New controls and requirements delayed to 2023

Following the government announcement on 28 April 2022, we want to share some further information on what this might mean for your businesses.

New controls and requirements due to be introduced from 1 July 2022 will no longer go ahead as part of a new approach. 

The proposed controls, which would have required Export Health Certificates (EHCs) for the majority of products of animal origin (POAO) imports and physical examinations of Sanitary and Phytosanitary (SPS) goods from the EU, will be reviewed to produce a Target Operating Model in autumn 2023. This new model will aim to lay out a new regime of controls for implementation by the end of 2023.  

This means businesses no longer need to acquire a certified EHC from the 1 July 2022, and can continue to import animal product consignments from the EU until further notice.

These delays do not impact any arrangements already in place, i.e. products under safeguard measures.

From 1 January 2022, importers – or representatives acting on their behalf – are required to pre-notify authorities via IPAFFS that their consignment will be entering Great Britain.

If you haven’t already registered for IPAFFS, please do so now at gov.uk

For any further questions, please email the Trader Readiness Team at traders@defra.gov.uk

Questions and Answers

• How and where will I need to pre-notify my goods from 1 January 2022?

IPAFFS is the import of products, animals, food and feed system (IPAFFS) and is the system used to notify the arrival of imports of live animals, animal products and high-risk food, as well as feed not of animal origin.

It is the responsibility of the GB importer (or a representative acting on their behalf) to register for IPAFFS and pre-notify the relevant authority of the goods’ arrival. If an EHC is required for the commodity, the EU exporter should provide the GB importer with an electronic copy of the EHC and the GB importer must upload this on to the notification in IPAFFS.

You can register for IPAFFS on gov.uk

• What controls are in place for HRFNAO and Plastic kitchenware imports from the EU?

From January 2022, High Risk Food and Feed Not of Animal Origin (HRFNAO) will be subject to new import requirements. Information on products classed as HRFNAO can be found here.

Whilst there are currently no HRFNAO originating from within the EU, these requirements will apply to non-EU HRFNAO imported into the EU and subsequently exported to GB.

Importers will be required to submit import pre-notifications (IMPs) in advance of the goods’ arrival. Importers will need to submit pre-notifications via IPAFFS. Details on creating the IMP can be found here.

These consignments can enter at any GB port.

• What controls are in place for transits of HRFNAO and Plastic kitchenware imports?

It has been the case since 1^st January 2021 that any non-EU originating HRFNAO that transits the EU for import into GB needs to enter GB via an established point of entry with an appropriate BCP approved for HRFNAO, in order to undergo full import checks.

Consignments in this category will not have been controlled upon entry to the EU as they are not intended to be placed on the EU market, allowing them to travel through the EU under Customs seal for import into GB.

Details on the import checks for such consignments can be found here.

• My composite product is exempt from certification, will I need to pre-notify its arrival into Great Britain?

No, if your product meets the requirements for exemption from Sanitary and Phytosanitary (SPS) controls you do not need to pre-notify authorities of its arrival.

Further information is available on gov.uk

• Does the delay remove any controls from products under safeguard measures?

No, products being imported under safeguard measures must continue to follow existing requirements and controls.

Import requirements are already in place for a small number of POAO subject to safeguard measures.

Emergency safeguard action can be taken at very short notice to prohibit or restrict the importation of certain products from certain countries following an outbreak of disease or a public health issue, such as avian or swine flu.

Information on the latest updates concerning disease outbreaks which may affect imports into the UK can be found on gov.uk

POAO subject to safeguard measures are required to be pre-notified in advance of arrival using IPAFFS and all goods must be accompanied by an Export Health Certificate.

The GB importer will also need to supply the EU exporter/ Certifying Officer (usually an Official Veterinarian) with the unique notification number (UNN) that is produced when the importer notifies the UK’s Animal and Plant Health Agency (APHA) about the import.

The exporter must add the UNN to the Export Health Certificate. If the safeguard measure is in place due to a new or emerging disease outbreak, and the commodity code is not available in IPAFFS, there may be other steps traders need to take to pre-notify.

Further information can be found at gov.uk

• Does this impact the introduction of new EHCs for goods exported to the EU or moved to NI from Great Britain as part of the Animal Health Regulation?

No, Animal Health Regulations EHCs apply to goods being exported from GB to the EU or goods moving from GB to NI only. The changes in this communication relate to goods being imported from the EU into Great Britain only.   

Please note that is the responsibility of the importer to be aware of the conditions of importation to GB.

More information can be found on the Border Operating Model published by gov.uk:

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1004070/2021_July_BordersOPModel_Publishing__2_.pdf