Exporting or moving high risk food and feed of non-animal origin to the EU or Northern Ireland from 1 January 2021
Last updated 30 December 2020
Some non-animal food and feed products from certain non-EU countries present risks to human health because of aflatoxins, pesticides, salmonella or dioxins. These high-risk food and feed of non-animal origin (HRFNAO) must meet more requirements to be imported to EU member states or moved into Northern Ireland (NI) than low risk food and feed products.
There is no HRFNAO listed in legislation 2019/1793 originating in the UK.
The rules apply to HRFNAO that you have imported from non-EU countries to GB (England, Scotland and Wales) and then re-export to the EU or move into NI.
Exporting HRFNAO from GB to the EU or moving it to NI
The EU will no longer recognise UK import controls as satisfying EU import requirements.
To export to the EU or move to NI HRFNAO in Annex 1 of regulation 2019/1793:
- you must include commercial shipping documents, such as the invoice, shipping document and bill of lading with the HRFNAO
- your EU or NI-based import agent must pre-notify the arrival of the consignment on TRACES NT
You must meet more requirements to export to the EU, or move to NI, HRFNAO listed in:
- Annex 2 of regulation 2019/1793
- Annex 1 of regulation 2020/1158 - HRFNAO following the Chernobyl power station accident
- Annex 2 of regulation 2019/1793 that are processed and repackaged into a new compound food - a final product that contains more than 20% high risk ingredients listed in Table 1 (for example, peanut butter which contains 20% or more of groundnuts from Argentina is a compound food)
For these HRFNAO you must:
- get an official certificate
- get the HRFNAO sampled in an approved UK laboratory - the lab will give you a sampling report
These rules apply to the HRFNAO in Annex 1 of regulation 2020/1158 following the Chernobyl power station accident that either:
- originate from GB
- are imported to GB before being re-exported or moved to the EU or NI
Follow these steps to meet EU requirements to export these HRFNAO from GB to the EU or move them to NI from 1 January 2021.
Get an official certificate and laboratory analysis report
You complete part 1 of the:
You email the official certificate to your local authority.
You contact your local authority to:
- find a certifying officer who can sign your certificate
- request a site visit
Check that your certifying officer is qualified to inspect your product.
- visits your site to oversee sampling
- sends samples to an official laboratory with a unique reference number (URN) that they give your consignment
- gets the samples and does the testing
- gives results or analysis to the certifier
- completes part 2 of the official certificate
- returns laboratory results and report and the completed official certificate to you
You send copies of the official certificate and sampling results or analysis report to the EU import agent. The original official certificate and sampling results or analysis report must travel with the goods.
The EU import agent uploads the copies onto the TRACES notification required for entry to the EU.
Send your HRFNAO to an EU border control post or NI point of entry
You must send your export to:
- an EU border control post (BCP) approved to accept your HRFNAO
- a designated point of entry in NI
Your EU or NI import agent must:
- pre-notify the BCP or point of entry of your goods on TRACES at least 24 hours before arrival
- fill in Part I of the Common Health Entry Document (CHED-D)
Your EU or NI import agent will upload to TRACES:
- the official certificate
- analysis report
- any commercial documents
Your consignment must arrive in the EU at the BCP or the point of entry in NI that used in the pre-notification.
At the BCP or point of entry, the consignment must have the:
- original official certificate
- laboratory analytical report
Currently, points of entry in NI can accept the original official certificate within 10 working days of the arrival of your consignment, so long as you have supplied the documents on TRACES. This is a temporary measure because of COVID-19 so you should check with the BCP or point of entry for their specific arrangements.
The BCP or point of entry will carry out checks, which may include:
- documentary checks
- ID checks
- physical checks (including sampling and analysis)
If the BCP or point of entry selects your consignment for sampling they will detain it until sample results are available.
Release of the consignment
The BCP or point of entry will record the checks on Part II of the CHED-D on TRACES.
If the checks are successful, the BCP or point of entry will release your consignment.
If your goods fail inspection at a BCP
If your HRFNAO fail inspection because of risks to animal or public health, they will be destroyed immediately.
If the goods fail for other reasons, the BCP will:
- notify your importer or NI-based agent
- ask your importer or NI-based agent to decide whether your goods should be destroyed or returned to GB
The BCP will not usually contact you directly.
Banned exports or movements of HRFNAO from GB to EU or NI
You will not be able to export to EU or or move NI products listed in regulations:
Grace period for authorised traders moving food from GB to NI
There will be a 3 month grace period from certification through to 1 April 2021 for authorised traders such as supermarkets and their trusted suppliers from 1 January 2021.
If you're moving HRFNAO from GB to NI, you will not require official certification, such as export health certificates, phytosanitary certificates or marketing standards certification.
The UK government and the NI Department for Agriculture, Environment and Rural Affairs will engage in a rapid exercise to ensure that traders who can benefit from these arrangements are identified prior to 31 December.
The government will not discriminate against smaller suppliers or between different companies in implementing these practical measures.
The following conditions will be attached to these arrangements:
- the goods are packaged for end consumers and they bear a label reading "These products from the United Kingdom may not be marketed outside NI"
- they are destined solely for sale to end consumers in supermarkets located in NI, and they cannot be sold to other operators of the food chain
- they are accompanied by a simplified official certificate globally stating the products meet all the import requirements of EU legislation
- they enter NI through a designated point of entry, where they are submitted to a systematic documentary check and to a risk-based identity check on a selection of items in the means of transport
- they are monitored through a channelling procedure applicable from the designated point of entry to the destination supermarket in NI
Exporting HRFNAO from Northern Ireland to the EU
HRFNAO moving between NI and the EU will not have to meet any notification, certification or sampling requirements. The EU will treat this as an intra-EU movement from an sanitary and phytosanitary perspective.