Brexit transition Q&As - Movement of Products of Animal Origin (POAO)

Brexit transition questions and answers related to movement of Product of Animal Origin (POAO)

General

We are a Northern Ireland (NI) meat producer. From 1st April if we are using the shipping route Rosslare to EU mainland (not using GB land bridge) do we need an Export Health Certificate (EHC)?

No – POAO from NI can move freely to RoI and between Member States without EHCs (commercial documentation only)

Is there any change in bringing in powdered lactose for brewing beer from GB to NI?

After considering the requirements of Regulation (EU) 2019/2007 and regulation 2019/628, we have concluded that for import of lactose EHC 8348 is required.

Will a NI commercial document accompanying the transport of milk products (e.g. buttermilk) between Food Business Operator’s (FBO’s) from NI to Republic of Ireland (ROI) for use as an ingredient continue to be sufficient for the Department of Agriculture, Food and Marine (DAFM in ROI) to rely upon when signing export certificates for finished products? 

In theory, yes, but it depends on the ultimate destination after ROI.

You will need to check with the exporter who should ask their DAFM certifying vet.

We supply pasta sauces from GB containing cooked chicken and beef to NI. Is Traces required?

You will need the appropriate EHC and to notify the Point of Entry in NI via TRACES NT.

We buy cheese which is a Product of Animal Origin (POAO), from GB. It is a pallet made up from several producers in the area. Do we need an EHC for each product or each pallet? Also we then send some of the product on to EU along with our cheese. Do we need a new EHC for this?

You will need an EHC to import cheese to NI from GB. The EHC required depends on the treatment the milk had: if pasteurised EHC 8285 and if unpasteurised EHC 8287. All of one type can go on one EHC although you may need to attach a schedule if there is a lot of information.

Cheese exported from NI to EU moved directly or via the GB land-bridge does not require an EHC if staying in the EU. If travelling to EU via GB land-bridge, the importer must pre-notify the border control post at point of entry to the EU.

Is there a basic flow chart that would outline how to get a consignment of cheese from England (whole wheels of cheese, not for retail but for catering)?

To move cheese from GB to NI -

  1. Exporter applies for EHC - see Find an export health certificate - GOV.UK.
  2. Import pre-notified to Point of Entry in NI via TRACES-NT.

You will need to contact HMRC etc. for advice on other obligations.

What are Sanitary and Phytosanitary (SPS) requirements?

Sanitary and phytosanitary requirements are measures to protect humans, animals, and plants from diseases, pests, or contaminants as laid down in EU legislation. The measures maintain traceability, safety and standards in the food chain and are comprised of a wide range of controls including regulation, infrastructure and systems of auditing, certification and inspection.

How often do pre- movement inspections need to happen to obtain an attestation?

This will depend on which certification scheme is being used. It will range from per consignment to every 30 days or on a risk based frequency. Please refer to the scheme which is appropriate for your business.

If the POAO has been sold to a trader located outside NI, and the POAO is in a cold store in NI, who applies for the attestation to accompany the POAO from NI to GB?

It is the responsibility of the owner of the POAO, in this case the trader, to apply for the SHA. However the producer of the POAO will be required to provide all the necessary SPS information to the trader. If this is not available, an attestation cannot be provided.

Where the POAO is eligible for either RBFEC or GEFS then the SA can only be applied for and will only be issued to the FBO responsible for the premises of manufacture/ origin.

What do I need if I sell my product to a business in Republic of Ireland (ROI), and it is shipped from there to GB?

Please talk to your customer in ROI to establish what documentation may be needed.

My business buys POAO from EU and third countries for further processing before it is exported to EU via a depot in GB. What do I need to obtain an SHA/SA?

The SPS requirements which apply to the POAO exported from GB to EU will have to be certified for all the POAO regardless of its origin. You will need to be able to demonstrate that these requirements are met. Additional information about the POAO you import may be required to allow completion of the SHA in NI and the final EHC in GB and may be provided to your business in the form of an incoming certificate from the country of origin. This will depend on the commodity being certified.

Will I have to pay for an SHA?

