Composite food products impacted by new EU rules from 21 April 2021

15 March 2021

The impact of Brexit is becoming clearer, which is allowing for businesses to plan and mitigate risks. However, as with any evolving situation, the odd curve ball gets thrown in. One such issue has taken many of our clients by surprise.

Many businesses are struggling to prepare for new EU rules relating to the import and export of composite food products. This is due to the relatively short timelines, specifically a pending deadline of 21 April 2021.

The new rules will affect third countries like the UK significantly. They are anticipated to increase requirements for export health certificates considerably, which will in turn have a knock-on effect to the already strained situation at the Irish sea border.

What is a composite food product?

Composite food products are defined in the legislation as “food containing both products of plant origin and processed products of animal origin”, a pretty broad definition including many of the foods we eat on a regular basis. This will affect many categories of food products which contain ingredients such as milk, egg, meat or fish to name but a few. Examples of shelf-stable composite products include cakes, biscuits and chocolate.

The impact on the food industry

The legislation (and draft amendments) set out requirements for a “private attestation” document to be provided with shelf-stable composite products. This document (in draft form) has two sections – the first has approximately 60 data points to fill in, the second part about 10 data points including the necessary signatures. If you add in mixed consignments of products and different batches of products, this adds up to a potentially massive administration burden. The impact to the food industry in terms of additional cost and transit time could be considerable, running into millions of pounds.

As with most of the legislation in this space, the rules are complex with various exemptions and definitions that will have to be looked at carefully. This is a challenge even for well-prepared businesses and experienced regulatory professionals. The main burden is likely to be on the shoulders of smaller businesses who don’t have the specialist resources to manage these new processes.  

There is a real possibility that these rules will cause some companies to see such exports as non-viable, which could be particularly bad news for consumers in mainland Europe, Ireland and Northern Ireland.   

Need support?

Leatherhead Food Research is monitoring the situation as it develops and working with clients to try and mitigate business impacts. If you have any questions or need guidance on the new regulation, please get in touch at [email protected]. Remember, if you’re a Leatherhead Member you can use your Helpline allocation for support on Brexit related issues.


  • Luke Murphy - VP Key Accounts, Leatherhead Food Research


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