Since 2024, the Rapid alert System for Food and Feed (RASFF) of the European Union has repeatedly reported that processed composite food products exported from China to the EU, such as instant noodles and flavored French fries, have been found to contain animal-derived ingredients of porcine, bovine and chicken origin Most of the exported products are face with adverse situations such as official detention, market recall, and confiscation, which which are undesirable situations that exporters have to face. So, why the animal-origin components that are common and frequently used in China defined as illegal additives in processed composite foods in the EU? What are the regulations that exporters are not familiar with or are completely unaware of? In this article, Foodmate will reveal the complex and stringent requirements of the EU for the admission of animal-origin components in processed composite foods from a legal perspective, hoping to help everyone break through the export dilemma.

I. Summary of Notification Details

From January to March 2024, the frequency of notifications from the RASFF for China's processed composite products due to the detection of illegally added animal-origin components was as high as 17 batches, mainly from Italy, and the economic impact and losses are unknown. For example, Chinese noodles, instant noodles, snacks, potato chips, prepared dishes, etc. have been repeatedly notified by Italy of products containing illegally added bovine, porcine and avian ingredients in the process of exporting to the European Union, and most of the substandard products have been subjected to disposal measures such as confiscation, market recalls and official detention.

II. The "Access" Secret Behind the Notification

It can be seen from the above table that Italy, a member state of the EU, has recently frequently notified common foods in our daily life, such as noodles, instant noodles, snacks, chips, meat soup, and seasonings, which are exported from China. The reason for the notification is single and concentrated: the addition of bovine and porcine components in the products is considered illegal because they have not been approved by the EU. Why are porcine and other animal-origin components that we often consume in our daily life frequently notified by Italy? In fact, this is not a problem with the quality and safety of animal-origin components, but that the export companies have not truly grasped the EU's admission requirements for animal-origin components in imported processed composite foods.

III. Regulatory Requirements for Export

based on the animal epidemic, plant epidemic, and the level of official supervision of the exporting country, the EU adopts different import control measures for products from different countries. The higher the risk level, the stricter the access threshold. based on this principle, the EU has strict access reviews for primary processed animal-origin products such as beef, mutton, aquatic products, and animal-origin components in composite foods. 

The review is mainly based on (EU) 2022/2292 "Regulations on the requirements for the entry of food animals and certain goods for human consumption into the EU" (approved the list of products allowed to enter the EU), (EU) 2016/429 "Animal Health Law" (involving animal epidemics and welfare), (EU) 2017/625 "Official Control Law" (public health and welfare), (EU) 2021/405 "List of countries allowed to export animals and their products for human consumption to the EU", (EU) 2021/404 "List of countries allowed to export animals and their products to the EU", (EU) 2022/2293 "Approved third-country residue monitoring plans" and specific access conditions for China 2002/994/EC "Protective measures for animal-origin food from China exported to the EU", etc. At the regulatory level, the categories of products permitted to be exported to Europe are comprehensively defined, as well as the various mandatory market access conditions to be met, including national access, overseas manufacturer registration, etc. For composite food products containing processed meat ingredients such as seasonings, instant noodles, potato chips, etc., which are stored at room temperature and exported from China to the EU, the animal-origin components should meet the following access requirements:

a.Production Country Requirements: It must be a country approved by the EU to export meat products to the EU, and can use raw materials from its own country or other EU member countries or other EU-approved countries. In layman's terms, if meat is used in composite foods, the country where the production company is located must be approved to export that kind of meat to the EU. Currently, China's pork, beef, mutton, horse meat, etc. have not yet obtained the autority to be exported to the EU. only processed poultry meat from Shandong Province can be exported to the EU under certain conditions, including poultry vaccination, meat thermal processing technology, and other requirements. Therefore, composite foods produced by Chinese enterprises containing bovine, porcine, and ovine components (regardless of the content) cannot be exported to the EU. Therefore, the EU has repeatedly notified that bovine and porcine components were detected in composite foods exported from China.

At present, the animal-origin products that approved to be exported from China to the EU include the following 7 categories: rabbit meat, processed poultry meat, aquatic products, sausage casings, egg products, gelatin, and collagen. In theory, China's processed composite foods containing these 7 categories of animal-origin components can be exported to the EU.

b. Overseas manufacturers Requirements: For composite foods exported to the EU, in addition to meeting the above production country access requirements, the animal-origin components should also be purchased from enterprises in EU member states or third countries approved by the EU. In layman's terms, animal-origin components must come from enterprises approved by the EU, and the list of approved enterprises can be found on the official EU website. For example, if need to use chicken meat, and if domestically produced chicken meat is used in the product, it must be sourced from Shandong enterprises approved by the EU; if imported raw materials are used, it is imperative to ensure that the supplier has been approved by the EU and to provide reasonable and accurate proof in the accompanying export documents. The EU's notification mentioned that China's exported composite food contains chicken and poultry ingredients, which is presumably due to the exporting production enterprises being unable to prove that their raw materials come from enterprises approved by the EU.

Furthermore, it should be clarified that composite food exporting enterprises do not need to be registered in the EU, but they should ensure that the product complies with regulations (production process, formula, labeling, packaging, etc.), and that the accompanying documents such as the importer's self-declaration or official certificate are complete and qualified.

IV. How to Avoid the Hassles of Access

based on the above analysis, if Chinese enterprises plan to export processed composite foods to the EU, it is recommended to control risks according to the following points:

Firstly, clarify whether the product belongs to processed composite foods or animal-origin foods.

Secondly, after determining the category, for the animal-origin components in composite foods: first, it is essential to clarify whether there are restrictions on the exporting production country, such as China's composite foods containing animal-derived ingredients of porcine, bovine and chicken origin are not allowed to be exported to the EU; second, even if the enterprise uses animal-origin components that have been approved for export to the EU, it must ensure that the corresponding animal-origin raw materials supplied by aquatic products and poultry suppliers approved by the EU, ensuring that the supplier's qualifications are legal and compliant, thereby minimizing the export risk at the source.

Additionally, if you are not sure, you can also seek technical support from Foodmate via global_info@foodmate.net.