2.1.1 Overview

There will be no changes to the core import process from April 2021, and for the majority of goods, there will be no change in import procedures overall. However, certain categories of (2.2.3) goods subject to Sanitary and Phytosanitary controls will have additional requirements placed on them, as follows:
• Animal products (Products of Animal Origin only)
• Fish and fishery products
• High-risk food and feed not of animal origin (HRFNAO)
• Plants and plant products

The details of these controls are laid out in the following section.

2.2.3 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 or inland (temporarily)
• Entry via a Border Control Post (BCP) from July 2021

An import pre-notification refers to the means by which importers provide advance notice to relevant regulatory bodies of a consignment’s arrival into GB. 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 GB. 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) from July 2021 refers to the requirement for certain goods to enter GB 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 the EU. 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.

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

Requirements

From April 2021, new import requirements will apply to EU Products of Animal Origin (POAO). Guidance on products that are classed as POAO can be found here.
For imports of EU POAO, there will be a requirement for:
• goods to be accompanied by an Export Health Certificate in order to undergo documentary checks
• import pre-notifications submitted by the importer in advance of arrival.

This does not include the requirement for entry via a Border Control Post or identity or physical checks at the border. However, these controls will be introduced in July 2021 – see SECTION 3.2.3.

From April 2021, there will be new requirements for EU POAO to be accompanied by an Export Health Certificate (EHC). An EHC is an official document that confirms the export meets the health requirements of the destination country; this will need to be secured by the exporter from the EU country of origin’s competent authority.
Where there are no standardised requirements and no model Export Health Certificate currently exists, the GB importer will need to contact CEFAS/CITC for England/Wales. In Scotland, individual importers do not require authorisation but relevant authorities may need to confirm that the consignment is destined for an authorised facility.
Contact details for relevant authorities can be found here:
• Centre for International Trade Carlisle (CITC)
• Centre for Environment, Fisheries and Aquaculture Science
• Fish Health Inspectorate

From April 2021, there will also be new requirements for importers to submit pre-notifications for POAO via IPAFFS.
Imports of fully processed animal feed, including pet food, will be subject to the requirements set out above for EU POAO.

Additional Requirements for marine-caught fish and CITES-listed goods

Imports 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 in 2.2.3.

Imports of food products 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 SECTION 1.2.2. These include the requirement for relevant EUWTR export permits from the country of departure and a UKWTR import permit issued by APHA.

Location of checks

From April 2021, POAO will be subject to remote documentary checks. This entails the examination of official certifications, attestations and other commercial documents that are required to accompany the consignment. All goods will need to be accompanied by an EHC and movements to be pre-notified in advance of arrival.
Identity checks and physical checks will not apply until July 2021 – see SECTION 3.2.3. Systems
The importer will need to register for IPAFFS.

Process Map: Products of Animal Origin

Process Map: High-Risk Animal By-Products

Fish, shellfish and their products

Requirements for all fish and shellfish and their products

From January 2021, fish, shellfish and their products originating from the EU will be subject to additional sanitary and phytosanitary import controls implemented in stages, similar to those applying to animal products and live animals.

In addition, most imports of marine-caught fish and some shellfish will need to be accompanied by a catch certificate.
Imports of non-marine-caught fish (e.g. farmed fish/shellfish, freshwater fish) and certain exempt marine species (e.g. mussels, cockles, oysters, scallops, fish fry or larvae) are not subject to catch certificate requirements.

Requirements for fish and shellfish as animal products (e.g. containerised fish or via vivier transport) and live animals (e.g. ornamental fish)

In line with rules for animal products, new import requirements will apply to EU fish as Products of Animal Origin (POAO) from April 2021. Please note that in a few instances, live animals are treated as products and not as live animals, e.g. lobster direct to the final consumer. General guidance on products that are classed as POAO can be found online at: https://www.gov.uk/government/collections/guidance-on-importing-and-exporting-live-animals-or- animal-products and elsewhere.
In line with rules for live animals, imports of fish as live animals will continue to be subject to controls for live animals as introduced in January 2021 – see 1.2.3. Between January 2021 and July 2021, these will remain unchanged.

