Private attestations

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From 21st April 2021 for Composite Products:

Where a health certificate had been required for a certain composite product prior to 21 April 2021, a transition period is provided by Article 35 of Commission Regulation (EU) 2020/2235* . This allows for existing certificates to be used until 20 October 2021. These certificates must have been issued prior to 21 August 2021. For products where no certification was previously required the new rules apply in full from 21 April 2021.

The EU Commission have developed a comparative table to detail the effect of the transition established by Article 35 of Commission Regulation (EU) 2020/2235* on the imports of composite products into the EU after 21 April 2021 and until 20 October 2021, available here .

Article 12 of Commission Delegated Regulation (EU) 2019/625 establishes three categories of composite products based on risk:

1. Non-shelf stable composite products 

2. Composite products that contain any quantity of meat products, except gelatine, collagen and highly refined products, and 

3. Shelf stable composite products that do not contain meat products, except gelatine, collagen and highly refined products.

Composite products that fall into the higher risk categories (categories 1+2 above) must be accompanied by a health certificate, EHC 8350 *. For products previously requiring a health certificate the transition period above applies. 

Composite products that fall into the lower risk category do not require a health certificate. However they must be accompanied by a private attestation drawn up in accordance with the model private attestation in Annex V of Commission Regulation (EU) 2020/2235* . The private attestation is to be completed by a representative of the importer.

*Commission Regulation (EU) 2020/2235

Note that lower risk products that contain dairy or egg, the dairy must have been subjected to a heat treatment at least equivalent to those detailed in Column B of Annex XXVII to Regulation (EU) 2020/692 Table 1 and the egg must have been subjected to a treatment as detailed in Annex XXVIII of Regulation 2020/692 Table 2.

Consignments of composite products referred to by the following CN codes are subject to official controls at the Border Control Post (BCP): 1517, 1518, 1601 00, 1602, 1603 00, 1604, 1605, 1702, 1704, 1806, 1901, 1902, 1904, 1905, 2001, 2004, 2005, 2101, 2103, 2104, 2105 00, 2106, 2202, 2208 [CN codes available in Annex I to Regulation (EEC) No 2658/87]

Consignments of certain very low risk composite products referred to by the CN codes in Table 3 may be exempted from official controls at the Border Control Post as long as they are 

- shelf-stable

- do not contain meat

- for products under these CN codes that contain dairy or egg, the dairy must have been subjected to a treatment at least equivalent to those detailed in Table 1 above and the egg must have been subjected to a treatment as detailed in Table 2 above to be considered exempt from Official Controls.

These exempted products must be accompanied by a private attestation to the place of destination, the point of release for free circulation in the Union, or the warehouses/premises of the operator responsible for the consignment.