On 04 June 2026, the European Commission published Commission Notice C/2026/3013 on the implementation of requirements for composite products. While this document does not introduce new primary legislation, it represents an important guidance document for food business operators (FBOs) exporting composite products to the European Union. It brings together existing legal requirements, clarifies regulatory interpretations, and provides practical examples to support more consistent application by competent authorities, Official Veterinarians (OVs), and food businesses.

For many years, composite products have presented complex export certification challenges. Determining whether a foodstuff qualifies as a composite product and identifying the correct certification model or border control requirements, has often resulted in differing interpretations between EU Member States. Notice C/2026/3013 aims to address this uncertainty by providing further clarification on how the existing rules should be applied.

In this article, our National Technical Lead for Exports, Georgios Kakarantzas, looks at the new guidance in detail.

From Percentage to Risk-Based Assessment

Historically, many exporters relied on the percentage of processed products of animal origin (PPOAO) contained within a product when assessing classification.

However, since the entry into force of the Animal Health Regulation (“Animal Health Law”), the percentage of PPOAO is no longer relevant for the categorisation of composite products. Instead, composite products are categorised strictly according to the risk they pose to animal and public health. Key assessment criteria include:

• Shelf stability (temperature requirements during transport and storage).
• Type of processed animal product used as an ingredient.
• Processing treatments applied (e.g., heat treatment, curing).
• Storage and handling conditions.

This approach reflects scientific assessments from the European Food Safety Authority (EFSA), which recognise that factors such as water activity, pH, storage conditions, and processing parameters are more important determinants of food safety risk than the percentage of animal-derived ingredients.

Categories of Composite Products

The Commission Notice introduces a five-category framework for classifying composite products, replacing the previous three-category framework presented in earlier Commission guidance. This new framework more accurately reflects the legal requirements applicable to the different categories of composite products. The five categories are as follows:

1. Non shelf-stable composite products.
2. Shelf-stable composite products containing any quantity of colostrum-based products or meat products.
3. Shelf-stable composite products containing processed products of animal origin (PPOAO), other than colostrum-based products or meat products, for which requirements are laid down in Annex III to Regulation (EC) No 853/2004.
4. Shelf-stable composite products containing only PPOAO or composite products falling within the scope of Regulation (EC) No 1332/2008 (food enzymes), Regulation (EC) No 1333/2008 (food additives), Regulation (EC) No 1334/2008 (flavourings and certain food ingredients with flavouring properties), or containing only vitamin D3.
5. Shelf-stable composite products containing PPOAO, other than colostrum-based products or meat products, for which no requirements are laid down in Annex III to Regulation (EC) No 853/2004, for example, a shelf-stable composite product containing only honey as its PPOAO.

This categorisation now forms the basis for determining the certification, supporting documentation and official control requirements applicable to composite products entering the European Union.

It is particularly noteworthy that composite products falling within Categories 4 and 5 require neither an Export Health Certificate nor a Private Attestation.

However, the Commission Notice makes clear that this exemption from certification does not remove the obligation to demonstrate compliance with the relevant hygiene requirements. Food business operators responsible for importing these composite products into the Union must be able to demonstrate, through appropriate commercial documentation, such as invoices, trade documents or product specifications, that the processed products of animal origin contained in the composite products comply with the applicable requirements of Article 6 of Regulation (EC) No 853/2004.

For shelf-stable composite products falling within Category 5, such as products containing only honey as the processed product of animal origin, the food business operator must ensure that the PPOAO complies with the requirements laid down in Article 6(4) of Regulation (EC) No 853/2004 and maintain appropriate supporting commercial documentation. Likewise, for products falling within Category 4, importers must be able to demonstrate that the PPOAO contained in the composite products satisfies the applicable requirements of Article 6(1) to (4) of Regulation (EC) No 853/2004 through appropriate commercial documentation.

Establishment Registration vs. Approval

An establishment that assembles ingredients to produce a composite product, using products of animal origin that have already been processed in other approved establishments, is required only to be registered with the competent authority in accordance with Regulation (EC) No 852/2004. Such establishments do not require approval under Regulation (EC) No 853/2004.

This includes establishments producing composite products by assembling processed products of animal origin (PPOAO) with ingredients of plant origin and applying only those processes necessary for the assembly of the final product, for example, the manufacture of biscuits.

However, where an establishment also processes an unprocessed product of animal origin, for which requirements are laid down in Regulation (EC) No 853/2004, before using it as an ingredient in a composite product, the establishment must be approved in accordance with Regulation (EC) No 853/2004.

The same requirement applies where an establishment carries out further processing of processed products of animal origin before incorporating them into a composite product. This also includes establishments performing animal health risk-mitigating treatments on products of animal origin prior to their use as ingredients in composite products.

Where approval is required, the establishment must be listed in the appropriate section of TRACES in accordance with the activity carried out.

Identification Marks

Article 5(1)(b) of Regulation (EC) No 853/2004 provides that, where Article 48 of Implementing Regulation (EU) 2019/627 does not require the application of a health mark, products of animal origin handled in establishments approved in accordance with Article 4(2) of Regulation (EC) No 853/2004 must bear an identification mark when placed on the market.

