Mar 18th, 2021
7 mins
As highlighted in previous articles, on 21st April 2021, new Export Health Certificates (EHCs) will be required for exports of live animals and products of animal origin (POAO) to the EU. In total, there are 26 new export health certificates, 20 of which concern the export of live animals and 6 relating to POAO. 3 of the 6 POAO EHC’s relate to composites.
Final EU legislation for the live animal certificates is yet to be published. However, the EU legislation for the certifications for Products of Animal Origin (POAO) is available and therefore the EHC’s are now being developed with a target publication date of April 1st. These six EHC’s (as listed below) must be used from April 21st.
Note: There will be a potential increase in the number of composite products that require an EHC. Defra is currently developing guidance for businesses and will shortly issue more detailed information. Webinars are also being planned for industry on these changes. The EU’s legislation provides for a phased approach.
Defra plan to introduce the remaining new EHCs for animal products and live animals, as they are needed, by August 2021 when the switch needs to be complete.
Products of Animal Origin EHC’s to be used from April 21st
Composite Products (Export) – MODEL ANIMAL HEALTH/OFFICIAL CERTIFICATE FOR THE ENTRY INTO THE UNION OF NOT SHELF-STABLE COMPOSITE PRODUCTS AND SHELF-STABLE COMPOSITE PRODUCTS, CONTAINING ANY QUANTITY OF MEAT PRODUCTS EXCEPT GELATINE, COLLAGEN AND HIGHLY REFINED PRODUCTS, AND INTENDED FOR HUMAN CONSUMPTION
Composite Products (Transit) – MODEL ANIMAL HEALTHCERTIFICATE FOR THE TRANSIT THROUGH THE UNION TO A THIRD COUNTRY EITHER BY IMMEDIATE TRANSIT OR AFTER STORAGE IN THE UNION OF NOT SHELF-STABLE COMPOSITE PRODUCTS AND SHELF-STABLE COMPOSITE PRODUCTS CONTAINING ANY QUANTITY OF MEAT PRODUCTS AND INTENDED FOR HUMAN CONSUMPTION
Composite Products (Attestation) – MODEL PRIVATE ATTESTATION BY THE OPERATOR ENTERING SHELF-STABLE COMPOSITE PRODUCTS INTO THE UNION IN ACCORDANCE WITH ARTICLE 14 OF REGULATION (EU) 2019/625
Meat of certain farmed game – MODEL ANIMAL HEALTH/OFFICIAL CERTIFICATE FOR THE ENTRY INTO THE UNION OF FRESH MEAT INTENDED FOR HUMAN CONSUMPTION, EXCLUDING OFFAL, MINCED MEAT AND MECHANICALLY SEPARATED MEAT, OF ANIMALS OF THE FAMILY BOVIDAE (OTHER THAN DOMESTIC BOVINE, OVINE AND CAPRINE ANIMALS), CAMELID ANIMALS AND CERVID ANIMALS KEPT AS FARMED GAME
Meat of certain wild game – MODEL ANIMAL HEALTH/OFFICIAL CERTIFICATE FOR THE ENTRY INTO THE UNION OF FRESH MEAT INTENDED FOR HUMAN CONSUMPTION, EXCLUDING OFFAL, MINCED MEAT AND MECHANICALLY SEPARATED MEAT, OF WILD ANIMALS OF THE FAMILY BOVIDAE (OTHER THAN DOMESTIC BOVINE, OVINE AND CAPRINE ANIMALS), WILD CAMELID ANIMALS AND WILD CERVID ANIMALS
Porcine mechanically separated meat (MSM) – MODEL ANIMAL HEALTH/OFFICIAL CERTIFICATE FOR THE ENTRY INTO THE UNION OF MECHANICALLY SEPARATED MEAT, INTENDED FOR HUMAN CONSUMPTION, OF DOMESTIC PORCINE ANIMALS
Regarding composite products, we should also highlight to you that currently Article 6 of Commission Decision 2007/275/EC provides an exemption from certification that applies to certain composite products containing less than 50% of specified processed products of animal origin. This rule will be removed with the introduction of the new EHC’s meaning many more products will fall into scope of requiring a composite EHC.
Certification requirement will be based on the risk linked to the product itself and products will be categorised as follows:
- non-shelf stable composite products,
- shelf stable composite products that contain meat products
- shelf stable composite products that do not contain meat products.
The new requirements for a composite EHC will therefore be:
- ambient/chilled/frozen – EHC required for temperature-controlled products containing any non-shelf stable dairy or egg (must be from EU-approved countries)
- If contains processed meat products – EHC required
- If on an EU list of “lower risk products” (i.e. low risk shelf-stable composite products not containing processed meat) – EHC not required
This is outlined in a draft regulation and its accompanying annex here.
Note: the list of “lower risk products” is given in the Annex.
Article 2 also now clearly defines what a “shelf stable composite product” is:
‘shelf-stable composite products’ means products that do not need to be transported or stored under controlled temperatures.