For all imports of fish as live animals (from January 2021) and animal products (from April 2021), there will be the requirement for:
• goods to be accompanied by an Export Health Certificate (EHC), which may or will be subject to documentary checks;
• import pre-notifications submitted by the importer in advance of arrival.
This does not include the requirement for entry via a Border Control Post or identity or physical checks at the border. However, these controls will be introduced in July 2021 – see 3.2.3.

From January 2021, there will be new requirements for fish imported as live animals, specifically that they must be accompanied by an EHC. This requirement will also apply to fish as POAO (live or dead) from April 2021. An EHC is an official document that confirms the export meets the health

Requirements of the destination country; this will need to be secured by the exporter from the EU country of origin’s competent authority.
Where there are no standardised requirements and no model EHC currently exists, the GB importer will need to contact the Centre for International Trade (CITC) for fishery products or CEFAS/MS for live aquatic animals, for import requirements, if permitted, including any licencing or documentation where applicable.
Contact details for relevant authorities can be found here:
• Centre for International Trade Carlisle (CITC)
• Centre for Environment, Fisheries and Aquaculture Science
• Fish Health Inspectorate

From January 2021, there will also be new requirements for importers to submit pre-notifications for POAO and live animals via IPAFFS. This will also apply to POAO from April 2021. The importer will need to use IPAFFS to pre-notify the goods’ arrival in advance.
Imports of composite products containing fish will also be subject to these controls but may become exempted from Catch Certificate requirements.

Requirements for direct landings of marine-caught fish by EU registered fishing vessels
If an EU registered fishing vessel wishes to land its catch directly into the UK it must give 4 hours’ notice to UK authorities, 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 EU regulations, land at a designated port and in accordance with North East Atlantic Fisheries Commission (NEAFC) rules. Further details of ports in this category are available online.
EU vessels will need to submit a NEAFC Port State Control form (PSC1 or PSC2). EU vessels will also need to complete a prior notification form and pre-landing declaration.

Further details are available online.

Additional requirements for endangered species listed under CITES

Imports of food products or live animals 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 1.2.2. These include the requirement for relevant EUWTR export permits form the country of departure and UKWTR import permit issued by APHA.

Locations of checks

Imports of fish as animal products and live animals will not be subject to controls at the border until July 2021 – see 3.2.3.
Direct landings of marine-caught fish will need to be landed at a designated GB port as listed by the North East Atlantic Fisheries Commission. Direct landings exempt from BCP inspection, must additionally land at an IUU designated port.

The vessel must also give 4hrs notice to UK authorities, submit a prior notification document, a pre-landing document and a catch certificate for the fish that is being landed.
All catch certificates will need to be checked and authorised prior to landing. These checks are carried out away from the border. For fishery products (includes fish), direct landings by EU registered fishing vessels will also become subject to landing in IUU designated ports.
5% is the IUU regulation benchmark for port inspection of 3rd country vessels (which would include EU vessels). This is determined by species of fish caught, previous catch behaviour and/or country flag.

Systems

The importer will need to register for IPAFFS here.

Process Map: Fish as Animal Products

Process Map: Fish as Live Animals

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

New import requirements for High-Risk Food and Feed Not of Animal Origin (HRFNAO) will apply from April 2021. This does not, however, include the requirement for entry via a Border Control Post; this will come into place in July 2021 – see 3.2.4.

Whilst there is currently no HRFNAO originating from within the EU, these requirements will apply to third country HRFNAO imported into the EU and subsequently exported to the UK.

HRFNAO that originates from RoW will need to be controlled on entering the UK from 1 January 2021 (see 1.2.3)
HRFNAO that falls within the scope of regulated plants and plant products will also be subject to these requirements. Further information on these is available in 2.2.3.

Requirements

From April 2021, High-Risk Food and Feed Not of Animal Origin (HRFNAO) will be subject to new import requirements.

Whilst there is currently no HRFNAO originating from within the EU, these requirements will apply to third country HRFNAO imported into the EU and subsequently exported to the UK.

These include the requirement for import pre-notifications to be submitted in advance of the goods’ arrival. Importers will need to submit pre-notifications via IPAFFS.

