EU Food Safety: Animal Ingredient Rules for Exporters

I.Summary of Notification Details

1.1 Notification Background

Output:

Since 2024,the EU’s Rapid Alert System for Food and Feed (RASFF) has repeatedly reported that processed composite foods exported from China to the EU have been found to contain animal-derived ingredients such as pork,beef,and chicken,resulting in customs detention,market recalls,and confiscation of exported products.These reports mainly involve daily consumer goods such as instant noodles and flavored french fries.To help export enterprises understand the regulatory requirements behind these issues,this article will provide a detailed interpretation of the EU’s complex and stringent requirements for animal-derived ingredients in processed composite foods.

1.2 Summary of Notification Data

Output:

According to the data reported by RASFF,between January and March 2024,the frequency of notifications of processed composite foods in China due to the illegal addition of animal-derived ingredients reached as high as 17 batches,with Italy being the main country of notification.The following are the specific details of the notifications:

From these data,it can be seen that EU member state Italy frequently reports processed composite foods exported from China,with the main reason being the addition of animal-derived ingredients not approved by the EU,thus deemed as illegal additives.

II.The "Access" Secret Behind the Notification

2.1 Definition and Classification of Processed Composite Foods

Output:

Processed composite food refers to food products containing both animal-derived and plant-derived ingredients simultaneously.Determining whether a product falls into this category requires attention to the following key points:

• Requirementsforhandlinganimal-derivedingredients:Animal-derivedingredientsmustundergoprocessing;productscontainingunprocessedanimal-derivedingredientsarenotconsideredcompositefoods.Forexample,porkdumplingsusingrawporkwouldnotbeclassifiedascompositefood.
• Functionofplant-derivedingredients:Plant-derivedingredientsmustplayasubstantiveroleintheproduct,notmerelyserveasdecorationorseasoning.Forinstance,cuminincuminsteakonlyfunctionsasseasoningwithoutalteringtheproductsnature,thustheproductremainsananimal-derivedfood.

Based on whether special storage conditions are required,the EU categorizes processed composite foods into the following three types:

• Compositefoodsrequiringrefrigeratedstorage
• Ambient-stablecompositefoodscontainingprocessedmeatingredients
• Ambient-stablecompositefoodswithoutprocessedmeatingredients

Most food products notified from China belong to ambient-stable composite foods containing processed meat ingredients.Below we focus on analyzing the EUs market access requirements for importing such foods.

2.2 Export Regulatory Basis Requirements

Output:

The EU implements different import control measures for products from different countries,with stricter access thresholds for higher-risk products based on the exporting countrys animal disease status,plant disease status,and official supervision level.Specific regulations include:

• (EU)2022/2292:RequirementsfortheentryintotheUnionofconsignmentsofcertainanimalsandgoodsintendedforhumanconsumption
• (EU)2016/429:AnimalHealthLaw
• (EU)2017/625:OfficialControlsRegulation
• (EU)2021/405:ListofthirdcountriesauthorizedfortheentryintotheUnionofanimalsandproductsofanimaloriginintendedforhumanconsumption
• (EU)2021/404:ListofthirdcountriesauthorizedfortheentryintotheUnionofanimalsandproductsofanimalorigin
• (EU)2022/2293:Approvedresiduemonitoringplansofthirdcountriesforcertainhazards
• 2002/994/EC:Safeguardmeasuresforanimal-derivedfoodsexportedfromChinatotheEU

According to these regulations,the EU implements strict access reviews for primary processed animal-derived products and animal-derived ingredients in composite foods.For ambient-stable composite foods containing processed meat ingredients exported from China to the EU,the main requirements are as follows:

A.Requirements for producing countries

The producing country must be EU-approved for exporting meat products to the EU and may use raw materials from its own country or other EU-approved countries.Currently,Chinas pork,beef,mutton,and horsemeat have not obtained EU export rights.Only processed poultry meat from Shandong Province can be exported to the EU under specific conditions (such as poultry vaccination,meat heat treatment processes,etc.).Therefore,composite foods containing bovine,porcine,or ovine ingredients produced by Chinese manufacturers cannot.

B.Requirements for overseas manufacturing establishments

For composite foods exported to the EU,the animal-derived ingredients must be sourced from manufacturing establishments in EU member states or third countries approved by the EU.Enterprises must ensure animal-derived ingredients come from EU-approved establishments and provide reasonable and accurate documentation in accompanying export files.

Additionally,manufacturers exporting composite foods do not need EU registration but must ensure product compliance,including production processes,formulations,labeling,packaging materials,etc.and provide accompanying documents such as importer self-declarations or official certificates.

III.How to Avoid the "Pitfalls" of Market Entry

3.1 Clarify Product Categories

Output:

First,clarify whether the product is a processed composite food or an animal-derived food.If it is a processed composite food,ensure that the animal-derived ingredients have undergone processing and play a substantial role in the product.

3.2 Ensure Raw Material Compliance

Output:

Ensure that the animal-derived ingredients in composite foods meet the following requirements:

• Productioncountryrequirements:Ifcompositefoodscontainingpig,cattle,orsheep-derivedingredientsareused,itmustbeensuredthattheseingredientsoriginatefromcountriesapprovedbytheEUforexport.
• Supplierqualifications:Ensurethatthesuppliersofanimal-derivedingredientshaveobtainedEUapprovalandprovideaccompanyingdocumentationprovingtheircompliance.

3.3 Seek Professional Support

Output:

If companies are unable to determine whether they meet EU access requirements,they can seek technical support from professional third-party institutions to ensure compliance in production,formulation,labeling,and packaging materials,avoiding economic losses and market share decline due to non-compliance.