UK manufacturers of multi-ingredient food products are bracing themselves for a fresh wave of EU import controls this month.
There is concern that the new rules on composite food products, which came into force from 21 April, will result in more laborious paperwork and costly delays at ports.
Many more products that contain processed meat and dairy ingredients – such as pizzas and lasagnes – may require export health certificates (EHCs) and veterinary checks.
So it’s crucial that UK food exporters have a clear understanding of the new requirements to minimise disruption when the new rules take effect in a few days’ time.
The requirement for health certificates will no longer be based on the quantities of meat, milk and other products of animal origin in multi-ingredient foods. Instead, it will depend on the animal or public health risk linked to those ingredients and the way they are transported or stored.
The 50% threshold for dairy ingredients is being scrapped so all products containing milk, yoghurt, butter and cheese that are not shelf-stable, will require an EHC.
So, for example, a ham pizza made with processed meat is not shelf-stable and will need a health certificate stamped by a vet. The same applies to vegetarian pizzas that only contain cheese and which require refrigeration.
But if your shelf-stable food product doesn’t contain any processed meat, it is automatically classed as low risk. And if you manufacture certain sweets, chocolate, pasta, bread, cakes, biscuits or soups, for example, then these may be exempt from official inspection at EU border control posts altogether.
Bear in mind, however, that to qualify as exempt, products must be produced in EU factories or located in third countries like the UK that are authorised for importing into Europe.
Knowing whether you need an EHC, selecting the right certificate if you do, and completing and certifying it correctly will be essential if you want to prevent border delays and the risk of food spoiling.
Bear in mind that under the new rules, the EU or Northern Ireland import agent must complete a private attestation for exports of exempt products.
Don’t forget that you still need to follow existing export formalities too. So, as well as your export health licence, you must file an accurate customs declaration, issue the correct invoice for international trade, ideally with a statement of origin to claim preferential duty.
You’ll also need to include the right packing list alongside your transportation documentation, such as a CIM consignment note. And you may need to provide proof of insurance too.
There’s no escaping the fact that the new rules on composite food products will add extra layers of bureaucracy on food exports to the EU. But having a clear understanding of the new requirements – and what you need to provide - will help you minimise disruption and avoid costly delays.
Steps to avoid export costs
According to Mielken, you can avoid falling foul of the new EU food rules by following these ‘essential steps’:
- Identify which category your product falls into: shelf-stable or non-shelf-stable.
- Establish what meat or meat products are present in your products.
- Check if you are exempt from needing an EHC. If you are, remember you need to provide your driver with the necessary evidence and customs declarations to avoid delays.
- Identify the right EHC for your products. You can find the new and old set of health certificates here: https://www.gov.uk/export-health-certificates?keywords=composite+product
- Ensure your certificate is completed correctly and properly certified by a vet.
- Make sure the consignment is registered in the EU Commission’s Trade Control and Expert System (TRACES) before shipment.
- Ensure the transport operator exporting the goods out of the UK has the complete and correct paperwork.