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European Union (EU) - Export requirements for composite products

The information presented below is under review.

On this page

  1. Eligible/ineligible product
  2. Pre-export approvals by the competent authority of the importing country
  3. Production Controls and Inspection Requirements
  4. Labelling, packaging and marking requirements
  5. Export documents available upon request
  6. Additional information

According to Commission Delegated Regulation (EU) 2019/625 'composite product' means food containing both products of plant origin and processed products of animal origin. Please note that a composite product (CP) cannot contain an unprocessed animal product.

It is important to note that the addition of a product of plant origin during the processing defined in Article 2(1) (m) of Regulation (EC) No 852/2004 of an animal product does not automatically mean that the resulting food falls within the definition of composite products. If the addition of the plant product to the processed product of animal origin during the manufacturing procedures does not modify the main characteristics of the processed product of animal origin, the final food product is not a composite product. Pizza with salami and cheese and chicken Caesar salad containing chicken and parmesan cheese are examples of composite products.

1. Eligible/ineligible product



2. Pre-export approvals by the competent authority of the importing country


The EU has not yet established a specific list of establishments of third countries authorized to export CPs to the Union.

The CPs that fall under the HS codes listed on the model certificate for export of CP and which contain processed product of animal origin (POAO) can be exported to the EU if each processed POAO contained in the CPs has been produced in an establishment on the list administered by the Directorate-General of Health and Food Safety (DG-SANTE). The third country lists are available on the EU website, Third Country Establishments - List per Country. Please click on "Canada" for the Canadian establishments, or the country for the imported products to see the associated documents.

3. Production controls and inspection requirements

The CPs requiring an export certificate must originate from an establishment licensed under the Safe Food for Canadians Regulations (SFCR) with a CFIA establishment identification number and must be operated in accordance with the requirements applicable to the commodity of POAO used in the production of the CPs, for example, meat products, dairy products, fishery products.

The CP must come from an establishment licensed under the Safe Food for Canadian Regulations (SFCR) with a preventive control plan in place which is deemed to meet the EU requirements under Article 5 of Regulation (EU) No 852/2004.

The inspector must verify during a preventive control inspection that the manufacturer is aware of the standards and requirements of the EU and has a specific manufacture and export procedure in place. This procedure should clearly refer to the relevant EU regulations (see section 6 below), particularly regarding the controls for the eligibility of the processed POAO used in the manufacture of the CP and the traceability controls regarding the eligibility of the processed POAO to ensure only compliant CP are exported to the EU.

Processed products of animal origin – eligibility

The eligibility of processed meat products other than gelatine, collagen and highly refined products (HRP) should be determined as per Export requirements for meat intended for export to the EU. For example in the case of products received from another Canadian producer, the load of processed meat product should be accompanied by Annex J.

The eligibility of the dairy products or colostrum-based products contained in the CPs should be determined according to the export requirements of dairy products to the EU.

The eligibility of the fishery products contained in CPs must come from an establishment authorised to export to the EU as well as the country of origin. In case of fishery products derived from bivalve molluscs the country of origin must be authorised for entry into the Union of live bivalve molluscs.

The eligibility of the egg products in the CPs should be determined according to the export requirements of egg products to the EU.

Manufacturer's declaration

Imported ingredients of animal origin

The use of imported ingredients from certain countries may limit the ability to export to the EU. Commission Implementing Regulation (EU) 2021/404, Commission Implementing Regulation (EU) 2021/405 and the lists of EU approved establishments can be consulted to verify the eligibility of imported products.

Note: if the CP contains both processed meat products and other POAO, than the eligibility requirements for both must be met.

4. Labelling, packaging and marking requirements

Exported products depending on their final destination must meet certain packaging and labelling requirements. The exporter must work closely with the importer to ensure the compliance of their products.

5. Export documents available upon request

It is the responsibility of the exporter to ensure that the issued certificate meets the requirements of the entry border control post (BCP)/member state of destination in terms of official language.

As a manufacturer/exporter and in order to facilitate the certification process, it is important that you are familiar with the content of parts I and II of the EU model certificates.

The export certificate will be issued through TRACES. The applicant must select the EU model certificate that corresponds to the product intended for export and complete Part I. Please note that the applicant is responsible for the details entered in Part I of the certificate. In addition, the applicant will need to include the EU reference IMSOC number (Box I.2.a of Part I of the certificate) with their export request in order for the CFIA to retrieve the certificate in TRACES.

Part II must be completed by an official veterinarian or an official inspector, depending on the case. However, some information will have to be provided by the applicant in order for Part II to be completed, if applicable. This information should be provided in the form of a manufacturer's declaration when applying for an export certificate.

These animal health/official certificates shall be completed according to the notes for the completion of certificates provided for in Chapter 4 of Annex I to Implementing Regulation (EU) 2020/2235 as well as the notes on the export certificates.

For more information about TRACES, please refer to the CFIA web page Exporting food and animal products to the European Union.



For animal health reasons, guarantees shall accompany shipments of composite products that are either not shelf-stable or that are shelf-stable and contain meat products (other than gelatine, collagen or highly refined products) exported to a third country that will transit in the Union or that will be temporarily stored in the Union. The above TRANSIT-COMP certificate should be issued at the request of exporters.

Other composite products, for example, those for which the above certification is not required (for example, shelf stable composite products that do not contain meat products, except gelatine, collagen and highly refined products) must be accompanied by a private attestation drawn up in accordance with the model private attestation in Annex V of Commission Regulation (EU) 2020/2235. The private attestation is to be completed and signed by a representative of the importer. The CFIA does not need to be involved in the issuance of this document.

6. Additional information

Exported products transiting through a third country may require transit documentation. It is the responsibility of the exporter to ensure that the shipment will be accompanied by all necessary certificates. Please work closely with your importer.

Samples (personal or commercial) of composite products may be subject to the same requirements as regular shipment. It is strongly recommended that the exporter verify these requirements with his importer and / or at the EU border inspection post where the products will be shipped.

Links to the EU regulation:

Please ensure that you are using the most up-to-date/consolidated version. See EUR-Lex, the official and most comprehensive online access point to the EU legal documents.

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