This does not include the requirement for entry via a Border Control Post (BCP) or identity or physical checks at the border. However, these controls will be introduced in July 2021 – see SECTION 3.2.3.
RoW-originating HRFNAO that transits the EU will continue to need to be pre-notified on the Import of Products, Animals, Food and Feed System (IPAFFS) and enter the UK at a BCP approved for HRFNAO in the same way as similar consignments imported directly from a third country – see 1.2.3 for further information.

Where applicable, regulated plants will also need to be accompanied by a Phytosanitary Certificate as outlined elsewhere in this document.

Additional requirements for high-risk plants and products
HRFNAO also includes imports of some controlled plants and plant products – such as apples, lettuce, and all solanaceous fruits (e.g. tomatoes, aubergines). Imports of HRFNAO within this category will also need to meet phytosanitary controls as detailed in 2.2.3.

Location of checks

With the exception of RoW-originating HRFNAO transiting the EU, HRFNAO will not be subject to controls at the border until July 2021 – see 3.2.3 for those requirements.
Systems
The importer will need to register for IPAFFS.

Process Map: HRFNAO
As there is currently no EU origin HRFNAO, this step will only be applicable to third country HRFNAO which has been cleared for placing on the EU market before moving to the UK. This is distinct from transits of third country HRFNAO through the EU which will not have been cleared on entry into the EU.

Live Animals and Germinal Products

Equines

Plants and Plant Products
Requirements

From 1 April 2021, new requirements will apply to all regulated plants and plant products. This includes the requirement for:
• goods to be accompanied by a phytosanitary certificate
• import pre-notification submitted by the GB importer
• documentary and identity checks and physical inspection (frequency dependent on risk)

This will apply to all regulated plants and plant products, which includes high-risk plants and plant products as detailed in SECTION 1.2.3. An exhaustive list of the regulated plants and plant products that will require a phytosanitary certificate and pre-notification of import from 1 April 2021 will be published in due course and will include:
• all plants for planting;
• root and tubercle vegetables;
• some common fruits other than fruit preserves by deep freezing;
• some cut flowers;
• some seeds and grains;
• leafy vegetables other than vegetables preserved by deep freezing;
• potatoes from some countries;
• machinery or vehicles which have been operated for agricultural or forestry purposes.

All regulated plants and plant products imported from the EU will need to be accompanied by a phytosanitary certificate and may be checked upon entry into GB. 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.

The exporter will need to apply for a phytosanitary certificate from the relevant competent authority of the EU country of origin; this will need to be secured prior to the goods’ departure so that it can be sent to the importer for pre-notification purposes.

Importers will need to submit import notifications at least four hours prior to arrival if travelling by air, or at least one working day prior to arrival by all other modes of transport– along with the original phytosanitary certificate.

Checks will be carried out by Plant Health and Seed Inspectors (PHSI) from the Animal and Plant Health Agency (APHA) and the Forestry Commission (FC) in England and Wales, and the Scottish Government in Scotland. Physical inspections will take place at destination or another authorised premises.

Further information is available here.

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 in SECTION 1.2.3
Plants and plant products that fall under endangered species regulations (CITES/UKWTR) have further requirements as detailed in SECTION 1.2.2.

Locations of checks

Depending on the risk category, regulated plants and plant products will be subject to documentary checks either at or away from the border; they may also be subject to identity and physical checks.

Documentary checks entail examination of official certifications, attestations and other commercial documents that are required to accompany the consignment.
An identity check entails a visual inspection to verify that the contents of a consignment corresponds to the information provided in the accompanying documentation.
A physical check entails a check on the goods to verify that they are compliant with the phytosanitary import requirements of the country of destination. This includes, as appropriate, checks on the consignment’s packaging and means of transport. Sampling for laboratory testing or diagnosis may also be required.
Information on the location where checks will take place will be provided on GOV.UK in due course.

Systems

For all regulated plants and plant products, the importer will need to have registered via the relevant IT system. For England and Wales this will be IPAFFS; further information will be available shortly for Scotland.
Importers in England and Wales can register for IPAFFS online.

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 GB to verify compliance with the ISPM15 requirements.
Further details on ISPM15 requirements can be found online here.

Process map: Plants and Plant Products