Updates to HRFNAO Import Requirements Effective December 2024
New legislation will change what Non-Animal Origin (NAO) food and feed are classed as high-risk and therefore require health checks when being imported into Great Britain. Importers and agents should familiarise themselves with the below changes and ensure they submit accurate documentation for their consignments. The full legislative changes can also be viewed here: The Official Controls (Import of High-Risk Food and Feed of Non-Animal Origin) (Amendment of Commission Implementing Regulation (EU) 2019/1793) (England) (No. 2) Regulations 2024 .
For products being imported into Northern Ireland, please refer to the responsible port health authority in Northern Ireland.
NEW PRODUCTS REQUIRING CHED-Ds AND SPECIFIC HEALTH CHECKS
Importers (or their representative) will need to submit CHED-Ds, and any other required documentation, when importing the following products into Great Britain that have an arrival date on or after 18th December 2024:
- Groundnut paste from Argentina
- Granadilla and Passion fruit from Colombia*
- Bananas from Ecuador**
- Hazelnuts and their products from Georgia (specifically mixtures of nuts containing hazelnuts, hazelnut paste and hazelnut oil)
- Basil (holy, sweet) from Israel
- Mint from Israel
- Cumin seeds (whole) under CN code 0909 3100 from India***
- Crushed and ground cumin seeds under CN code 0909 3200 from India***
- Fenugreek leaves from India
- Yardlong beans from India
- Mukunuwenna (sissoo spinach, sessile joyweed) from Sri Lanka
- Groundnut paste from Madagascar
- Grapefruits from Turkey
- Sesamum seeds from Turkey
- Tahini and halva made using sesamum seeds from Turkey
* These products are already in Annex I. The ‘new’ legislation has updated the tariff codes to 0810 9020 40 and 0810 9020 50.
**These products are already in Annex I. The ‘new’ legislation has updated the tariff code to 0803 90.
***These products are already in Annex I but have been mentioned separately in the ‘new’ legislation in order to make it clear that these items need separate CHED-Ds.
PRODUCTS NO LONGER REQUIRING CHED-Ds AND SPECIFIC HEALTH CHECKS
Importers (or their representative) will no longer need to submit CHED-Ds for the following products that have an arrival date on or after 18th December 2024 into Great Britain, as they will not be subject to specific health checks:
- Groundnuts and their products from Brazil
PRODUCTS MOVING FROM ANNEX II TO ANNEX I
Products that are moving from Annex II to Annex I in the new legislation will still require CHED-Ds to be submitted to port health prior to their arrival in Great Britain. However, they will no longer require health certificates or test reports to be submitted to port health****.
The health certificate and test results removal applies to consignments leaving their countries of origin on or after 18th December 2024, which will be determined by the loading dates displayed on bills of lading:
- Guar Gum from India
- Nutmeg from India
- Dried, roasted, crushed or ground peppers of the genus Capsicum (sweet or other than sweet) from India for aflatoxin controls have moved from Annex II to Annex I. ****However, they remain in Annex II for pesticide residues controls. This means that the health certificate and test report need to relate to pesticide residues only.
PRODUCTS MOVING FROM ANNEX I TO ANNEX II
Products moving from Annex I to Annex II in the new legislation will now require original health certificates and copies of test results to be submitted to port health along with CHED-Ds. The format of the health certificates can be found on the Gov website: https://www.gov.uk/government/publications/high-risk-food-and-feed-not-of-animal-origin-hrfnao-health-certificates (Certain food or feed GBHC176).
The requirement for a health certificate and test report applies to consignments leaving their countries of origin on or after 18th December 2024, which will be determined by the loading dates displayed on bills of lading:
- Tea from China
SAMPLING FREQUENCIES
To see the health controls (hazards) and sampling frequencies that will apply to each product with an arrival date on or after 18th December 2024 into Great Britain, please refer to the tables in Schedules 1 and 2 in the new legislation The Official Controls (Import of High-Risk Food and Feed of Non-Animal Origin) (Amendment of Commission Implementing Regulation (EU) 2019/1793) (England) (No. 2) Regulations 2024.
There are a number of changes to previous sampling frequencies.
Increasing are:
- Guar Gum from India up from 5% to 20% of consignments to be sampled by port health for Pentachlorophenol and dioxins.
- Nutmeg from India up from 20% to 50% of consignments to be sampled by port health for aflatoxins.
- Sesamum seeds from India up from 20% to 30% of consignments to be sampled by port health for Salmonella.
Decreasing are:
- Sesame seeds from India down from 50% to 30% of consignments to be sampled by port health for pesticides residues and ethylene oxide.
- Tea from China down from 20% to 5% of consignments to be sampled by port health for pesticide residues.
Tables – all of the above changes are shown in the SCPHA tables (for reference only, full details are in the legislation).
BANNED PRODUCTS
There are no changes. Dried beans from Nigeria for food use continue to be banned from import into Great Britain. A CHED-D will be required and the product will be rejected from import.
IMPORTING HRFNAO FROM EU COUNTRIES INTO GREAT BRITAIN
Please ensure you are familiar with the requirements for importing HRFNAO from the EU into GB – https://www.gov.uk/guidance/import-high-risk-food-and-feed-not-of-animal-origin-from-the-eu-to-great-britain
If you have imported HRFNAO into the EU and had full CHED-D checks at the EU border and you simply store the products in the EU without further processing (note: repackaging does not count as processing) before shipping them to GB, you will need to go through the process again at the GB border (CHED-D on IPAFFS with required documentation, and sampling).
For example, if you import Dried Figs from Turkey into the Netherlands (CHED-D, health certificate, results report) and receive full clearance, and then export some/all of this consignment to GB you will need to create a GB CHED-D on IPAFFS, submit an original Netherlands issued health certificate along with a copy of test results for aflatoxin as well as commercial documentation to port health.
FURTHER INFORMATION
Further information on importing non-animal origin products into Great Britain can be found here https://www.porthealth.uk/import-guidance/non-animal-origin/
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