UK to EU Export / Import Controls (SPS)

Goods Subject to Sanitary and Phytosanitary Controls

Key definitions for traders

These controls will introduce a number of new processes and procedures which will apply to the import of Animal Products, Fish, Shellfish and their Products, Live Animals and Plants and Plant Products.
These controls include the requirements for:
• Import pre-notifications
• Health certification (such as an Export Health Certificate or Phytosanitary Certificate)
• Documentary, identity and physical checks at the border
• Entry via a Border Control Post (BCP)
An import pre-notification refers to the means by which importers provide advance notice to relevant regulatory bodies of a consignment’s arrival into the EU. This is typically a standardised import notification form that requires the importer to provide details regarding the consignment, such as the consignment’s country of origin, place of destination, the specific species/product and general details for the importer, exporter and transporter. This is submitted by the importer in advance of the consignment’s arrival to the relevant regulatory body for that commodity.
A health certificate refers to an official document that confirms the product meets the health requirements of the destination country. This is required to accompany the consignment during its passage. It is the responsibility of the exporter to secure this from the country of origin’s relevant competent authority. Different products will require different details from the exporter regarding the consignment, though this will generally include details of the country of origin, place of destination, and nature of transport, as well as a health attestation of the consignment. For products of animal origin and live animals, for instance, this will require the consignment to be inspected by an Official Veterinarian in order to verify that the consignment’s contents meet the health requirements of the destination country. An individual health certificate is required for each species/type of product.

Therefore, a single import may consist of multiple consignments that each require multiple health certificates.
A documentary check is an examination of official certifications, attestations and other commercial documents that are required to accompany a consignment.

An identity check entails the visual inspection of a consignment in order to verify its content and labelling corresponds to the information provided in accompanying documentation.

A physical check entails a check on the goods to verify that they are compliant with the sanitary and phytosanitary import requirements for the EU. This includes, as appropriate, checks on the consignment’s packaging, means of transport and labelling. Temperature sampling for analysis, laboratory testing or diagnosis may also be required.
Entry via a Border Control Post (BCP) refers to the requirement for certain goods to enter the EU via specific points of entry that are equipped to perform checks on specified goods. A BCP is an inspection post designated and approved in line with that country’s relevant legislation for carrying out checks on animals, plants and their products arriving from GB. These checks are carried out to protect animal, plant and public health. The commodities that BCPs are equipped to process will differ between BCPs. Therefore, it is the responsibility of the importing/exporting parties to ensure that their goods are routed via an appropriate BCP; importers are typically required to notify the relevant BCP of the goods arrival as part of the pre-notification process as such.

Groupage exports – Defra commodities

A groupage export in reference to Defra commodities is an export where:
a) multiple product lines of the same commodity type are grouped under a single export health certificate to export as a single consignment.
b) multiple quantities of the same commodity type (e.g. fish products) potentially from several sources are grouped into the same container. It may be possible to export these as a single consignment covered by a single health certificate or as a mixed load (containing several consignments).
c) multiple different commodity types (e.g. dairy products and meat products) are grouped in a single container.

Defra’s Groupage Export Facilitation Scheme (GEFS)
Defra have developed a new scheme known as the Groupage Export Facilitation Scheme (GEFS) which is designed to facilitate the export of certain commodities with complex but stable supply chains for use at the end of the Transition Period.

Guidance on GEFS was published in June 2020 and is available here (http://apha.defra.gov.uk/external-operations-admin/library/documents/exports/ET193.pdf )

Ahead of the launch of GEFS later in 2020, Defra are working closely with the industry and certifiers to implement the scheme. Particularly in determining how exporters will monitor the activities of the supply chains that they want to include.

Animal products (Products of Animal Origin and Animal By-Products)

This will include the requirement for:
• goods to be accompanied by an Export Health Certificate in order to undergo documentary checks
• import pre-notifications submitted by the importer at least one working day in advance of arrival
• Entry via a suitable Border Control Post (BCP) in order to undergo documentary, identity and physical checks at the border

Exports of certain composite products containing animal products will also be subject to these controls. Guidance on what this includes is available here. Exporters should check if the CN code for their product is listed in Regulation 2019/2007 to find out if the POAO or ABP must meet the above requirements. To find out if the POAO or ABP must meet the above requirements.
All goods will need to be accompanied by an Export Health Certificate (EHC) or other official documentation. The exporter will need to contact APHA to obtain the appropriate EHC which must be filled out by an Official Veterinarian or Official Inspector on inspection of the consignment. Local authority Environmental Health Officers can sign for seafood. The original EHC must be physically presented at the BCP on arrival in the EU.

