Composite products
Composite products are foodstuffs containing both products of plant origin and processed products of animal origin.
All raw materials of animal origin contained in composite products imported from outside the EU must come from establishments approved by the EU.
EU-approved establishments are non-EU country establishments authorised by the Commission for the entry into the EU territory of certain processed composite products of animal origin (including as regards the control of residues).
In addition, all dairy and egg products contained in composite products must meet the requirements set out in Article 163(1) of Commission Delegated Regulation (EU) 2020/692.
Read more about EU-approved establishments (europe.eu)
What to do when importing from outside the EU
Imports of composite products from outside the EU are usually controlled by the Finnish Food Authority. In that case, the products will undergo a border check at a border control post.
Some of the composite products are inspected by Customs.
Some of the composite products don’t undergo a border check, in which case Customs carries out an inspection. The inspection is carried out by Customs when
- the product doesn’t contain colostrum-based products or meat (except highly refined meat products, such as gelatine or collagen) and
- the product is shelf-stable and
- the commodity code of the product is listed in the annex to Commission Delegated Regulation (EU) 2021/630.
Examples: products containing small amounts of milk powder, such as a breakfast cereal product or muesli bar containing yoghurt.
For imports of composite products controlled by Customs, the importer needs a private attestation. Customs starts checking private attestations on 1 January 2025.
Send the completed form by email to Customs to the address kuluttajansuojelu@tulli.fi. or by Customs.
By following the guidance below step by step, you can find out the import requirements for the composite product and whether the import is controlled by the Finnish Food Authority
1. Is the product you are importing a composite product?
a. The product is controlled by Customs. You don’t need to go through the rest of the questions.
b. Continue to the next questions.
2. Does the composite product contain processed meat?
a. No. Continue to next question.
b. Yes. Check the guidance on the Finnish Food Authority’s website.
3. Is the composite product shelf-stable?
This doesn’t apply to composite products that are shelf-stable and that have to be transported chilled only due to their organoleptic characteristics, such as chocolate in hot weather.
a. No. Check the guidance on the Finnish Food Authority’s website
b. Yes. Continue to next question.
4. Is the CN code of the composite product listed in the Annex to Commission Delegated Regulation (EU) 2021/630 and is the description of the product in accordance with column 2 of the list?
a. The commodity code or the goods description doesn’t correspond to the products described in the Annex to the Regulation. Check the guidance on the Finnish Food Authority’s website.
b. The CN code and the goods description are listed in the Annex to the Regulation. Continue to next question.
5. Does the composite product contain e.g. processed milk, egg or highly refined meat products, such as gelatine or collagen?
If the composite product contains some of these raw materials, check Commission Delegated Regulation (EU) 2021/630 to see whether the raw materials have been treated appropriately.
a. No, the raw materials haven’t been treated appropriately. Check the guidance on the Finnish Food Authority’s website.
b. Yes, the raw materials have been treated appropriately. Continue to next question.
6. Have the appropriately treated raw materials of animal origin contained in the composite products been produced outside the EU in EU-approved establishments authorised for the entry into the EU of processed composite products of animal origin or in establishments located within the EU?
See the approved establishments outside the EU here
a. No, the raw materials haven’t been produced in approved establishments. Check the guidance on the Finnish Food Authority’s website.
b. Yes, the raw materials have been produced in approved establishments. Complete the form “Private attestation”.You can find the form and the completion instructions on this page.
What to do when importing from within the EU
- Customs also has the right to take samples of foodstuffs imported from within the EU. If asked, be prepared to give import details to Customs. Read more about sampling on the page Imports of foods and consumer goods (The link is not yet functional)
- Send the package labels of the product with the sample to the Customs Laboratory, if they are not on the product.