Composite products

Country
European Union (EU)
NPG Category
Edible
NPG Product
Edible processed goods

The following should be considered prior to updating establishment details:

  • When an establishment notifies the Department of an administrative change (that is, a change of occupier, company name, address, or in some instances product specific changes), the Department will amend the establishment record in the system.
  • The establishment's amended details will appear on applicable export documentation including health certification from the date that the Department amends the establishment record
  • When relevant changes are made to an establishment's details, the Department will advise trading partners that maintain establishment lists of the change of details; however, the Department is unable to guarantee a timeframe as to when trading partners will update the establishment's overseas listing details they maintain. This means that there may be a period in which export certification issued by the Department does not match the trading partner's official published listing, which may result in clearance issues at the port of entry.
  • Establishments should be aware that their ability to export to some countries may be impacted during this transition period and may include issues with goods in transit.
  • Exporters and manufacturers are encouraged to check that their establishment's details are recorded accurately where they appear on trading partners' lists and to contact the Department if errors are found.
Table 1: EU member states, dependencies and other European countries that adopt EU requirements

Relationship with the EU

Countries and territories

Member States

Austria (AT), Belgium (BE), Bulgaria (BG), Croatia (HR), Cyprus (CY), Czech Republic (CZ), Denmark (DK), Estonia (EE), Finland (FI), France (FR), Germany (DE), Greece (GR), Hungary (HU), Italy (IT), Latvia (LV), Lithuania (LT), Luxembourg (LU), Malta (MT), Netherlands (NL), Poland (PL), Portugal (PT), Republic of Ireland (IE), Romania (RO), Slovakia (SK), Slovenia (SI), Spain (ES), Sweden (SE)

Note
These Member States adopt all EU requirements for products that have been harmonised throughout the EU and may have additional requirements for products that are not yet harmonised.

EU dependencies

  • France: French Guiana (Cayenne) (GF), Guadeloupe (GP), Mayotte (YT), Martinique (MQ), Reunion Island (RE), and St Pierre and Miquelon (PM)
  • Portugal: Azores (PT), Madeira (PT)
  • Spain: Canary Islands (ES)
Note
These countries adopt all EU requirements for products that have been harmonised throughout the EU and adopt requirements of the country they are a dependency of for products that are not yet harmonised.

Other European countries that adopt EU requirements

Faroe Islands (FO), Iceland (IS), Liechtenstein (LI), the Republic of North Macedonia (MK), Norway (NO), United Kingdom (GB) (including Gibraltar (GI) and the Channel Islands) and Switzerland (CH)

Note
These countries may not adopt all EU requirements for products that have been harmonised throughout the EU.

Northern Ireland Protocol

Northern Ireland (GB)

1.1. Prohibited

Unless specified in the specific goods list below, the Department is not aware of any prohibited edible non-prescribed products, including apiculture products for this market.

1.2. Conditions

Government certification

Australian producers and exporters of animal products should understand and adhere to the requirements under Commission Implementing Regulation (EU) 2020/2235 concerning official certificates for certain animals and goods. In particular, the export certificate must be issued before the consignment departs Australia (Article 5).

Registration and Listing

Establishments that export edible products to the EU must be export registered with the Department and included on the lists on the European Commission's (EC) website, except for plant-based foods. Please see the specific goods section below.

Packaging requirements

Ban on use of PFAS in paper and cardboard food contact materials

Denmark has banned paper and cardboard food contact material containing per- and polyfluoroalkyl substances (PFAS) (for example, from recycled paper and cardboard or from printing inks), unless the food contact materials are separated from the food by a functional barrier which prevents the migration of PFAS substances to the food.

The ban came into effect from 1 July 2020.

Food processors may be asked by importers to demonstrate that materials in contact with foods such as non-prescribed goods do not contain any PFAS or if they do, are used with a functional barrier to ensure no migration to food can occur.

While Denmark is currently the only EU member state to take action on use of PFAS in food contact materials, it is noted that individual member states and the EU as a whole are considering risks associated with human exposures to PFAS and similar proposals may be made at a later date in other jurisdictions.

The Department encourages all exporters to work with their importer to ensure that product meets the current importing country requirements.

