1.1.1      Goods Subject to Sanitary and Phytosanitary Controls

Various new Sanitary and Phytosanitary controls will apply to goods imported from the EU from 1 January 2021. Details of the controls which will apply are in the following sections.

Key definitions for traders

Controls from 1 January 2021 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 January 2021, high-risk Animal By-Products (ABP) – such as Category 1 material, Category 2 material and meat-and-bone meal or animal fat derived from Category 1 and Category 2 materials and Category 3 processed animal protein (PAP) – will be subject to the following import requirements.

Guidance on what constitutes high-risk ABP is available online here. This includes the requirement for:

• Pre-authorisation by Defra/APHA of Category 1 material, Category 2 material and meat- and-bone meal or animal fat derived from Category 1 and Category 2 materials prior to any imports taking place
• Import pre-notifications submitted by the importer on the domestic notification system (IPAFFS) in advance of the goods’ arrival (in line with existing requirements for imports of high-risk ABP from the EU)
• Goods to be accompanied by the current official ABP commercial documentation

The requirement for most ABPs to be accompanied by official commercial documentation when imported from the EU will remain from January 2021. Detail on the information that must be contained in commercial documentation can be found at the link above. Contact APHA if you’re unsure whether you need a commercial document.

All other ABP consignments will still need to be accompanied by the current official ABP commercial documentation without the need for pre-notification.

This does not include the requirement for goods to be accompanied by an Export Health Certificate, enter via a Border Control Post, or undergo identity or physical checks at the border. However, these controls will be introduced in July 2021 – see SECTION 3.2.3.

Regular auditing of premises importing ABP goods, where the commercial documents will be checked, will continue as part of the UK Government’s national inspection regime to tackle disease and fraud risk for all ABP products, including EU imports.

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. Imports 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 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.

Systems

The importer will need to register for IPAFFS.

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 and shellfish and their products originating from the EU will be subject to sanitary and phytosanitary import controls, similar to those applying to animal products and live animals. However, some aspects will not take effect until April 2021 or July 2021.

In addition, most imports of marine-caught fish and some 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 competent authority of the country the fishing vessel is registered to; this will need to be secured by the EU exporter.

Imports of non-marine-caught fish (e.g. farmed fish or 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)

In line with rules for animal products, imports of fish and shellfish as animal products will not be subject to new SPS import controls until April 2021 – see 2.2.3.

Requirements for fish as live animals (e.g. ornamental fish)

In line with rules for live animals, imports of fish as live animals will be subject to new import controls from January 2021.

This includes the requirement for:

• goods to be accompanied by an Export Health Certificate (EHC).
• import pre-notifications submitted by the importer in advance of

EHCs 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; an importer of live fish/shellfish must be authorised by CEFAS before importing. In Scotland, individual importers do not require authorisation but relevant authorities may need to confirm that the consignment is destined for an authorised facility. Depending on the type of animal, specific welfare requirements may apply including the need for Transporter Authorisation and specifically approved transportation vehicles.

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

The GB importer will also need to submit a notification via the Import of Products, Animals, Food and Feed System (IPAFFS) in advance of the goods’ arrival.

Additional Requirements for direct landings of marine-caught fish and shellfish and their products by EU registered fishing vessels

If an EU registered fishing vessel wishes to land its catch directly into GB 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.

Requirements for direct landings of marine-caught fish

Fish will need to be landed at an appropriately designated (i.e. in line with llegal, Unreported, Unregulated fishing regulation (IUU)) GB port and according to the species being landed must also land in ports listed under the North East Atlantic Fisheries Commission (NEAFC) protocol. Further details of ports in this category are available 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 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 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 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 new controls at the border until July 2021 – see 3.2.3.

From January 2021, direct landings of marine-caught fish, which are subject to the North East Atlantic Fisheries Commission (NEAFC), will need to be landed at a designated GB port as listed by the NEAFC.

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 Illegal, Unreported Unregulated fishing regulation (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

For import pre-notifications for fish as live animals, the importer will need to register for IPAFFS.

Process Map: Fish Direct Landings

Process Map: Fish as Live Animals

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

Requirements

There is currently no EU-origin HRFNAO. Therefore, any HRFNAO will have originated from a third country, and will have been controlled at the EU border. If these ‘EU cleared’ HRFNAO are subsequently imported into the UK, they will be treated as EU-origin and will be subject to new import requirements from April 2021 – see SECTION 2.2.3.