For England and Wales, exporters can apply for their health certificates on EHC Online (EHCO) and further information on EHCs can be found here. EHCO is a new digital online application service for EHCs that has been developed by Defra and APHA. By Winter 2020, EHCO will have replaced the current manual PDF process for applying for non-EU EHCs. Further details for Scotland will be made available in due course.
Where animal products need to enter the EU via a Border Control Post (BCP) the BCP must be designated for that commodity in order for the goods to be checked.

If no EHC currently exists for the country of destination, the GB exporter should contact CITC for further information. Contact details for CITC can be found here.
The EU importer will need to submit pre-notifications to the relevant Border Control Post (BCP) via TRACES NT. This will need to be done at least one working day in advance of the goods arrival with a potential derogation to four hours before arrival if the BCP deems there to be logistical constraints (although the standard period is 24 hours).
Additional Requirements for Marine-Caught Fish and CITES-listed goods
Exports of marine-caught fish, fishery products and some types of shellfish will also need to meet catch certificate requirements as detailed for fish, shellfish and their products.

Exports of food products made from species listed in the CITES, EUWTR or UKWTR annexes, such as caviar from the Sturgeon family, will also need to meet CITES-related requirements as detailed for CITES goods in 4.2.2. These include the requirement for relevant UKWTR export permits from APHA and EUWTR import permit issued by the competent authority of country of destination.

Location of checks

Animal products will need to enter the EU via an appropriately designated BCP in order for the goods to be checked. A list of current BCPs and the commodities they accept is available here.
Upon arrival at the BCP, goods will be subject to 100% documentary and identity checks. This entails examination of the official certifications, attestations and other commercial documents that are required to accompany the consignment. An identity check entails a visual inspection to verify the content and labelling of a consignment correspond to the information provided in the accompanying documentation.

Goods may also be subject to physical checks.
There are no outbound checks on animal products for sanitary and phytosanitary purposes.

Systems

The EU importer will need to register for TRACES NT.
Process Map: Products of Animal Origin

Process Map: Animal By-Products

Fish, shellfish and their products

Requirements for all fish
All fish, shellfish and their products being exported from GB to EU will be subject to sanitary and phytosanitary EU import controls, similar to those applying to animal products and live animals. With the exception of certain direct landings of fish into the EU, this includes the requirement for export health certificates, import pre-notifications and entry via a Border Control Post (BCP).

In addition, exports of most UK marine-caught fish and shellfish will need to be accompanied by a catch certificate.
Catch certificates are official documents that prove any marine-caught fish has been caught legally. These are issued by the Marine Management Organisation and will need to be applied for and secured by the GB exporter. The exporter will need to create a catch certificate online.

Exports of non-marine-caught fish (e.g. freshwater fish and shellfish) and certain exempt marine species that includes mussels, cockles, oysters, scallops, fish fry or larvae) are not subject to catch certificate requirements.

No health certification is required for direct landings of fresh (or primary processed) fish landing into a port designated under the EU’s IUU regulation.
Requirements for fish and shellfish as animal products and as live aquatic animals

In line with rules for animal products, new export requirements will apply to GB fish and shellfish exported as animal products (e.g. containerised fish or via vivier transport) from January 2021 – see 4.2.3. Guidance on products within this category can be found online.
In line with rules for live animals, exports of fish and shellfish as live aquatic animals (e.g. ornamental fish) will be subject to new export controls for live animals from January 2021 – see 4.2.3.
Certain live bivalve molluscs can be exported as food for human consumption and should follow the appropriate rules for animal products.
Live aquatic animals where intended for direct consumption by the final consumer – such as live oysters and mussels (if from Class A waters or depurated), crabs and lobster – are classed as animal products and not as live animals; therefore, these will be subject to controls applying to animal products rather than live animal controls. LBMs are subject to circumstantial rules.

