Clarification of import requirements for certain animal products

Animal health
Animal health certification
Food safety
General Food Law
Hygiene
Third country lists
Food safety controls
Official controls

Summary

The European Union (EU) has clarified which products of animal origin must meet specific requirements (authorisation of country of export, approval of establishments, health certificates) to enter the EU. It has added Combined Nomenclature/Harmonized System (CN/HS) customs codes defining certain dairy products, food additives, and collagen casings not currently included in the Regulation. In addition, this Regulation establishes that all meat establishments providing raw material for the EU market must be EU approved, and clarifies that no document is required to accompany gelatine capsules not derived from ruminant bones when used in composite products.

EU clarifies requirements for certain animal products (dairy products, food additives, collagen casings, gelatine capsules) to enter the European Union

Commission Delegated Regulation 2025/637 of 29 January 2025 amending Delegated Regulation (EU) 2022/2292 as regards the requirements for the entry into the Union of certain dairy products, certain food additives derived from animals, collagen casings, minced meat, meat preparations, mechanically separated meat and composite products containing gelatine capsules

Update

Impacted Products

Food additives, collagen casings, minced meat, meat preparations, mechanically separated meat, composite products, gelatine capsules

What is changing?

Lists of animal products that must meet specific requirements

Article 3 of Regulation 2022/2292 presents a list of animal products that may only enter the EU if the non-EU exporting country has been authorised by the EU to export.

Article 13 of that Regulation provides a list of animal products that may only be exported if they come from establishments approved for the EU market.

Both lists define the animal products with reference to customs codes. However, the customs codes for certain categories of animal products were not previously listed.

The new Regulation clarifies which animal products are covered by:

adding the following to the list of products that can only be imported from authorised non-EU countries: certain dairy products, food additives derived from animals, and collagen casings with the following CN/HS customs codes: 1301, 1806, 3203, 3204, 3823, 3824, 2202 99, 3917 10 10 [Art. 3(b)]
introducing the following in the list of products that can only be exported from listed establishments: certain dairy products and collagen casings with the following customs codes: 1806, 2202 99, 3917 10 10 [Art. 13(1), a.ii].

Types of establishment that may be listed

Article 15 of Regulation 2022/2292 specifies the types of establishment that must be approved and listed to provide raw material for the production of fresh meat, minced meat, meat preparations, mechanically separated meat, meat products, and gelatine.

The new Regulation clarifies that the establishments requiring approval include those producing minced meat, meat preparations, and mechanically separated meat, so that all establishments providing raw material, from the slaughterhouse onwards, must be EU approved (Art. 15).

Health certificates

Article 21 of Regulation 2022/2292 lists the animal products that require official health certificates on export. The new Regulation adds certain dairy products and collagen casings with the following CN/HS codes to the list: 1806, 3302, 2202 99, 3917 10 10.

Gelatine capsules

Certain composite products do not require a health certificate, but do require a private attestation, signed by the operator responsible for the consignment, stating that they meet EU requirements (Art. 22 of Regulation 2022/2292). The new Regulation amends this requirement so that no private attestation is required for composite products where the only animal ingredient is gelatine capsules not derived from ruminant bones.

Why?

Certain animal products, such as food additives, dairy products, and collagen casings, are extensively imported into the European Union and must meet EU requirements. The new Regulation adds to Regulation 2022/2292 the customs categories under which they are traded.

Timeline

The new rules apply from 19 May 2025.

What are the major implications for exporting countries?

This proposal provides greater legal certainty about which rules apply to certain dairy products, food additives, and collagen casings. It facilitates the export of composite products in which gelatine capsules not derived from ruminant bones are the only animal ingredient.

Background

Regulation 2022/2292 sets out the public health requirements for animal products exported to the EU. It aims to ensure that food-producing animals, products of animal origin, and composite products meet requirements that are at least equivalent to the EU public health legislation (as detailed in the relevant official certificates). For further information, see Public health requirements for exporting live animals, products of animal origin, composite products and sprouted seeds to the EU.

Resources

ePing: SPS & TBT Platform: G/SPS/N/EU/791

European Commission: Have your say: Products of animal origin – amendment of import conditions for public health reasons

European Commission: Integrated Management System for Official Controls (IMSOC): Establishment Lists

Commission Delegated Regulation 2022/2292 with regard to requirements for the entry into the Union of consignments of food-producing animals and certain goods intended for human consumption

Sources

Commission Delegated Regulation 2025/637 amending Regulation 2022/2292 as regards the requirements for the entry into the Union of certain dairy products, certain food additives derived from animals, collagen casings, minced meat, meat preparations, mechanically separated meat and composite products containing gelatine capsules

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EU clarifies requirements for certain animal products (dairy products, food additives, collagen casings, gelatine capsules) to enter the European Union

What is changing and why?

Certain animal products – such as food additives, dairy products, and collagen casings – are extensively imported into the European Union. These products may only enter the EU from authorised countries and from establishments approved by the EU, and must be accompanied by health certificates. However, certain products were previously not covered by these requirements because the Combined Nomenclature/Harmonized System (CN/HS) customs codes under which these products are traded were not included in the list of products covered by the relevant legislation (Regulation 2022/2292). This new Regulation adds the customs codes for those missing products.

The new Regulation also clarifies that, in the meat chain for the EU market, all establishments providing raw material, from the slaughterhouse onwards, must be EU approved, including establishments producing minced meat, meat preparations, and mechanically separated meat.

In addition, under the new Regulation, no private attestation guaranteeing compliance with EU rules will be required for composite products that use gelatine capsules not derived from ruminant bones as their only animal ingredient.

Timeline

The new rules apply from 19 May 2025.