Composite Products of Animal Origin

What is a composite product?

A product is referred to as a composite product if it is a foodstuff for human consumption which contains processed products of animal origin combined with plant material

Check the import requirements for composite products
The composite product may be made by:-

The product will not be a referred to as a composite product if it contains any raw material of animal origin or if it is not intended for human consumption e.g. it is pet food

Not all products that contain animal and plant material are treated as a composite product

A processed product of animal origin containing plant material is not a always a composite product

If the plant material is present solely for technical reasons (used as an aid to the manufacturing process) or is there just to give specific characteristics to the product of animal origin, the product remains a processed product of animal origin and does not become a composite product.  Find out more about the requirements for the importation of POAO

Plant material present for technical reasons - For example, canned tuna in vegetable oil.  This would still be regarded as a processed fishery product and not a composite product. This is because the vegetable oil is necessary as part of the manufacturing process of the canned tuna, (the can needs to be filled with liquid for processing).

Plant material providing specific characteristics
Examples would be sugar added for sweetness, herbs and spices used to add flavour, plant products added as a thickening agent or being used for decoration or as a topping.

Not all composite products are subject to veterinary checks

As a general rule all food that contains a product of animal origin is covered by veterinary checks unless it is specifically excluded. 
Composite products are excluded from veterinary checks if both of the following points are met:-  Note to Article 6 point 1 (a)(i)
For refrigerated composite products,
it is the final composite product itself that must clearly have been cooked or heat-treated sufficiently to denature (physically change) the animal-origin components after the animal product and the plant material have been combined together.

Milder heat-treatments such as pasteurisation will not denature the animal origin component.

If it is not clear from visual examination that the animal-origin content has been denatured, proof such as a flowchart from the producer showing the cooking process with times and core temperatures, will be required

Exempt composite products - Article 6

If a composite product meets all of the criteria below it is exempt from veterinary checks:-

  1. There is no meat product  (including no meat extracts or powders present)
  2. The total animal origin content is less than 50% by weight 
  3. The product is shelf stable at ambient temperature or if refrigerated the final composite product has clearly undergone during its manufacture a complete cooking or heat treatment process throughout its substance, so that any raw product is denatured 
  4. The composite product is clearly identified as for human consumption 
  5. The composite product is securely packaged or sealed in clean containers 
  6. The composite product is accompanied by a commercial document and labelled in an official language of a Member State, so that the document and labelling together give information on the nature, quantity, number of packages, country of origin and manufacturer of both the composite product and its ingredients.
  7. Any dairy content is from an approved source.

Products exempt from veterinary checks - Annex II

Annex II of Commission Decision 2007/275/EC lists the products that are exempt from veterinary checks; provided they do not contain any meat products (including meat extracts and powders) and any dairy content is from an approved source.  View the list of exempt products and find out more about products that are subject to checks.

Composite products containing any dairy content

Products containing any dairy content will not be exempt from veterinary checks unless the requirements of Article 6(2) are met.  This requires that the dairy content originates from an approved third country and has undergone the specified processing for that country.  The current list is contained in Commission Regulation (EU) 605/2010 (link to latest consolidated version at time of publishing).

Information required for detained consignments not subject to veterinary checks?

If your consignment is detained by Port Health you need to submit further information (usually by email). 

Basic information needed for all detained consignments:-

Where it is not clear that the goods are exempt from veterinary checks, further information will be required:-

Even in a composite product not subject to checks, all animal-origin ingredients must come either from the EU or from non-EU countries which are approved to supply the animal-origin product itself to the EU.  This means that each animal origin ingredient must be sourced from a non-EU country which is both on the relevant third country list published by the Commission and has an approved residue control plan for the animal origin ingredient concerned.  The list of countries with approved residue control plan can be found in Commission Implementing Decision (EU) 2018/1067.

For composite products outside veterinary checks, checking of the requirements relating to the origin of the ingredients may be undertaken by the local authority inland. 

What are the import requirements for composite products subject to veterinary checks?

If you are importing a composite product which is subject to veterinary checks the requirements of Regulation 28/2012 apply.

Health Certificate

The health certificate laid down in  Regulation 28/2012 is required if the composite product contains:-

If the product contains 50% or more of any other animal product e.g. gelatine, honey, collagen then the EU health certificate that applies to the pure product is required.

Processed animal product content not mentioned above does not have to be certified (although it can be) but must still meet the general requirements to come from an approved establishment in an approved third country with an approved residue control plan


Regulation 28/2012 requires that the animal-origin ingredients must originate in the same country that manufactured the composite product.  However, there are exceptions in that the Regulation allows countries with low animal health risk to manufacture composite products using meat products or dairy products from other low-risk third countries or from the EU.

The principles are:

The details are as follows: 


I import ice cream confectionery made with milk powder and vegetable oil. Is this a composite product? Is it subject to veterinary checks?

It is a composite product. It is subject to veterinary checks. As the final composite product requires refrigeration, to be exempt from veterinary checks the final composite product must have been cooked or undergone a heat-treatment sufficient to denature the milk powder. This is not possible for ice cream confectionery. Pasteurisation of the final mix would not be sufficient to denature the animal-origin constituents.