Composite products themselves are not required to bear an identification mark.

However, where a composite product is produced in an establishment approved in accordance with Regulation (EC) No 853/2004, the establishment may apply its existing identification mark to the composite product. This is permitted under point B.7 of Section I of Annex II to Regulation (EC) No 853/2004.

The use of the identification mark is not restricted to composite products containing the specific processed products of animal origin for which the establishment was approved. Article 1(2) of Regulation (EC) No 853/2004 provides that, unless expressly indicated to the contrary, the Regulation does not apply to food containing both products of plant origin and processed products of animal origin.

However, the processed products of animal origin used to prepare such food must be obtained and handled in accordance with the requirements of that Regulation. Therefore, where an establishment manufactures both food covered by Regulation (EC) No 853/2004 and food not covered by that Regulation, the same identification mark may be applied to both types of food.

Animal Health Requirements

Animal health remains the primary consideration for the entry of composite products into the European Union. Although the categorisation of composite products has changed, the underlying animal health principles and requirements applicable to the processed products of animal origin they contain remain unchanged.

The Commission Notice makes it clear that a composite product may only enter the Union if the processed products of animal origin (PPOAO) it contains comply with the applicable animal health requirements laid down in Delegated Regulation (EU) 2020/692. In particular, Article 162 of that Regulation requires that:

1. The processed products of animal origin contained in the composite product comply with all applicable animal health requirements for their entry into the Union.
2. The processed products of animal origin have been obtained either:

a) in the same listed third country, territory or zone as the composite product;

b) in the European Union; or

c) in a listed third country, territory or zone authorised for the entry into the Union of those products of animal origin without the application of a specific risk-mitigating treatment, provided that the third country, territory or zone where the composite product is produced is also listed for the entry of those products without the need for such treatment.

The practical effect of these rules is significant.

Where a processed product of animal origin requiring a specific risk-mitigating treatment is used in a composite product, the general rule is that it must originate from the same third country, territory or zone in which the composite product is manufactured. An important exception to this rule applies to certain shelf-stable composite products subject to a Private Attestation, as explained below.

Conversely, where the processed product of animal origin originates from a different third country than the one in which the composite product is manufactured, both countries must be listed for the entry into the Union of that processed product without the requirement for a specific risk-mitigating treatment.

The Commission Notice also clarifies the position for products of animal origin originating in the European Union that are exported to a third country for use in the manufacture of composite products before the composite product is exported to the Union. Where the third country is listed for the entry of those products only following the application of a specific risk-mitigating treatment, those Union-origin products must undergo the same risk-mitigating treatment in that third country before the composite product may enter the Union.

It is important to note that this specific risk-mitigating treatment must be carried out in an EU-approved/listed establishment, as provided for in Article 13 of Delegated Regulation (EU) 2022/2292.

An important exception applies, in accordance with Article 163 of Delegated Regulation (EU) 2020/692, to certain shelf-stable composite products containing dairy products, egg products, or both. For these products, the restriction set out above under point 2(c) does not apply. Consequently, the dairy products and/or egg products contained in the composite product may originate from a different listed third country, territory or zone that is authorised for the entry into the Union following the application of the relevant specific risk-mitigating treatment, provided that the conditions laid down in Article 163 are fulfilled. These products must be accompanied by a Private Attestation.

Public Health Requirements

Public health requirements remain equally important. The Commission Notice confirms that compliance with animal health requirements alone is not sufficient for the entry of composite products into the European Union.

Composite products must continue to comply with the applicable EU food safety legislation, including:

• General Food Law requirements.
• Food hygiene requirements.
• HACCP principles.
• Microbiological criteria.
• Residue monitoring requirements.

These public health requirements apply alongside the relevant animal health requirements and remain essential for composite products placed on the EU market.

Practical Examples Bring Welcome Clarity

One of the most valuable sections of the Notice is the collection of practical examples.

The Commission explains why products such as pizzas, biscuits containing butter and egg, or Caesar salads are considered composite products, while products containing unprocessed meat or fresh fish remain subject to Regulation (EC) No 853/2004 as products of animal origin.

These examples should help industry and competent authorities apply the legislation more consistently and reduce unnecessary disputes regarding product classification.

What Does This Mean for Exporters?

For exporters, manufacturers and certification bodies, this guidance is likely to become an important reference document.

Although the underlying principles of the legislation remain unchanged, the Commission has provided clearer explanations of how the rules should be interpreted and applied in practice.

Businesses should review their product classifications, certification routes and supporting evidence to ensure that they remain aligned with the clarified regulatory framework.

For Official Veterinarians, the document also provides a valuable framework for making certification decisions that are consistent with EU legislation and supported by an appropriate assessment of the relevant risks.

As international trade continues to evolve, clear and consistent guidance is essential. A consistent understanding of the requirements applicable to composite products benefits exporters, reduces uncertainty at Border Control Posts, and supports the protection of both animal health and public health throughout the food chain.

Georgios Kakarantzas

Georgios is our National Technical Lead for Exports, overseeing national standards and legislative changes for export certification. He has worked at E&J for over 20 years, starting as an OV in 2003, before moving to specialise in exports.