Import and Transit of Animal-Origin Food from Third Countries into the EU
A Practical Map of the Border Control Regime

Importing food from third countries is not just about tariffs and labels. When a product contains animal-origin raw materials — fish oil, fish collagen, gelatin, crustaceans, milk or meat — an entirely different legal regime applies. One that, in practice, determines whether goods will enter the Union at all.

Two Product Categories — The Key Distinction

EU law distinguishes two fundamental groups:

Products of animal origin (POAO) — products where animal-derived ingredients form a substantial part or that are classified as such (e.g. fish oils, fish collagen, gelatin, dairy products).

Composite products — products containing both plant-based ingredients and processed products of animal origin. A classic example: a food supplement in a gelatin capsule with fish oil and herbal extracts.

The Standard Path: Border Control Post + CHED-P

For products of animal origin and most composite products, the full procedure applies:

1. Goods must originate from an establishment approved for export to the EU (list published by the Commission).
2. The consignment must be accompanied by an official veterinary certificate issued by the competent authority of the third country.
3. The consignment must be notified in the TRACES system via a CHED-P document (Common Health Entry Document – Products).
4. Goods must enter EU territory through a designated Border Control Post (BCP).
5. At the BCP, a documentary check is carried out, and where necessary, identity and physical checks.

Only after a favourable outcome may the goods be released for free circulation or — in the case of transit — forwarded under customs supervision.

The Lighter Path — Low-Risk Composite Products

Under Commission Delegated Regulation (EU) 2021/630 (as amended), certain composite products may be exempted from BCP checks. The conditions are strict:

• The product must be shelf-stable (stable at ambient temperature)
• It must not contain processed meat
• The proportion of processed products of animal origin must be sufficiently low
• The product must fall within the catalogue of exempt categories

In such cases, instead of a full official certificate and BCP inspection, a private attestation by the importer suffices. Controls may be conducted later — at the place of destination or at the importer's warehouse.

Transit Through EU Territory

The fact that goods are ultimately destined to leave the Union (e.g. heading to Ukraine or Belarus) does not exempt them from formalities upon entry into EU territory. For transit of animal-origin products or composite products not meeting exemption conditions, the same logic applies:

• Entry through a designated BCP
• CHED-P notification in TRACES
• Veterinary checks
• Onward transport in sealed vehicles under customs supervision
• Exit from the EU through a designated point

There is no blanket exemption from CHED-P simply because goods are "passing through." Exceptions exist, but they are narrow and depend on the specific product composition.

What This Means in Practice

For importers and distributors, there are three key takeaways:

1. Composition determines the pathway. Even a small change in the proportion of an animal-origin ingredient can shift a product from one category to another.
2. The establishment must be approved. If the manufacturing establishment is not listed on the EU-approved list, legal import is impossible regardless of product quality.
3. Transit is not "easier." In many cases, formalities for transit are nearly identical to those for import into the EU market.

Summary

Import and transit of animal-origin food from third countries is an area where composition details and documentation have a direct impact on whether goods can physically move. The standard path (BCP + CHED-P) is the rule. The lighter private attestation mechanism exists but applies only to a narrow group of composite products meeting specific conditions.

The first step for any portfolio containing animal-origin ingredients should be to precisely determine which pathway a given product must follow — before planning logistics and delivery timelines.

Disclaimer: This material is for general informational purposes only and does not constitute legal advice in any individual case. Regulatory status and enforcement practices may change.