HOW TO IMPORT OR MOVE HIGH-RISK FOOD AND FEED OF NON-ANIMAL ORIGIN (HRFNAO) FROM THE EU INTO GREAT BRITAIN
The introduction of the Border Target Operating Model (BTOM) on 30th April 2024 now means that all imports of high-risk food and feed are subject to import controls at the GB border. This applies to products coming directly from the country of origin and to products being dispatched from an EU country or another country that is not the country of origin.
Details of the requirements are available on the UK Government website: Import high risk food and feed of non-animal origin from the EU to Great Britain – GOV.UK (www.gov.uk)
HRFNAO includes:
- Food and feed listed in assimilated Regulation (EU) 2019/1793, Regulation (EU) 2020/1158 and Decision 2011/884/EU. These products require a CHEDD to be created on IPAFFS: NAO Requiring CHED-D List – SCPHA (porthealth.uk)
- Melamine and Polyamide plastic kitchenware from China and Hong Kong. You must complete a PDD (Plastic Declaration Document) on PHILIS DES: Plastic Kitchenware – SCPHA (porthealth.uk)
HRFNAO processed in the EU:
If HRFNAO has been imported to the EU and then processed, it is no longer considered high risk.
Please note there is a legal definition of ‘processing’ which must be met. It can be found in Article 2 of assimilated Regulation (EC) No 852/2004.
Repackaging foods or grinding spices do not meet this definition.
Health certificate and Laboratory reports
In addition to completing the CHEDD in IPAFFS you will need a laboratory report and a health certificate (also called an ‘official certificate’) if you import the following HRFNAO:
- Products listed in Annex II of assimilated Regulation (EU) 2019/1793.
- Chernobyl affected products listed in Annex II of assimilated Regulation (EU) 2020/1158.
- Rice products from China listed in Annex I of assimilated Decision 2011/884/EU.*(see notes below).
The model health certificates can be found on the following website: High risk food and feed not of animal origin (HRFNAO): model health certificates – GOV.UK (www.gov.uk)
Please ensure you use the correct model for the product being exported to GB.
Health certificates
The EU exporter must:
- Apply for the export health certificate (EHC) in their own country.
This means that, for example, Dried Figs from Turkey that have been stored in The Netherlands before being shipped to GB must be accompanied by an EHC issued by the competent authority in The Netherlands. The health certificate used to import the goods into the EU is not acceptable.
Laboratory reports
Laboratory analyses must cover the contaminant(s) specified as an issue for that product. Laboratory analyses must be dated no more than 6 months before the date of issue of the health certificate.
The Food Standards Agency (FSA) have advised us of the following:
- the results of sampling and analyses should be performed by the competent authority of the country of dispatch.
*Rice and Rice products from China
Please note: rice and rice products controlled by assimilated Decision 2011/884/EU that have been imported into the EU and stored before being shipped to GB will not be permitted.
The FSA have advised that this is because assimilated Decision 2011/884 does not have provisions allowing consigning countries to complete the paperwork. Article 4 requires that the consignments are accompanied by an analytical report and a certificate, which are completed, signed, and verified by an authorised representative of the ‘Entry Exit Inspection and Quarantine Bureau of the People’s Republic of China’ (AQSIQ). If the consignments come with the EU certificate, we would advise that it is non-compliant and could be rejected due to a documentary failure.
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