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Better Training for Safer Food BTSF

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  1. Better Training for Safer Food BTSF Composite Products Simon rowell MOVEMENT AND IMPORT CONTROLS OF FEED, FOOD AND ANIMALS Control checks at border inspection posts Session 7 – 8th to 11th April 2014

  2. Be Logical! • 1st: Is it a composite product? • Only then decide: • 2nd: Is it subject to vet checks? • Only then decide: • 3rd: What are the import conditions?

  3. Is it a composite product? Is it subject to veterinary checks? What are the import conditions?

  4. Definitions Composite product: A 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 product Commission Decision 2007/275 article 2 • Food only • If any raw animal material is present it cannot be a composite product

  5. Processed product: Foodstuff resulting from the processing of unprocessed products. • These products may contain ingredients that are necessary for their manufacture or to give them specific characteristics. Regulation (EC) No 852/2004 Article 2 point (o) Definitions Processing: Any action that substantially alters the initial product, including heating, smoking, curing, maturing, drying or a combination of those processes. Regulation (EC) No 852/2004 Article 2 point (m) Specific definitions of meat products, dairy products, egg products, processed fishery products, etc. are in Regulation (EC) No 853/2004 Annex I point 7

  6. Commission Guidance http://ec.europa.eu/food/food/biosafety/hygienelegislation/guide_en.htm

  7. Composite product: “A 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 product” Composite product. Raw honey has been added to mustard & soya bean oil and cooked Not a composite product. Raw honey has been mixed with nuts but the honey has not been processed

  8. Composite product: “A 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 product” Composite products

  9. Composite product: “A 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 product” Prawn spring roll. If prawns cooked – a composite product A prawns raw – a fishery product

  10. Composite product: “A 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 product” Composite product

  11. Composite product: “A 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 product” • Vegetable Oil, Water, Whole Egg, Lemon Juice , • Vinegar, Salt • Final product has been cooked Mayonnaise: If egg content cooked – a composite product If egg content raw - egg product

  12. Warning! • Processed animal products can contain some plant material without becoming composite products

  13. Commission Guidance Commission Guidance on Regulation (EC) No 853/2004: If the plant material is: necessary for the manufacture of the product(i.e. there for technical reasons), or is there to add special characteristics, it is still a processed animal product and not a composite product

  14. Processed fishery product. (Not a composite) Canned tuna in sunflower oil: Vegetable content essential for manufacture + adds special characteristics Ingredients: Skipjack Tuna (Katsuwonuspelamis), Sunflower Oil and Salt

  15. Processed meat product. (Not a composite) Canned minced beef with onions – vegetable content adds special characteristics Ingredients: Beef (75%), Water, Onions, Wheat flour, Tomato Puree, Beef Extract, Salt, Corn flour, Sugar, Natural Colour (Plain Caramel), Natural Onion Flavour, Maltodextrin and White Pepper (Potatoes shown on label were not present in tin – this is just a serving suggestion)

  16. Composite product

  17. Is it a composite product? Is it subject to veterinary checks? What are the import conditions?

  18. Composite products which must be subject to vet checks - Decision 2007/275/EC –Article 4

  19. Composite products which must be subject to vet checks - Decision 2007/275/EC –Article 6 Total animal product content must be <50%

  20. CD 2007/275 /EC Article 6.2 • Any milk product included in any composite products shall only be derived from, and treated as provided for, countries listed in Annex I to Commission Regulation (EU) No. 605/2010 Column A = Raw Column B = Pasteurised Column C = Sterilised, double pasteurisation, UHT, pH <6, etc

  21. CD 2007/275/EC Article 6

  22. CD 2007/275/EC - Annex II • Composite products and foodstuffs exempt from veterinary checks: • Biscuits, Bread, Cakes, Chocolate, Confectionery (including sweets) • Unfilled gelatine capsules • Food supplements packaged for the final consumer, containing small amounts of animal product, and those including glucosamine, chondroitin, or chitosan. • Meat extracts and meat concentrates. • Olives stuffed with fish. • Pasta and noodles not mixed or filled with meat product. • Soup stocks and flavourings packaged for the final consumer, containing meat extracts, meat concentrates, animal fats, or fish oils, powders or extracts.

