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Changes to Customs Regulations

As a result of Brexit, the government is continuing to implement customs-related measurements as well as additional checks that will be required for specific categories of goods as of 1 January. The changes were originally scheduled for 1 October but have recently been postponed by the UK government until January 2022. It is very important that these changes be observed and, if necessary, discussed with your logistics provider.

It is impossible to list every item individually. However, broadly these cover:

Products Of Animal Origin (POAO)
Any animal products that are for human or animal consumption, such as (but not limited to):

  • Meat, including fresh meat, meat products, minced meat, meat preparations, poultry meat, rabbit, farmed game meat, and wild game meat
  • Eggs and egg products
  • Milk and milk products
  • Honey, Gelatine and Gelatine products

Animal By-Products (ABP)
The following include materials of animal origin that are not meant for human consumption:

  • Animal feed consisting of fish meal and processed animal protein
  • Organic fertilizers and soil improvers
  • Technical products such as pet food, hides/skins, blood

 Composite products:

  • These products are the most difficult to categorize, however they essentially refer to foodstuffs that contain both processed products of animal and plant origin. These include products where the processing of the primary product forms an integral part of the production, e.g., lasagne, chicken wraps, pizza, cream liqueurs

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

  • Regulated plant and plant products
  • Live animals and germinal products
  • Fish

CITES goods:

  • Endangered animal or plant species

Carnet:

  • This refers to a passport for goods moving temporarily between different countries and must be presented to customs officials at borders, e.g., exhibition goods, professional tooling

Requirements for Exporters:

  • Must ensure that the goods meet UK import requirements and have been exported by an approved establishment and country. If unsure, this must be checked by a competent EU authority
  • Must make sure the importer is aware of GB import requirements
  • Must apply for an Export Health Certificate (EHC)
  • Must send a copy of the EHC to the importer
  • The original EHC must travel with the goods. If this is not possible (unaccompanied trailer) then the original must be presented to the Port Health Authority before arrival
  • Must supply a copy to the GB importer
     

Requirements for Importers:

  • Must check requirements with AHPA (Animal and Plant Health Agency)
  • Must pre-notify the relevant Port Health Authority by IPAFFS (Traces for NI) and upload a copy of the EHC. It is mandatory to do this at least 4 hours prior to arrival at the destination port
  • Must present transit health certificates required for landbridge movements
  • Must carry out live animals and fish SPS checks at importer’s premises
  • Must ensure that any other permits/licenses required for import into GB are in place and notified to GB clearance agent e.g., Certificate of Inspection (organic), Catch certificates, CITES license, Phytosanitary certificates

In addition to 1 January 2022 requirements, the following changes will take place from 1 July  2022:

  • Inbound Safety and Security (ENS) declarations required for all exports to GB, not just SPS (controlled goods)
  • Pre-notified timescales – must be 4 hours for RoRos and live animals 1 day in advance – this are liable to change
  • Goods must enter via a port of entry that operates a BCP (Designated Border Control Post) for physical checks
  • Penalties for non-compliance now in place - penalties to be determined
  • Additional risks as all goods will now be physically checked

  • If a shipment is non-compliant then all goods will have to be inspected at a GB Designated Border Control Post (BCP). The goods may also be subject to seizure
  • This is a significant risk if the goods are moving under groupage as the whole trailer will be delayed until the examination and checks have been carried out
  • The responsibility for compliance from the GB authorities is that of the importer/exporter. There is a risk that certain customers may not have the appropriate knowledge to fully comply with the new requirements

    To try to give some perspective on the complexity when last checked there are 290 different model EHC certificates which can apply. Comprised of:
    – 53 for ABP only
    – 74 that apply to live animals
    – 13 for equines
    – 33 for germinal products
    – 113 for products of animal origin
    – 4 for HRFNO (High Risk Food of Non-Animal Origin)
  • This excludes any non-harmonised products- These will need a tailored certificate devised by the APHA (Animal and plant health agency)

As of October 2021 – this information is supplied without liability.