Date of issue: 23 April 2021
Date of effect: Immediate
Reference Number: MAA2021-03
Related: MAA 2020-10
- Industry Bodies – Australian Food and Grocery Council (AFGC), Dairy Australia, Dairy Industry Export Consultative Committee, Seafood Exports Consultative Committee
- Department of Agriculture, Water and the Environment—Central and Regional offices
To notify manufacturers and exporters of changes to European Union (EU) regulations affecting specific composite products and to request information from exporters.
Composite products (for example; pizzas, soup, pies) are defined by the EU as foodstuffs containing both products of plant origin and processed products of animal origin.
Prior to 21 April 2021, the export of the following categories of composite product required export health certificates:
- Containing more than 50 per cent of processed products of animal origin
- Containing any quantity of meat
- Non-shelf stable containing any quantity of milk.
These are currently exported on export health certificates templates:
- M492 – Heath Certificate for import into the European Union of composite products intended for human consumption
- M492A- Health Certificate for transit through or storage in the European Union of composite products intended for human consumption
- M493- Heath Certificate for import into the European Union of composite products intended for human consumption (English – French version).
Summary of key points
From 21 April 2021, EU entry requirements for composite products are no longer based on the percentage of ingredients of animal origin. From 21 April 2021, Commission Delegated Regulation (EU) 2019/625 use the following categories for composite products:
- Category (1) non shelf stable composite products;
- Category (2) shelf stable composite products that contain meat products; and
- Category (3) shelf stable composite products that do not contain meat products.
Further, in accordance with EU Delegated Regulation 2020/2235, the export of composite products requires new export health certificates. Please read the below carefully as there are different dates of implementation for different products.
Composite products which have required export health certificates can continue to be certified with the existing certificates (M492, M492A and M493 as above) until 20 August 2021. After this date, new export certificates will be required for composite products to the EU. The department is developing these certificates.
Two of the new categories (1) and (3) have subsets, which did not require export certificates. Delegated Regulation 2020/2235 affects them from 21 April 2021. These are:
Category (1) subset
- Non-shelf stable composite products, containing less than 50 per cent processed products of animal origin, other than meat or dairy.
Category (3) subset
- Shelf stable composite products, containing less than 50 per cent processed products of animal origin other than meat (except gelatine, collagen and highly refined products)
These two sub-sets will be affected as follows:
|Composite product||Effect of new rules from 21 April 2021|
|Shelf stable composite products, containing less than 50 per cent processed products of animal origin other than meat (except gelatine, collagen and highly refined products)||Require a manufacturer’s private attestation PDF (964 KB) (to be signed by the importer)|
|Non-shelf stable composite products, containing less than 50 per cent processed products of animal origin, other than meat or dairy*. These products are required to be transported or stored under controlled temperature.||Require Export Health Certification, issued by the department – currently there is no certificate. This certification will be developed based on industry need.|
* Australia does not currently maintain an EU approved residue plan for eggs, porcine or poultry and therefore is not permitted to export those commodities or products containing these ingredients to the EU. Australia does maintain EU approved residue plans for meat, dairy and fish products and can export these products, and products containing these ingredients, to the EU.
If you are exporting non-shelf stable composite products, containing less than 50 per cent processed products of animal origin, other than meat or dairy, please contact the department immediately at firstname.lastname@example.org. This information will be used to prioritise market access work.
The European Commission has published detailed information on the new requirements titled, Special EU import conditions for composite products.
The Manual of Importing Country Requirements (Micor) shall be updated to reflect this Market Access Advice.
Contact email@example.com 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.