This short article discusses what food items require a licence to be imported into Great Britain from overseas.
Plant-based products that contain animal ingredients are confusing. In this essay, we shall discuss the export and import of composite food and animal products from the United Kingdom.
What exactly is composite food?
In layman's terms, it refers to a dish that combines two or more components.
Both of the following are present in composite products: Plant products as a primary element in processed products of animal origin (POAO) for human consumption - not merely added for flavouring or processing. Composite goods include the following: Chicken burritos, lasagne, pork pies, pepperoni pizza, cream liqueurs, and chicken burritos. Plant-based goods containing no POAO are not composite products.
STOP! Are you confident your food is really a composite product?
Different rules and certificates may apply if your product isn't a processed POAO. For example, fresh chicken that contains minor amounts of plant-based products added for processing or to add flavour would not be a composite product. Or what about yoghurt with added fruit? Cheese with herbs contains multiple forms of POAO but does not fit the composite product definition.
Also, if your business is importing animal items that are not for human use, such as pet food, then there are other rules you must follow. Please arrange for a call with your Customs Manager to go through these, or drop a message in the chat.
Note: Composite items including unpasteurised milk dairy products (for example, a cooked ready meal topped with unpasteurised cheese) cannot be imported using a composite health certificate.
What should I do now that my product matches the classification of composite products?
Goods containing processed meat or at least 50% milk, dairy, egg, or fisheries products may be subject o licencing.
Overall, we can simplify and summarize the requirements like this:
To import composite items to Great Britain, you will usually require an export health certificate for the import of the POAO products. Composite goods usually do not require any plant health measures and so do not require a phytosanitary certificate. You also need commercial documentation.
The exporter is usually the one to apply for a health certificate in their own nation - competent authorities should utilise model health certificates to produce versions that exporters may apply for and provide you with an electronic copy to submit to the import system.
If you do not know which Health Certificate to go for, get in touch, and we can help you access the correct documentation.
The exporter may then provide the UK importer with an electronic copy of the EHC to submit to the UK's IPAFFS (product, animal, food, and feed import system). Usually, the original certificate (not a replica) must accompany the shipment.
Some composite items are excluded from the requirement for a health certificate.
Composite which meet these 4 generic rules are exempt if all the following conditions are met, and they are:
heat-treated - this means that the product is shelf-stable at room temperature or that it has undergone complete cooking or heat treatment during manufacture so that any raw product is denatured
made without processed meat, meat extracts, or powders
made with less than 50% of any other processed POAO (any dairy must come from an approved country and have undergone the correct heat treatment for that country)
labelled for human consumption securely packaged or sealed
In addition, there are specific products. Here are the key ones:
Heat-treated confectionery (including sweets) and chocolate containing less than 50% processed dairy and egg products
Pasta and noodles that have not been blended or filled with processed meat products, have been heat-treated, and include less than 50% processed dairy and egg goods
bread, cakes, biscuits, waffles and wafers, rusks, toasted bread, and similar heat-treated toasted items containing less than 20% processed dairy and egg products
Heat-treated olives stuffed with fish soup stocks and flavourings that are packaged for the ultimate customer and contain less than 50% fish oils, fish powders, or fish extracts
food supplements produced for the ultimate consumer that include less than 20% processed animal products (including glucosamine) in total
Here is the list of exempted products and more information
No EHC but a Commerical Document - What you need to know
If your product is exempt, a commercial document is required. This also needs to be pre-notified to enter the United Kingdom through a BCP - detailing facts about the shipment, the identity of the person who delivered it the name of the person to whom it is being sent. It should also entail the kind, amount, and the number of packages of composite items the country of origin manufacturer information list of ingredients. The commercial paperwork must accompany the shipment.
The following regulations give more information about composite products, including definitions:
Regulation No. 28/2012
If you need help with your customs declaration
Contact your Customs Manager or drop a message in the chat.