1 August 2025: Intermediate products – interpretation for imports
Updated 27 August 2025
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This publication is available at https://www.gov.uk/government/publications/official-veterinary-surgeon-ovs-notes/1-august-2025-intermediate-products-interpretation-for-imports
OVS note number: 2025/53
Date: 1 August 2025
Purpose
To clarify the interpretation of the definition of intermediate products, to promote consistency across Port Health Authorities (PHAs).
Background
An intermediate product is defined in Annex I point 35 of Regulation (EU) 142/2011 as a derived product.
Article 3(2) of Regulation (EC) 1069/2009 defines derived products as ‘obtained from one or more treatments, transformations or steps of processing of animal by-products’.
Regulation (EU) 142/2011 clarifies that a derived product can be considered an intermediate product if it fulfils specific criteria for intended use, design, transformation, manufacturing, and materials from which it should be derived. Further information can be found in the Import Information Note (IIN) ABP/20.
‘Steps of processing’, ‘treatments’, and ‘transformations’ are not defined in the Animal By-Products (ABP) Regulations, so this note aims to provide a steer on how to interpret these terms. Taken together, these terms cover anything which substantially and irreversibly changes the nature of the ABP.
What should not be considered an intermediate product
Unprocessed raw material should not be considered an intermediate product, even if it meets the other criteria. Examples include:
- raw blood
- raw body parts
- organs and glands of animals
- meat
What should be considered an intermediate product
A processed, treated, transformed but still relatively ‘raw’ product, can be considered an intermediate product, provided that it meets the other criteria. Examples include:
- animal cells dissolved in serum
- serum containing specific antibodies for diagnostic purposes, ready to be assembled into a medical device
- heparin used as laboratory reagent
A more comprehensive guidance will also be provided on relevant GOV.UK pages in due course.
Contact point for enquiries
Email: imports@apha.gov.uk
Animal By-Products Policy Team