Holly Jade O'Leary
Export Shelf-Stable Composite Products from Great Britain to the European Union and Northern Ireland
Updated: Apr 13, 2022
When composite products that are shelf-stable and contain no meat are exported to the European Union, or moved to Northern Ireland, a private attestation will need to be completed by the importer or their agent. As the GB exporter, traders may wish to complete the form with the relevant information prior to their EU client signing the document.
A brief overview of how to export shelf-stable composite products from Great Britain to the European Union and Northern Ireland
1. If your factory processes products of animal origin, e.g. dairy, within your products, you must register for approved EU premises.
2. Obtain an importer's attestation form, and complete the relevant details, including providing a list of the categories of your ingredients for your EU client.
3. The EU importer or their agent must sign the importer's attestation.
4. Arrange an export declaration.
5. Providing that your consignment is exempt, no border control post-examination will take place. Checks may take place at the place of destination, subject to the local authorities.
Check if your shelf-stable composite goods are listed as: Exempt products
The following composite products listed in the annex to Commission Delegated Regulation (EU) 2021/630 are exempted from official controls at border control posts providing that:
a.) they comply with the requirements for the entry into the Union laid down in Article 12(2)(c) of Delegated Regulation (EU) 2019/625
b.) any dairy and egg products contained in the shelf-stable composite products have been subjected to treatment in accordance with Article 163(a) of Delegated Regulation (EU) 2020/692;
c.) they are identified as intended for human consumption; and
d.) they are securely packaged or sealed
The products may be subject to inspection at the place of destination. Composite products that are not shelf-stable, or that contain meat, require an Export Health Certificate and will be subject to border control post checks.
A model importer’s attestation is available from: Importer's Attestation
In the case of shelf-stable composite products containing only dairy or egg products, they may enter the EU if the processed dairy products and the processed egg products contained in the composite products have been subjected to a risk-mitigating treatment:
• Composite products that contain dairy products that have been treated with one of the two treatments referred to in column B of Annex XXVII to Commission Delegated Regulation(EU) 2020/692.
• Composite products that contain egg products that have been treated with one of the treatments referred to in Annex XXVIII to Commission Delegated Regulation(EU) 2020/692.
The trader's premises will need to be listed as an approved business with the EU if they process POAO within the composite product. Composite products do not need to be dispatched to the EU from approved establishments if the establishment of dispatch is simply assembling the product from pre-processed POAO.
GB exporters that process products of animal origin as part of the manufacturing process of the shelf-stable product, should apply for approved premises in accordance with requirements of Regulation (EC) No 853/2004 of the European Parliament and of the Council.
A list of approved premises is available from:
Details of how to apply for approval are available from: The Food Standards Agency.
The third country producing the composite product should either have an approved residue control plan for each of the ingredients of animal origin contained in composite product or it should source the animal ingredients from a Member State or from another third country which is listed in the Decision 2011/163/EU for those commodities.
Traders should note the following:
1.8 - Region of origin: At the time of publication, the region code “GB-0” applied to the United Kingdom (excluding Northern Ireland) for both consignments containing egg products and consignments containing dairy products.
For products containing dairy or egg content from outside of GB, the relevant region codes from EU legislation should be included additionally.
I.25 - Total quantity: This is not required as the relevant information is provided in I.24 (number of packages) and I.26 (total net weight).
The following fields are optional where the consignment is not subject to veterinary checks at an EU Border Control Post.
I.6 - Operator responsible for the consignment
I.13 - Place of loading
I.15 - Means of transport
I.16 - Entry Border Control Post
I.19 - Container number/seal number
Insight into completing Part II 4 and 5
4. The products contain the following list of products of plant origin and processed products of animal origin.
The importer will be able to attest to both of these statements on the basis of an ingredient list provided to them by the GB exporter. This should be in descending order of weight and include the nature (i.e. type of POAO or ‘product of non-animal origin’) of the ingredient and its percentage. Grouping certain ingredients by dairy products, fishery products, egg products, products of non-animal origin as relevant is allowed and this may be helpful to protect confidentiality of recipes.
5. The products contain processed products of animal origin, for which requirements are laid down in Annex III to Regulation (EC) No 853/2004 of the European Parliament and of the Council, originating from the following approved establishment….;
The importer will require the approval number of the establishment of origin of the composite product, if applicable, as well as approval numbers of the establishments that provided the processed POAO within the composite product. Composite products do not need to be dispatched to the EU from approved establishments if the establishment of dispatch is simply assembling the product from pre-processed POAO. In this scenario, an approval number for the establishment of dispatch does not need to be provided.
Fields will need to be completed by the EU Importer prior to the consignment entering the EU. In the case of products subject to veterinary checks at the Border Control Post the attestation will need to be available at the time the consignment reaches the EU BCP. You may wish to pre-populate Part I of the attestation and send it directly to your importer/agent for them to submit.
Signature – Part II of the attestation must be signed by a representative of the importing food business operator as defined in Article 14(1) of Commission Delegated Regulation (EU) 2019/625. The attestation cannot be signed by the GB exporter.
Further information is available from: Department for Environment, Food and Rural Affairs Guidance: Model private attestation by the operator entering shelf-stable composite products into the Union in accordance with Article 14 of Regulation (EU) 2019/625
For consultancy insight into exporting composite products from GB, please contact Alinea Customs email@example.com.