B etter T raining for S afer F ood Initiative

1. BetterTraining for SaferFoodInitiative Simon Rowell Composite Products This action/ training/ seminar is carried out by JVL Consulting under the contract no 2012.96.02 with the Consumers, Health and Food Executive Agency (former Executive Agency for Health and Consumers). Terespol, 1-3 July 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) Meat products, dairy products, egg products, processed fishery products, etc.are defined 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” Mayonnaise: If egg content cooked – a composite product If egg content raw - egg product Vegetable Oil, Water, Whole Egg, Lemon Juice , Vinegar, Salt Final product has been cooked

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 • There to add special characteristics, it is still a processed animal product and not a composite product

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

15. Canned minced beef with onions – vegetable content adds special characteristics Processed meat product. (Not a composite) 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 To be outside checks, total animal product content must be <50%

20. Column A = Raw Column B = Pasteurised Column C = Sterilised, double pasteurisation, UHT, pH <6, etc 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

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

30. Curd is a type of cheese

37. JVL Consulting s.a. Rue Jean Matagne 15 B-5020 Vedrin Belgium AESA Consortium This action/ training/ seminar is carried out by JVL Consulting under the contract no 2012.96.02 with the Consumers, Health and Food Executive Agency (former Executive Agency for Health and Consumers). European CommissionConsumers, Health and Food Executive AgencyDRB A3/042L-2920 Luxembourg