Part 3: UK Export Health Certificate for EU business requirements from 2022
(S,P) Food and drink producers and retailers need to prepare for submitting Export Health Certificate for EU-UK POAO trade from July 2022.
On 14 September 2021, the UK has set out a new timetable for introducing full import controls for goods being imported from the EU to the UK. Our part blog series explores everything an EU exporter or GB importer needs to know:
Part 1: New timetable and overview in a nutshell
Part 2: Frequently Asked Questions about the SPS import controls from 2022
Part 3: Details about the SPS changes
Import controls for GB are being introduced in a phased approach in order to give businesses impacted by COVID-19 time to adjust whilst maintaining effective biosecurity controls.
These stages include SPS controls will be rolled out from January 2022:
Importer pre-notifications (importer action)
Certification (such as export health certificate or Phytosanitary certificate)
Documentary, identity and physical checks at the border of inland. Entry via a point of entry with an appropriate Border Control Post (BCP with relevant checking facilities)
Key Points:
Pre-notification requirements for Products of Animal Origin (POAO), certain animal by-products (ABP), and High-Risk Food Not Of Animal Origin (HRFNAO) will not be required until 1 January 2022.
Export Health Certificate requirements for POAO and certain ABP will come into force on 1 July 2021
Physical SPS checks for POAO, certain ABP, and HRFNAO will not be required until 1 July 2022. At that point, they will take place at Border Control Posts.
There are already POAO Controls since January 2021
These are exports under safeguard measures (animal products intended for human consumption)
These controls relate to action that can be taken at very short notice to prohibit or restrict imports of certain products from certain countries following an outbreak of disease or a public health issue. If measures are introduced because of a new or emerging disease there may be additional steps you need to follow to pre-notify.
What businesses must do;
GB importers must: pre-notify in advance of arrival using IPAFFS and provide the EU exporter with the Unique Notification Number (UNN).
EU Exporters must: add the UNN onto the health certificate and provide the GB importer with an electronic copy of the Health Certificate (HC). EU Exporters must: ensure the original HC travel with the consignment.
GB importer must: upload an electronic copy of EHC onto IPAFFS.
1 January 2022
The requirements for pre-notification of Sanitary and Phytosanitary (SPS) goods, such as products of Animal Origin (POAO), certain animal by-products (ABP), and High-Risk Food Not Of Animal Origin (HRFNAO) will not be required until 1 January 2022. They were due to be introduced on 1 April 2021 and again on 1 October 2021.
How to Register for IPAFFS
Please note that the video was recorded before the new timetable was agreed. The dates in the video may be outdated by the announcement of the new timetable. The process described here however remains in tact
Import pre-notification process – IPAFFS: from October 2021, POAO for human consumption and some AB arriving from the EU or EEA countries will need to be pre-notified via the Import of Products, Animals, Food and Feed System (IPAFFS)
Prenotification times
For movements of live animals, importers need to submit import pre-notification via the domestic notification system (IPAFFS) at lease one working day in advance of the goods’ arrival at the point of entry.
Pre-authorisation by Defra/APHA of ABP prior to any imports taking place may also be required.
How to submit a pre-notification
Please note that the video was recorded before the new timetable was agreed. The dates in the video may be outdated by the announcement of the new timetable. The process described here however remains in tact.
We expect:
POAO and ABP: Pre notifications using IPAFFS introduced.
HRFNAO: requirement for pre-notification using IPAFFS will be introduced.
1 July 2022
The new requirements for Export Health Certificates, which were due to be introduced on 1 October 2021, will now be introduced on 1 July 2022. POAO must be accompanied by export health certificates (issued by the competent authorities of the EU MS).
We expect:
POAO and ABP: requirement for export HC, documentary checks using IPAFFS will be introduced. Goods are required to enter via a point of entry with an authorised BCP to undergo documentary, identity and physical checks as required.
Exporters must provide an electronic copy of the HC to the GB importer, to upload onto the notification in IPAFFS.
Live animals: live animals BCPs will be operational by this point.
EU exporters must:
Ensure that a copy of the HC accompanies the consignment.
Provide a copy of the HC to the GB importer to upload a copy on IPAFFS.
The requirements already in place for POAO under safeguard measures will continue.
Certification steps
The export HC is issued by the competent authority in the EU country.
The EU exporter is responsible for obtaining the HC.
The EU exporter must provide the importer with an electronic copy of the export HC for it to be uploaded to IPAFFS.
The EU exporter must ensure a physical copy travels with the consignment.
Exemptions
Note that certain composite products remain exempt from SPS controls at the border under Article 6 of EU Decision 2007/275 (retained EU law). These are certain composite products: are food containing both processed products of animal origin and products of plant origin. Composite products must follow the phased requirements of POAO and these goods must be pre-notified and accompanied by an HC from October 2021 unless otherwise exempt.
Some goods are exempt if they:
· Contain <50% processed animal product;
· Contain no meat product, and,
· Meet the requirement in Article 6 of Decision 2007/275.
Plants
Phytosanitary Certificates and physical checks on SPS goods at Border Control Posts, due to be introduced on 1 January 2022, will now be introduced on 1 July 2022.
High priority plants and plant products: identity and physical checks move to BCPs.
Regulated plants and plant products: prenotification required, the requirement for phytosanitary certificates and documentary checks introduced.
All regulated plants and plant products: identity and physical checks conducted at BCPs.
What shall businesses do?
At this stage, it is reasonable for businesses to start thinking about the appropriate and relevant actions they will need to take to be ready for 1 January 2022. Please contact us via the chat function to discuss your requirements or book a free consultation.
This is a great time to upskill yourself on how SPS works by booking one of our pieces of training. In addition to the LIVE! training, we offer on-demand training course on SPS:
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