For all exports of fish and shellfish as animal products, aside from some direct landings, or exported as live animals, there will be the requirement for:
• goods to be accompanied by an Export Health Certificate
• import pre-notifications must be submitted by the EU importer at least one working day in advance of arrival.
• Entry to the EU must be via a BCP in order for goods to undergo documentary, identity and physical checks
There are different rules for direct landings of fish into the EU, which are described below.

An EHC is an official document that confirms the export meets the health requirements of the destination country. The exporter will need to contact APHA to obtain the appropriate EHC for exports of fish as animal products, which must be completed and issued by a Certifying Officer on inspection of the consignment if they can be satisfied that the requirements have been met. EHCs for the export of fish as live animals are issued and certified by the Fish Health Inspectors (FHI), CEFAS, in England and Wales or Fish Health Inspectors from Marine Scotland in Scotland.

The original EHC must be physically presented at the BCP on arrival in the EU.
Exporters can apply for their health certificates via the Export Health Certificates Online (EHC Online) system and further information on EHCs can be found at online.
If the movement is not an EU harmonised import (i.e. if no model EHC is available from the EU for the goods being transported), the EU importer will need to confirm the appropriate import requirements for the specific consignment with their Competent Authority, and, the GB exporter can contact CITC for guidance and must meet the requirements.
Contact details for CITC can be found online.

Exports of certain composite products containing animal products will also be subject to these controls. Guidance on what this includes is available online.
The EU importer will need to submit pre-notifications to the relevant BCP via TRACES NT. This will need to be done at least one working day in advance of the goods arrival with a potential derogation to four hours before arrival if the BCP deems there to be logistical constraints.

Documentation requirements for direct landings of marine-caught fish and shellfish
If a UK registered fishing vessel wishes to land its catch directly into an EU port it must give 4hrs notice to the EU competent authority, submit a prior notification document, a pre-landing document and a catch certificate for the fish that is being landed.

If a vessel is over 12m in length it must also correctly complete & submit its electronic logbook in accordance with UK regulations, land at a designated port and in accordance with North East Atlantic Fisheries Commission rules. Landings of fresh fish (or fish which has undergone primary production, such as gutting or de-heading only) from registered vessels, do not require an EHC.
Direct landings from local authority approved freezer, factory or reefer vessels of fishery product that has undergone secondary processing, such as freezing or wrapping, will need to be accompanied by a Captain’s Certificate, signed by an APHA authorised captain, rather than a fishery products or LBM EHC and presented to a BCP for checks.

Details on how to do this are available online.

Additional requirements for endangered species listed under CITES
Exports of fish species listed in the CITES, EUWTR or UKWTR annexes, such as caviar from the Sturgeon family, will also need to meet CITES-related requirements as detailed for CITES goods in 4.2.2. These include the requirement for relevant UKWTR export permits from APHA and EUWTR import permit issued by the competent authority of country of destination.

Locations of checks

Direct landings of fresh fish (or fish that has undergone primary processing such as de-heading or gutting only) will need to be landed at an EU port designated under IUU regulation rather than a BCP.
The vessel will need to notify the relevant EU competent authority via email prior to landing in a designated port.
They will also need to send the completed catch certificate and logbook data via the Electronic Reporting System. Other than direct landings referenced above, exports of fish and shellfish as animal products and live aquatic animals will need to enter the EU via a suitable BCP. Exports of containerised fish or live animals that qualify as POAO, or direct landings of frozen or secondary processed fish from local authority approved vessels, will also need to enter the EU at a suitable BCP for goods to be checked. Following arrival at the BCP, goods will be subject to documentary, identity and physical checks. Goods may also be sampled for laboratory testing.

A list of current BCPs and the commodities they accept is available online.
Documentary checks entail examination of the official certification, attestations and other commercial documents that are required to accompany the consignment. An identity check entails a visual inspection to verify the content and labelling of a consignment correspond to the information provided in the accompanying documentation.

Physical checks entail a check on the goods and, as appropriate, checks on packaging, the means of transport, labelling and temperature, the sampling for analysis, testing or diagnosis and any other check necessary to verify compliance with the import sanitary and phytosanitary rules.

Systems

The EU importer will need to register for TRACES NT.

