MAA 2020-10: European Union: Processed Foods: Changes for the importation of composite products

Date of issue: 14 May 2020

Date of effect: 21 April 2021

Reference Number: MAA2020-10


  • Industries—Industry bodies - Australian Food and Grocery Council
  • Licensed exporters
  • Department of Agriculture, Water and the Environment - Central and Regional offices


To notify manufacturers and exporters of the change in European Union (EU) regulations affecting composite products. Composite products are defined as products containing both products of plant origin and products of animal origin such as chocolate bars, biscuits, soups, frozen cakes and pies.

Summary of key points

From 21 April 2021, EU entry requirements for composite products will no longer be based on the percentage of ingredients of animal origin. From this date onwards Commission Delegated Regulation (EU) 2019/625 will use the following categories for composite products:

(1) non shelf stable composite products;

(2) shelf stable composite products that contain meat products; and

(3) shelf stable composite products that do not contain meat products.

The most significant change for composite products, from previous regulatory requirements, is the requirement that all processed products of animal origin (meat, dairy, eggs and fish), regardless of their percentage as an ingredient in the product, are required to be sourced from EU listed establishments to be eligible for import.

The department will release further advice regarding EU listing as more information becomes available.

Official Certificates

An official certificate will be required for composite products within categories (1) and (2). The content of the official certificate will be established in the second half of 2020.

A manufacturer’s attestation will accompany composite products of category (3), see Attachment 1 for information on the attestation. Category 3 can further be divided into products that will be subject to control at the border, and products that will be subject to control at the destination within the EU. Further information will be provided in the second half of 2020, for products not subject to control at the border.

Listing requirements to export composite products to the EU

All the processed products of animal origin (meat, dairy, eggs and fish), contained in the composite products, regardless of their category, must be sourced from EU listed establishments.

Country approval for animal origin ingredients

In order to be eligible to export composite products to the EU, a country must have:

  • an approved residue monitoring plan for each of the ingredients of animal origin in question, in which case the country is listed in the Annex to Commission Decision 2011/163/EU; or
  • it must source the animal ingredients either from an EU Member State or a third country which is listed for those commodities.

The department notes Australia does not currently maintain an EU approved residue plan for eggs, porcine and poultry. Australia maintains an EU approved residue plan for meat, dairy and fish products.

Further information:

Contact if you have any queries.

The information provided in this advice is current at the time of writing and is intended for use as guidance only and should not be taken as definitive or exhaustive. The Commonwealth endeavours to keep information current and accurate, however, it may be subject to change without notice. Exporters are encouraged to verify these details with their importers prior to undertaking production/exports. The Commonwealth will not accept liability for any loss resulting from reliance on information contained in this notice.

Last reviewed: 14 August 2020
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