  23. Summary: Is it subject to veterinary checks? Work on the basis it is subject to veterinary checks and then try to exempt it …… • Does it meet the requirements for exemption in article 6? • Is it listed in Annex II?

  24. Composite products which are exempt from veterinary checks • Must still meet EU requirements. • Derogation is from vet checks at the BIP. • Official controls can still be done inland at any point in the distribution chain if necessary

  25. Composites Questionnaire

  26. GROUPS

  27. Made with salted cod roe. All ingredients from Japan

  28. Curd is a type of cheese

  29. Is it a composite product? Is it subject to veterinary checks? What are the import conditions?

  30. Import Conditions - General principles Processed POAO content: Must meet the EU animal and public health requirements that apply to processed POAOs and Finished composite product: Must meet EU animal and public health requirements

  31. Processed POAO content: Animal Health requirements Processed animal product content must come from an approved third country (Council Directive 2002/99/EC) – Dairy product content must have undergone the relevant treatment (e.g. pasteurisation, sterilisation) for country of origin of the dairy product. (Regulation (EU) No 605/2010) – Meat product content must have undergone required treatment for country of origin of the meat product. (Commission Decision 2007/777/EC)

  32. Commission Decision 2007/777 /EC - Meat products 3rd country & treatment list

  33. Processed POAO content: Public Health requirements The processed animal product content of a composite product: • Must come from an approved third country (Reg. (EC) No 852/2004) • Must come from an approved establishment (Reg. (EC) No 853/2004) • Must come from a country with an approved residue control plan for the product concerned (where required). (Dir.96/23/EC). (List is in Decision 2011/163/EU as amended)

  34. The Finished composite product Must meet EU general food hygiene provisions (same as for any food) • The composite product can be made in a registered establishment – i.e. it does not have to be made in an EU-approved establishment, • The composite product does not need to be marked with an ID mark

  35. Harmonised composite products • as listed in Regulation (EU) No 28/2012 composite products containing processed meat products, as referred to in Article 4(a) of Decision 2007/275/EC; composite products containing processed milk products and covered by Article 4(b) and (c) of Decision 2007/275/EC; (c) composite products containing half or more of their substance of processed fishery or egg products and covered by Article 4(b) of Decision 2007/275/EC. • Country where the final composite product was made must be on the relevant third country list(s) for the POAO content(s) that has to be certified (article 3.1)

  36. Harmonised composite products • as listed in Regulation (EU) No 28/2012 • Must have the health certificate laid down in Regulation (EU) No 28/2012 (article 3.2) • Must meet the requirements of the health certificate which has to be certified • The certificate covers the animal and public health requirements for relevant meat product, dairy, fish, egg contentwhich has to be certified

  37. Requirements laid down in certificate • Meat product and dairy product content • Must come from: – Same country as the composite product, or – EU, or – Another third country with similar high health status

  38. Similar high health status means: • Meat product content: • Meat products can only go from one Treatment A country to another Treatment A country (treatment applicable to the species concerned) [ref: Commission Decision 2007/777/EC] • Dairy product content: • Dairy products can only move from one Column A country to another Column A country or one Column B country to another Column B country • Dairy products cannot move from a Column C country to other countries [ref: Regulation (EU) No 605/2010]

  39. Requirements laid down in certificate • Country where composite product was produced must be on the relevant third country list for the POAO content(s) which has to be certified (Note to box I.7) • Place of origin of the composite product must be in the same country where the composite product was produced. (Note to box I.10)

  40. What POAO content has to be certified? • Any meat product content • Dairy content where: • Dairy product content is 50%+ • Not shelf stable – Any % • Fishery product content if 50%+ • Egg product content if 50%+ (‘Cooked’ = heat-treated sufficiently to denature any raw animal product)

  41. Health certificate - Compliance with food hygiene package I am aware of Regulations (EC) No 178/2002, (EC) No 852/2004and (EC) No 853/2004 …… and that the composite products were produced in accordance with the above legislation