Compsite Shelf-Stable Productsand Inspection Duty

EU regulation 2021/630 of 16 February 2021

EU Regulation 2021/632 of 13 April 2021

There is much uncertainty about when composite products with ingredients of animal origin must be inspected or not.

Therefore, when importing foodstuffs, make sure you check what type of product it is, under which CN code it falls, what the ingredients are and how it is packaged.

Ask your supplier if necessary and do this early to avoid problems and delays.

Here you will find information that clarifies when products are exempt or not.

According to Regulation 2021/632, all products from the CN codes listed here that contain animal components must be inspected.

This includes composite products (foodstuffs).

The ingredients are fish, meat, egg and milk products.

According to regulation 2021/630, these products are exempted from inspection:

The shelf-stable composite products listed in the annex of the mentioned CN codes that do not contain processed meat provided that they comply with ALL of the following conditions:

(PROCESSED FISH MAY BE INCLUDED PROVIDED THAT ALL THE CONDITIONS LISTED BELOW ARE MET)

(a) they comply with the requirements for entry into the Union set out in Article 12(2)(c) of Delegated Regulation (EU) 2019/625

(b) all the milk and egg products in the composite long-life products have undergone a treatment in accordance with Article 163(a) of Delegated Regulation (EU) 2020/692;

they can therefore be stored at ambient temperature and they have undergone risk mitigation treatments (sterilisation/pasteurisation/cooking, etc.)

(c) they are designated as intended for human consumption; and

(d) they are securely packaged or sealed..

 

Listed in the Annex:

GN-codes Explanation
1 2
1704, ex 1806 20, ex 1806 31 00, ex 1806 32, ex 1806 90 11, ex 1806 90 19, ex 1806 90 31, ex 1806 90 39, ex 1806 90 50, ex 1806 90 90 Confectionery (including sweets), chocolate and other food preparations containing cocoa meeting the requirements of Article 3(1)
ex 1902 19, ex 1902 30, ex 1902 40 Pasta, noodles and couscous meeting the requirements of Article 3(1)
ex 1905 10, ex 1905 20, ex 1905 31, ex 1905 32, ex 1905 40, ex 1905 90 Bread, pastry, cakes, biscuits, waffles and wafers, rusks, toasted bread and similar toasted products which comply with the requirements of Article 3(1)
ex 2001 90 65, ex 2005 70 00, ex 1604 Olives stuffed with fish complying with the requirements of Article 3(1)
2101 Extracts, essences and concentrates, of coffee, tea or maté and preparations with a basis of these products or with a basis of coffee, tea or maté, meeting the requirements of Article 3(1) Roasted chicory and other roasted coffee substitutes, and extracts, essences and concentrates thereof, which meet the requirements of Article 3(1)
ex 2104 Soup stocks and flavourings packaged for the final consumer which meet the requirements of Article 3(1)

 

Notes:

Regulation 2021/632 states that products containing processed fish or meat must be inspected.

Products which fall under the CN codes mentioned in the annex of 2021/630 are exempted from inspection if they do not contain processed meat (via is allowed here) and they comply with the set conditions.

CN code not attached CN code attached terms and conditions Complying with Inspections
Products with meat V N/A Yes
Products with meat V N/A Yes
Products with fish V N/A Yes
Products with fish V No Yes
Products with fish V Yes No
Products without meat V N/A No
Products without meat V Yes No
Products without meat V No No
Products without fish V N/A No
Products without fish V Yes No
Products without fish V No No
Products with meat V N/A Yes
Products with meat V N/A Yes
Products with fish V N/A Yes
Products with fish V No Yes
Products with fish V Yes No
Products without meat V N/A No
Products without meat V Yes No
Products without meat V No No
Products without fish V N/A No
Products without fish V Yes No
Products without fish V No No

Sauces:

CN code 2103 is listed in regulation 2021/632 as subject to inspection (only if containing products of animal origin)

CN code 2103 is not listed in Regulation 2021/630, which means that all sauces containing fish or meat are subject to inspection; there are no exceptions.

Soups and preparations for soups:

CN code 2104 is listed in regulation 2021/632 as subject to inspection (only if containing products of animal origin)

CN code 2104 is also listed in Regulation 2021/630 with the comment that products packaged for the final consumer, bouillons and flavourings that meet the requirements of Article 3(1) are exempt and do not need to be inspected.

Make sure that you receive ingredient lists from your supplier well in advance.

On the site ivo.nvwa.nl you can fill in the tool and check whether your products are subject to inspection.

Make sure that you issue a private declaration for the products you are importing.

At the end of the check in this tool you can download the form with the private declaration.

You must complete this and send it to us so that we can submit it to the NVWA upon import. It concerns spvk012022

Below you will find a blank private declaration to be completed and submitted for products for human consumption.

We would like to point out that a new regulation (EU 2022/1219 of 14.07.22) has already been ratified which states that from 15 April 2023, an original official health certificate, signed by a veterinarian, will be required in place of the private declaration.