China authorised to export vitamin D3 to the EU

Commission Implementing Decision (EU) 2023/1016 of 22 May 2023 amending Decision 2002/994/EC concerning certain protective measures with regard to the products of animal origin imported from China

Update

Vitamin D3 (and its precursors) has been added to the list of animal products that can be exported from China to the EU.

Impacted Products

feed, vitamin D3

What is changing?

The EU has included vitamin D3 (and its precursors) in the list of animal products that can be exported from China to the EU without an attestation (Annex, Part I):

• for human consumption, in compliance with specific treatments for highly refined products (fat derivatives) (Regulation 853/2004, Annex III, Section XVI); or
• as a feed additive in accordance with Regulation 1831/2003 for feed for farmed animals and petfood, in compliance with Regulation 1069/2009.

Why?

Due to specific EU concerns regarding food imports from China, China may only export to the EU the animal products listed in Decision 2002/994/EC. As vitamin D3 has a low risk profile, it can be added to that list.

Timeline

Date of publication: 24 May 2023.

Date of application: 13 June 2023.

What are the major implications for exporting countries?

China can export vitamin D3 to the EU for either human food or animal feed, provided the products comply with the respective food or feed Regulations, and are accompanied by the necessary certificates.

Recommended Actions

Establishments must be registered (or approved for feed) by competent authorities of non-EU countries.

For feed, establishments must be registered in TRACES NT and published on the COM website.

Listing of establishments is now a completely electronic process, carried out directly in TRACES NT. Email is no longer used for establishment listing. The European Commission provides an Establishment Amendments’ lists user guide for third countries’ authorities.

When vitamin D3 is mixed with another animal by-product (for example, vitamin D3 coated with pork gelatin), a certificate is needed for each animal by-product.

Background

Vitamin D is obtained from sheep's wool and is considered to be a product of animal origin.

Vitamin D3 is covered by the public health requirements for exporting animals and products of animal origin.

Food

For the specific hygiene rules for animal products, see Regulation 853/2004. Annex XVI (amended by Regulation 2022/2258) classifies Vitamin D3 in the low-risk category of highly refined products (certificate HRP no. 46 in Regulation EU 2020/2235).

The list of non-EU countries authorised to export highly refined products to the EU is given in Regulation 2021/405 (see Art. 22 and Annex XII).

For more information see the following in AGRINFO:

• EU official health certificates for exports to the EU – explained
• Third country lists for public health – explained

Feed

Vitamin D3 is covered by the Animal By-Products Regulation 1069/2009.

Regulation 142/2011 states that fat derivatives can be exported to the EU from any third country (Annex XIV, Table 2, No. 18, page 164); and gives the model health certificate for imports of fat derivatives (Annex XV, Chapter 14(B), page 329).

China is already authorised to export vitamin D to the EU in the lists for both food and feed.

Resources

Sources