Can you give me some examples of composite products which are subject to veterinary checks?
  • Meat pie (containing cooked meat)
  • Canned tuna salad (contains tuna combined with vegetables to make a salad)
  • Chicken curry (pieces of cooked chicken combined with vegetables in a sauce)
  • Prawn spring roll containing 50%+ cooked prawn
  • Pizza containing uncooked pasteurised cheese, (because it requires refrigeration, and the final product not cooked)
  • Gateau with a layer of pasteurised cream (because requires refrigeration and final product with cream in place has not been cooked).
  • Cup noodle containing meat powder
  • Biscuits, confectionery, butter toast with a dairy content from an unapproved country
Can you give me some examples of composite products which are not subject to veterinary checks?
  • Fully cooked pizza with less than 50% cheese and no meat (providing dairy content is from an approved source)
  • Fully cooked prawn spring roll with less than 50% prawn
  • Mayonnaise with less than 50% pasteurised egg content
  • Biscuits, confectionery, butter toast with a dairy content from an approved country (provided there is no meat product content and the combine egg and dairy content is <20%)
Can you give me some examples of foodstuffs containing plant material which are not composite products but are processed animal products containing plant material?
  • Uncooked meat pie containing raw meat (not a composite product because meat is raw)
  • Breaded raw prawns (not a composite product because prawns are raw)
  • Honey with nuts (not a composite product because honey is raw)
  • Canned tuna in oil (plant material essential for manufacture)
  • Cooked tuna fillets in a chilli marinade (marinade adds specific characteristics - flavour, texture - to the tuna)
  • Cooked breaded prawns (breading gives specific characteristics to prawns; applies regardless of % prawn)
  • Surimi/ crabsticks (a small amount of plant product is sometimes added to give specific characteristics to the fish content)
  • Breaded cooked haddock (breading gives specific characteristics - texture - to fish)
  • Battered chicken nuggets (batter gives specific characteristics - flavour, texture - to the chicken)
  • Corned beef containing glucose or small amounts of onions (glucose/onions give specific characteristics to corned beef)
  • Strawberry yoghurt (strawberries give specific characteristics - flavour, texture - to the yoghurt)
  • Milk dessert with a fruit topping (fruit topping adds specific characteristics  - flavour, texture - to the milk dessert) 
  • Battered cooked cheese e.g. 'paneer poppers' (batter gives specific characteristics - texture - to the cheese; applies regardless of % cheese)
  • Fish sauce with 10% fishery product content, other ingredients are sugar and water. This is a fishery product (no relevant plant material to make it a composite product). Subject to vet checks as a fishery product - the 50% rule applies only to composite products
  • Yogurt drink like Yakult containing water, 2% skimmed milk powder and sugar. This is a dairy product. There is no relevant plant material to make it a composite product
  • Gulab Jamun, Rasgulla and similar canned products from India. These consist of cottage cheese balls (@5%) in syrup in a can. These are dairy products (no relevant plant material) and cannot be imported from India

Need Help?

We are happy to provide advice in cases where you are not sure whether a product is a composite product or not?  To be able to advise we will require:-

Contact Us 

Page last updated: 23/01/2017

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Related Web Links

  • Animal Health
    Animal Health, now part of the Animal and Plant Health Agency (APHA) are a government agency responsible for overseeing the delivery of POAO controls at BIPs.

    General enquiries about imports of POAO should be directed to their helpline:

    General enquiries email:
    Telephone: 01228 403 600

  • Border Inspection Post Manual - Veterinary Checks
    The BIP Manual provides information and guidance on the application of veterinary checks. It is aimed at enforcement officers.
  • Commission Regulation (EC) No 178/2002
    Overarching Council Regulation laying down general principles of food law. Sits above the Regulation 882/2004 and Commission Decision 97/78(EC)
  • Customs Tariff/Commodity Codes

    CN codes can be checked online using the trade tariff on the website.

  • Defra - import of animal products

    Department for the Environment, Food and Rural Affairs (DEFRA) - are the government department responsible for policy in relation to imports animal products.  APHA provide import guidance to trade on their behalf.

  • Defra Animal Health (Personal Imports)

    The site contains guidance on products that travellers can bring back for personal use.

  • EU Food Safety Website
    The European Commission generates almost all of the legislation that is applied to imports to ensure smooth functioning of the internal market and as part of their commitment to make Europe's citizens healthier and safer. They have their own website Europa where they provide information about EU policy.
  • EU Law EUR-Lex search
    The European Commission generates almost all of the legislation that is applied to imports to ensure smooth functioning of the internal market and as part of their commitment to make Europe's citizens healthier and safer. They have their own website Europa  where they publish legislation. New legislation is published daily in the Official Journal.
  • Food Standards Agency - Imported Food Information
    The Foods Standards Agency (FSA) lead on policy affecting imports of fish and other food safety and standards controls. The Imported Food Branch provide a helpline for general enquiries about food imports who can be contacted by email
  • Her Majesty's Revenue and Customs (HMRC) Clearances

    HMRC Her Majesties Revenue and Customs are responsible for ensuring that controlled consignments from third countries have undergone border checks and the charges have been paid before releasing consignments for import.

  • Sign up for POAO updates from Defra
    Request Defra updates on changes to rules on imports and EU trade in animals and animal products [Link opens GOV.UK site]