Thursday, 11 February 2021
By Bronwyn Magee
Clarification on the application of new regulations for composite products
- The threshold of 50% for dairy as an ingredient in a composite product has been removed. As such, composite products with ANY dairy ingredient which is not shelf-stable will require an EHC
- Only one EHC is needed for a product, not one per ingredient which is a POAO
As of 21 April 2021, a new model Export Health Certificate (EHC) will come into force, which will impact the export of composite products containing products of animal origin (POAO) as an ingredient.
Under the new regulation, EHC requirements will be extended to include dairy products and other ingredients in composite food products, which were previously not required to be listed.
As defined by Defra, composite products contain a mix of processed POAO, and plant products used as a main ingredient.
What are the changes?
Under these new requirements, all POAO within a composite product will require an EHC, where previously just the composite product needed an EHC. For example, a shipment of lasagne would require an EHC, and under the new regulation, so will the cheese, milk and beef content within it. This means several new EHCs will need to be issued, compounding the added cost of exporting.
At present, composite food products exported to the EU from GB are required to be checked at a Border Control Point (BPC), unless the product is exempt. However, not all BCPs accept all goods, and so businesses will be required to use a BCP that is able to check all their products. This could redirect some trade, as goods may be refused entry if an incorrect BPS is used.
There are some composite products that are exempt from EHC requirements. These are products that meet certain conditions and are shelf stable. For example, a biscuit would be exempt from the new requirements as it is a shelf stable product and its dairy content is below the defined threshold. Other conditions of exempt products can be found here.
Ultimately, these changes will add further friction to UK-EU trade, as they increase both the administration burden and add cost to UK businesses.
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