Process Map: Fish Direct Landing (primary product only)

Process Map: Fish as Animal Products

Process Map: Fish as Live Animals

High-Risk Food and Feed Not of Animal Origin (HRFNAO)

From January 2021, exports of HRFNAO from GB to the EU will be subject to EU import controls in line with goods exported from the Rest of the World.
This includes the requirement for
• import pre-notifications submitted by the importer at least one working day in advance of arrival
• entry via a suitable Border Control Post (BCP) in order to undergo documentary, identity and physical checks at the border
The EU importer will need to submit pre-notifications to the relevant Border Control Post (BCP) via TRACES NT. This will need to be done at least one working day in advance of the goods arrival.

This also includes exports of some controlled plants and plant products – such as apples, lettuce, and all solanaceous fruits (e.g. tomatoes, aubergines) – that will be subject to these controls in addition to risk-based phytosanitary controls as detailed elsewhere in this document.

Additional requirements for high-risk plants and products
HRFNAO also includes some controlled plants and plant products – such as apples, lettuce, and all solanaceous fruits (e.g. tomatoes, aubergines). Exports of HRFNAO within this category will also need to meet phytosanitary controls as detailed in 4.2.3, such as the requirement for a Phytosanitary Certificate.

Location of checks

HRFNAO will need to enter the EU via a suitable BCP for the goods to be checked. A list of current BCPs and the commodities they accept is available here.
Upon arrival at the BCP, goods will be subject to 100% documentary and identity checks. This entails examination of the official certifications, attestations and other commercial documents that are required to accompany the consignment. An identity check entails a visual inspection to verify the content and labelling of a consignment correspond to the information provided in the accompanying documentation.
Goods may also be subject to physical checks.
There are no outbound checks on HRFNAO for sanitary and phytosanitary purposes.

Systems

The EU importer will need to register for TRACES NT.

Live animals and germinal products

Requirements
From January 2021, new import requirements will apply to exports of live animals and germinal products from GB to the EU.
This includes the requirement for
• goods to be accompanied by an Export Health Certificate (EHC).
• import pre-notifications submitted by the EU importer at least one working day in advance of arrival.
• entry via a Border Control Post (BCP), where goods will undergo documentary, identity and physical checks.

All goods will need to be accompanied by an Export Health Certificate (EHC); this will need to be secured by the exporter from APHA and completed by an Official Veterinarian/Inspector verifying that the animals meet the health conditions as outlined in EU regulation and stipulated on the certificate.
For fish and shellfish, this will need to be completed by the relevant Fish Health Inspectorate for either England and Wales (CEFAS) or Scotland (Marine Scotland).

If no EHC currently exists for the country of destination, the GB exporter should contact CITC for further information. Contact details for CITC can be found here.
All goods will need to enter the EU via a BCP designated for that commodity in order for the goods to be checked. The original physical copy of the EHC must be presented on arrival at the BCP for inspection by EU authorities.
The EU importer will also need to submit pre-notifications to the relevant BCP via TRACES NT. This will need to be done at least one working day in advance of the goods’ arrival.

Depending on the type of animal, specific welfare requirements may apply including the need for specifically approved transportation vehicles, and certificates or authorisations for the drivers and handlers of the animals.
Depending on the length of the journey, a journey log would also need to be submitted to APHA and the EU MS CA and the approved Log must accompany the consignment.

Additional requirements for endangered species, marine-caught fish and equines
Exports of live animal species listed in the CITES, EUWTR or UKWTR annexes will also need to meet CITES-related requirements as detailed for CITES goods in 4.2.2.
Exports of live, marine-caught fish will also need to meet catch certificate requirements as detailed in 4.2.3.
In addition to controls set out for live animals, exports of equines will also need to meet specific blood testing requirements. These are detailed in 4.2.3.

Location of checks

Live animals and germinal products will need to enter the EU via a suitable BCP in order for the animals to be checked. A list of current BCPs and the commodities they accept is available here.

Upon arrival at the BCP, the animals will be subject to documentary, identity, and physical checks. This entails an examination of the official documents which are required to accompany the consignment and a visual inspection to verify the content of the consignment corresponds to the official documents.

A physical check means a check on, as appropriate, the means of transport, the condition of the animal, and may include sampling for analysis.

Systems
The EU importer will need to register for TRACES NT.