However, RoW-originating HRFNAO that transit the EU from 1 January 2021 will not be controlled at the point of entry into the EU. They will be allowed to travel through the EU under Customs seal to the UK, so will need to be controlled at a UK BCP approved for HRFNAO from 1 January 2021. A list of current BCPs and the commodities they accept is available here.

The UK Government is currently exploring options to build more BCPs and to provide targeted support to ports to do so. Therefore, this list will likely change to include further sites. These changes will be made public in order for traders to prepare accordingly.

Additional requirements for high-risk plants and plant 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 any relevant phytosanitary controls as detailed in 1.2.3.

Process Map: Third Country Transit via EU

Live Animals and Germinal Products

Requirements

From January 2021, new import requirements will apply to live animals and germinal products from the EU.

This includes the requirement for:

• goods to be accompanied by an Export Health Certificate (EHC).
• import pre-notifications submitted by the importer via IPAFFS in advance of arrival

This does not include the requirement for entry via a Border Control Post (BCP); this will not come into force until July 2021 – see 3.2.4.

From January 2021, all live animals and germinal products will need to be accompanied by an Export Health Certificate (EHC); 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; an importer of live fish/shellfish must be authorised before importing. 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

Depending on the type of animal, specific welfare requirements may apply including the need for specifically approved transportation vehicles, and certificates of competence 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 accompany the consignment.

Details on these are available online.

The GB importer will also need to submit a notification via the Import of Products, Animals, Food and Feed System (IPAFFS) in advance of the goods’ arrival.

Additional requirements for endangered species and marine-caught fish

Imports 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 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.

Import of live, marine-caught fish will also need to meet catch certificate requirements as detailed in 1.2.3.

Location of checks

From January 2021, consignments from the EU can continue to enter at any point of entry and do not need to enter via a BCP until July 2021 – see 3.2.4.

Documentary checks will occur remotely, and identity and physical checks on live animals will be undertaken at the point of destination on a risk-led basis until July 2021.

A documentary check entails an examination of the official documents which are required to accompany the consignment, a visual inspection to verify the content of the consignment – including the marks on animals – correspond 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 importer will need to register for IPAFFS.

Process Map: Live Animals and Germinal Products

Equines

Requirements

From January 2021, new import requirements will apply to equines from the EU. This includes the requirement for

• goods to be accompanied by an Export Health Certificate (EHC).
• import pre-notifications submitted by the importer in advance of arrival

This does not include the requirement for entry via a Border Control Post (BCP); this will not come into force until July 2021 – see 3.2.4.

From January 2021, all equines will need to be accompanied by an Export Health Certificate (EHC); this will need to be secured by the exporter from the EU country of origin’s competent authority. The GB importer will also need to submit a notification via the Import of Products, Animals, Food and Feed System (IPAFFS) in advance of the goods’ arrival.

The driver of the equine transportation would also require a Certificate of Competence, a valid Vehicle Approval Certificate, from Defra, and Transporter Authorisation, from APHA. A journey log would also need to be submitted to APHA and accompany the equine in certain cases.

Details on these are available online.

Location of checks

From January 2021, consignments can continue to enter at any point of entry and do not need to enter via a Border Control Post.

Documentary checks will occur remotely, and identity and physical checks on equines will be undertaken at the point of destination on a risk-led basis. A documentary check entails an examination of the official documents which are required to accompany the consignment, 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 importer will need to register for IPAFFS here. 4

Process Map: Equines

Plants and Plant Products

Requirements

From 1 January 2021, new requirements will apply to imports of high-risk plants and plant products. This includes the requirement for:

• goods to be accompanied by a phytosanitary certificate,
• import pre-notification to be submitted by the GB importer,
• documentary and identity checks and physical inspection

An exhaustive list of the high-risk plants and plant products that will require a phytosanitary certificate and pre-notification of import from 1 January 2021 will be published in due course. It will include all plants for planting; ware potatoes; some seed; some timber; and used agricultural/forestry machinery. In addition, for solid fuel wood not otherwise regulated, pre- notification will be required but a phytosanitary certificate will not.

All high-risk 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 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. Guidance on what this entails will be available in due course.

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 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.

Locations of checks

High-risk plants and plant products will be subject to documentary, identity and physical checks. A documentary check entails the 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 correspond with 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 for where physical checks will take place will be provided on GOV.UK in due course.

Systems

For 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 here.

Process Map: Plants and Plant Products