, biscuits, waffles and wafers, rusks, toasted bread and similar toasted products (CN Codes - ex 1905 10, ex 1905 20, ex 1905 31, ex 1905 32, ex 1905 40, ex 1905 90)
- olives stuffed with fish (CN Codes - ex 2001 90 65, ex 2005 70 00, ex 1604)
- 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 maté (CN Code - 2101)
- roasted chicory and other roasted coffee substitutes, and extracts, essences and concentrates thereof (CN Code - 2101)
- soup stocks and flavourings packaged for the final consumer (CN Code - ex 2104)
- food supplements packaged for the final consumer, containing processed animal products (including glucosamine, chondroitin or chitosan) (CN Code - ex 2106)
- liqueurs and cordials (CN Code ex 2208 70)
Exempted composite products which meet High Risk Food Not of Animal Origin (HRFNAO) compound requirements will still have to follow the relevant conditions for HRFNAO.
Food business operators are reminded that it is their responsibility to ensure any foodstuffs they want to move comply with national rules in place to protect public and animal health. Traders should satisfy themselves that any composite products coming to NI comply with the requirements, which cover EU approved premises, countries and residues plan.
Further information can be found at using Defra's FAQs or the EU’s Composite Questions and Answers.
Grace period for authorised traders moving food from GB to Northern Ireland
The latest arrangements on the Scheme for Authorised Movements to Northern Ireland (STAMNI), for authorised traders such as supermarkets and their trusted suppliers, can be found on the DAERA website as Detailed Guidance for Authorised Traders.