Process Map: Live Animals and Germinal Products

Equines Requirements

From January 2021, new import requirements will apply to exports of equines from GB to the EU. As well as rules for live animals as set out in 4.2.3, equines will be subject to additional blood testing requirements.
This includes the requirement for
• goods to be accompanied by an Export Health Certificate (EHC).
• goods to undergo blood testing ahead of any movement as a prerequisite of the EHC.
• import pre-notifications submitted by the EU importer at least one working day in advance of arrival.
• entry via a Border Control Post (BCP), where goods will undergo documentary, identity and physical checks.
All goods will need to be accompanied by an Export Health Certificate (EHC); this will need to be secured by the exporter from APHA and completed by an Official Veterinarian/Inspector verifying that the animals meet the health conditions as outlined in EU regulation and stipulated on the certificate.

The original physical copy of the EHC must be presented on arrival at the BCP for inspection by EU authorities.
If no EHC currently exists for the country of destination, the GB exporter should contact CITC for further information. Contact details for CITC can be found here.

Exporters will also need to arrange blood testing in advance. The initial blood sample can be taken by any veterinarian, but the analysis report from the appropriate lab needs to be approved by an Official Veterinarian at the time of EHC certification.

Post testing, registered equines will be able to travel using their existing identity document (passport) and an Export Health Certificate (replacing the existing ITAHC or equivalent).
If the EU does not recognise UK studbook listings before January 2021, most UK horses would be considered unregistered and will therefore also require a Supplementary Travel ID document, issued by APHA and signed off by an Official Veterinarian at the same time as the EHC.

The driver of the equine transportation would also require a Certificate of Competence, a valid Vehicle Approval Certificate, and Transporter Authorisation, from the EU competent authority. A journey log may also need to be submitted and accompany the equines.

Equines will need to enter the EU via a BCP designated for that commodity in order for the goods to be checked.
The EU importer will also need to submit pre-notifications to the relevant BCP via TRACES NT. This will need to be done at least one working day in advance of the goods’ arrival.

Location of checks
Equines will need to enter the EU via a suitable BCP in order for the animals to be checked. A list of current BCPs and the commodities they accept is available here.

A physical check means a check on, as appropriate, the means of transport, the condition of the animal, and may include sampling for analysis.

Systems

The EU importer will need to register for TRACES NT.

Process Map: Equines

Plants and Plant Products

This will include the requirement for:
• goods to be accompanied by a phytosanitary certificate
• import pre-notification submitted by the EU importer
• documentary, physical and identity checks
Regulated plants and plant products exported to the EU will need to be accompanied by a phytosanitary certificate and may be checked upon entry.
The GB exporter will need to secure a phytosanitary certificate prior to the goods leaving GB with sufficient time to allow for inspections and testing. A phytosanitary certificate is an official document that certifies that the material has been inspected, is considered free from quarantine and other pests, and that it conforms to the plant health regulations of the importing country.

Fruit and vegetables that have been processed, such as packaged salad, may be subject to separate requirements. Exporters are advised to check import requirements with the relevant Member State’s plant health authority.

Physical inspections for the sake of securing an export phytosanitary certificate can take place inland, prior to export.
The exporter will need to apply to the relevant plant health authority in order to secure this (APHA in England and Wales and the Scottish Government in Scotland; and FC for wood, wood products and bark in England, Wales and Scotland).

Additional requirements for High-Risk Food and Feed Not of Animal Origin and CITES- listed goods
Imports of products categorised as High-Risk Food not of Animal Origin (HRFNAO) will also be subject to these controls as detailed elsewhere in this document.
Plants and plant products that fall under endangered species regulations (CITES/UKWTR) have further requirements as detailed elsewhere in this document.
Location of checks
Depending on the risk category, regulated plants and plant products may need to enter the EU at a Border Control Post and will be subject to documentary checks either at or away from the border, as well as physical and identity checks.
Further guidance can be found here.
Systems
For regulated plants and plant products, the GB exporter will need to have registered with the appropriate plant health authority in GB to obtain a phytosanitary certificate. For England and

Wales this will be through the EHC Online system; further information will be available shortly for Scotland.

Wood Packaging Material

Wood packaging material (WPM), including pallets and crates, must meet the ISPM15 international standards for treatment and compliant marking. The WPM holding a consignment may be subject to inspections upon entry to the EU to verify compliance with the ISPM15 requirements.
Further details on ISPM15 requirements can be found online here.
Process Map: Plants and Plant Products