Subscriber question: I want to send yoghurt to Scotland from Germany. What are my obligations?
(S) Food imports' paperwork can cripple businesses. But learn the ropes to cut red tape and costs says Arne Mielken of Customs Manager Ltd.
Marlies K, from Germany, a subscriber to our ongoing support service, is a major yoghurt producer in the EU. Some diary is brought in from outside the EU. They transport this non-EU diary to Scotland for further processing in their own plant. They need to know the rules for sending their dairy product to Great Britain and understand the requirements in detail. Her dedicated Customs Manager has now replied in German. We have translated the answer. Read his response.
Marlies,
Thanks for your question, which many of our food manufacturing clients are asking.
The UK deems some products to be riskier than others. The key reason for controls is the risk of the potential risk of food poisoning, in which more than 500,000 cases are reported yearly in the UK alone. Bacterial contamination can taint many types of food if allowed festering, and the causes and consequences are serious.
What are High-Risk Foods?
High risk foods share a tendency to spoil as a result of unsuitable storage conditions or improper cooking methods. Meats, fish, gravy, sauces, shellfish, dairy products, pasta and even cooked rice are all examples, and the smallest errors can lead to contamination. Consequently, basic mistakes in handling common produce can negatively impact on anyone - this applies to imports, too.
A crash course in harmful bacteria in food imports
There are quite a few harmful bacteria that can develop if you do not exercise proper care for high-risk food, its packaging and storage conditions. If you do not take proper care of the production, transportation, storage etc, your product may risk endangering the population with these bacteria:
Salmonella. Contamination and undercooking generally causes this common type of food poisoning. 2,500 sufferers in the UK are admitted to hospital each year.
Campylobacter. This is the most common cause of food poisoning in the UK, largely due to undercooked poultry.
Escherichia coli (E Coli) 0157. E Coli causes potentially fatal harm to the elderly and young children. You can prevent this by cooking meats thoroughly.
Listeria. This type of bacteria is present in raw milk (and anything made from it) and processed meats. Listeriosis is a huge risk because it can even counter the cold temperatures of a refrigerator. Only thorough cooking can destroy this.
Clostridium Perfringens. Causing nearly one million illnesses each year, the most common origin of this bacteria is large quantities of meals that are warmed for an extended period of time before serving. Companies and institutions are usually the responsible parties due to feeding many people at once.
Ultimately, importing high-risk foods requires adherence to strict rules and processes to keep people, and restaurant prospects, safe and secure.
What you need to know
Your yoghurt product is deemed to be a high-risk product. As such, strict import conditions apply. So there is important information on consignments of high-risk
food and feed transiting through the EU destined for GB that you need to know about.
1. Your product is known in the UK as
a) a "products of animal origin (POAO)
b) of high risk.
Where these consignments travel through the European Union to Great Britain from
non-EU countries, certain rules, despite the customs obligations, apply. These are so-called SPS measures.
GB SPS measures apply to all high-risk food, both POAO and HRFNAO (high-risk food and feed of non-animal origin).
This is also outlined in the UK's Border Operating Model. See: https://www.customsmanager.org/post/the-uk-border-operating-model-from-2021
Your obligations, in summary:
Direct imports of consignments of POAO and HRFNAO from non-EU countries must be imported into GB through an appropriately designated border control post (BCP). You must also complete a prenotification of your goods using the UK’s import control system, IPAFFS (Import of Products, Animals, Food and Feed System), which alerts the BCP to the intended arrival of the consignment.
GB destined POAO and HRFNAO consignments originating from non-EU countries which travel through the EU will not have received full sanitary and phytosanitary (SPS) checks (including veterinary checks) within the EU therefore these checks must be carried out at an appropriately designated BCP port in GB.
These checks are not required if the POAO and HRFNAO from non-EU countries are destined first for an EU delivery address and those consignments are subsequently exported (either in full or part) to GB. This is the case for you Marlies and your yoghurts are first going to your facility in Germany.
That is because they will have undergone full SPS checks at the EU BCP at the point of entry, maybe in Germany. This effectively allows them to be placed on the EU market and be treated the same as EU origin commodities and imported into GB in line with EU to GB trade rules.
Further information on the SPS rules and transiting requirements is available as well as extensive SPS training. Please see
https://www.customsmanager.org/booking
Here is what you need to know, Marlies...
Food Importers like yourself, when entering Scotland must be aware of the rules as it is your responsibility to ensure you comply with UK import requirements for high-risk food and feed.
This is essential to ensure the proper procedures and import controls can be followed and provides the assurances that imported food is safe.
High-risk food and feed which has been imported into the UK without meeting the specified import requirements is non-compliant and it is unlawful for such products to be placed on the UK market. Where such products are identified, appropriate enforcement action may be taken.
A list of all UK border ports and the commodities they can accept is listed on
gov.uk or you can ask your dedicated customs manager, as part of your subscription.
Further information on the import requirements of high-risk food and
feed transiting the EU and all other requirements in relation to the phased
introduction of UK controls on EU origin goods can be found in the Border
Operating Model. https://www.customsmanager.org/post/the-uk-border-operating-model-from-2021
If you have any concerns about this issue please contact us by email or chat. If you'd like more information on how to import food and drink items, please take a look at our dedicated section on our expert blog, which can be found here:
https://www.customsmanager.org/customs-global-trade-blog/categories/food
There you will also find a three-part mini-series videocast on the new EU import rules for food.
Marlies, why not join our training on SPS measures training, also available in German?
Here is what we cover:
What are SPS measures and how are they regulated?
European Union -> Great Britain:
Preparing to export live animals, animal products, food, feed and plants out of the EU.
Importing SPS goods into GB: Requirements, processes and procedures
GB Health Certificates, where to find and how do they look?
Introduction to IPAFFS.
Great Britain -> European Union:
Preparing to export live animals, animal products, food, feed and plants out of Great Britain.
Importing SPS goods into the EU: Requirements, processes and procedures.
EU Health Certificates, where to find, and how do they look? Introduction to TRACES.
Please let us know if you need any support or assistance.
Many thanks
Arne
Your dedicated Customs Manager