Labelling requirements

Exporters should be aware of European Union (EU) labelling requirements, including allergen statement requirements, as detailed in EU Regulation No 1169/2011.

Conditions

The European Commission (DG SANTE) has adopted a regulation setting a limit for the presence of trans fatty acids in food (two grams of industrially produced trans fat per 100 grams of fat). The new limit will apply to food intended for the final consumer and food intended for supply to retail in the European Union from 2 April 2021.

Residues

Export Destination Residues Warning – EU residue standards

Maximum residue limits (MRLs) or import tolerances for residues of specific agricultural and veterinary chemicals approved for use in Australia may not exist in the EU or may be established at levels lower than those established in Australia. Respective maximum limits (MLs) for contaminants may also vary between the EU and Australia.

Food business operators who are eligible to export to the EU should note that:

  1. a) These differences can be interrogated case-by-case by considering the EU standards (here for pesticides, veterinary drugs and contaminants) and the Australian standards (here for pesticides & veterinary drugs and here for contaminants).
  2. b) Any detection of a residue above the EU MRLs/MLs (if applicable) at the EU border would result in rejection of the consignment and trigger an information, alert and/or border rejection notification in the (public) EU Rapid Alert System for Food and Feed (RASFF).

Composite products are defined as products containing both products of plant origin and products of animal origin such as chocolate bars, biscuits, soups, frozen cakes and pies.

Commission Delegated Regulation (EU) 2019/625 stipulates the following categories for composite products:

  1. (1) non shelf stable composite products;
  2. (2) shelf stable composite products that contain meat products; and
  3. (3) shelf stable composite products that do not contain meat products.

A non shelf-stable composite product needs to be transported or stored under controlled temperature. It is not the case for shelf-stable composite products which can be kept at ambient temperature.

All processed products of animal origin (meat, dairy, eggs and fish), regardless of their percentage as an ingredient in the product, are required to be sourced from EU listed establishments to be eligible for import.

2.1 Import permit

Exporters are not required to obtain an import permit.

2.2 Listing and audit
Listing and audit procedureRequired?
AuditCurrent certificate of compliance for a Hazard Analysis and Critical Control Points (HACCP)-based food safety management program
Listing — Department's Establishment Register (ER)Yes
Listing — European Commission's (EC) websiteYes

Establishments that produce/process composite products to the EU and those establishment from which the animal origin ingredients are sourced must be listed on the European Commission's website. Listing of new establishments generally takes up to three months.

The processing establishment must be listed under Section IV of Animal By-products: Processing Plant. Refer to the current Establishment Lists.

In order to be listed on the European Commission's website, Australian producers and packers of composite products must be listed with the Department as EU eligible and have a current certificate of compliance for a HACCP-based food safety management program.

2.3 Prohibited products

Please note Australia does not currently maintain an EU approved residue plan for porcine or poultry and therefore is not permitted to export those commodities or products containing these ingredients to the EU. Australia does maintain EU approved residue plans for meat, dairy and fish products and can export these products, and products containing these ingredients, to the EU.

3.1 Government certification

The following export certificate is available as a manual only certificate.

This is completed and printed manually and then submitted to the department's regional offices for signature.

Certificate number
Title
Language
M492
(07/24)
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, highly refined products, or any quantity of colostrum-based products, and intended for human consumptionEnglish

The attestations on M492 (07/24) are crossed out based on the internationally recognised animal disease status of Australia and access and prohibitions on Australian commodities entering the EU. Refer to notes under 1.3 above, on prohibited products.

Formerly M492A (manual only) was issued for composite products transiting though the Union. A current version of this certificate is no longer available. If exporters are interested in having certificate template M492A made available, please contact the department.

Manufacturer's Private Attestation

This Attestation is for shelf stable composite products that do not contain meat products. 

It is required to be prepared and signed by the representative of the importing food business operator (in case of exemption from control at the border, it may accompany the products only at the time of the placing on the market)

The Private attestation is found in Annex V of Commission Implementing Regulation (EU) No 2022/2504. It is not an Australian Government document.

28/06/2023 - New case migrated from previous country page.