Businesses will have to pay for SHAs provided by a private Official Veterinarian (OV).

Questions from 8 December EU Exit Stakeholder event

The following questions are from the second EU Exit Stakeholder event on 8 December 2020.

When will a Support Health Attestation (SHA) be required?  For instance will I need one to move POAO from NI to the EU via the GB land bridge?  Will one be required for POAO moving from GB-NI which may be sold to ROI? What about moving product to GB for pallet trailing groupage and then returning it to NI?

POAO exported from GB to EU, including that moved from GB to NI, will require an EHC to demonstrate compliance with EU import requirements. Therefore where POAO originating in NI is intended for further export from GB to the EU, or movement back to NI, then NI to GB movements of POAO may require a Support Health Attestation (SHA) or in some cases a Support Attestation (SA). This will provide the necessary sanitary and phytosanitary (SPS) assurances to allow completion of the final EHC in GB.

The same rules will apply both to goods moving from GB to NI and to movement of goods from GB to EU/ROI. All these movements will require an EHC. Once the product enters NI, it can move freely to ROI on commercial documentation, and vice versa.

POAO exported from NI to EU via the GB land bridge, either via a NI or ROI port, will not require an EHC or SHA.

Where a SHA is required what products will require one and which are exempt?

All products of animal origin for human consumption and some animal by products which require an export health certificate for export from GB to EU may require an SHA. Some composite products are exempt, if they do not contain meat, or less than 50 % of other POAO in total, and meet other criteria such as heat treatment and labelling. Further information can be found at Gov.uk - Export or move composite food products to the EU or Northern Ireland from 1 January 2021.

Some animal by products currently require an EHC to move to GB /EU and will continue to require an EHC, so an SHA is not needed. Further information on what certificates are required for export from GB to EU can be found by visiting Gov.uk - export health certificates and entering EU as the destination country and the commodity in the search bar, to find relevant EHCs and notes for guidance.

Where can I apply for a SHA is it the same system as DECOL?

We have recently launched a webpage to host information on Support Health Attestations,

you will find a SHA template and templates for the Groupage Export Facilitation Scheme and the Risk Based Fish Export Certification approach and a link to the SHA online system by following the below link:

Do I need one SHA per product/consignment or can a SHA cover multiple consignments?

Generally SHAs are issued per consignment, however some flexibility may be available in certain cases. For example, a reduced frequency of SHA is permitted for the movement of fish and some retail products. Please visit UK Certification Schemes Guidance Page for more information.   In addition, where a standard operating procedure has been agreed with the certifying officer, it may be possible to issue SHAs on a production batch basis, up to a maximum of 1 day’s production rather than a per consignment basis. In all cases strict eligibility criteria apply.

Can I apply for multiple recurring SHAs at once e.g. if I make the same product and ship it twice weekly each month can I make one application for my two SHAs/week just once a month?

The Groupage Export Facilitation Scheme and the Risk Based Fish Export Certification approach both allow issue of a support attestation to cover multiple loads during a limited time frame where the product meets specific criteria, for example certain commodities in retail packaging. For further details please visit UK Certification Schemes Guidance Page.

Can I apply for a SHA retrospectively if I discover one is needed after the product moved to GB?

No, SHAs cannot be issued retrospectively.

How quickly will my application be processed?

Exporters must apply a minimum of 2 days in advance of dispatch of the consignment and supply all the relevant information as soon as possible. Arrangements should be made for the Certifying officer to inspect and verify the consignment before dispatch.

What will the inspection process be for issuing a SHA?

This varies depending on whether you are using a scheme such as GEFS (Groupage Export Facilitation Scheme) or requesting an SHA per consignment. You need to consult the guidance documentation for the relevant scheme, as appropriate, read the notes for guidance specific to your commodity, and contact your certifying officer to discuss the requirements for inspection of your premises, food management systems documentation and product.

What if I only know the final weight of the product at loading can I apply for a SHA in advance and then add the weight later to enable me to meet your 2 day advance notice requirement?

You are required to make the application 2 days in advance on the DAERA SHA On Line system, and as much information as possible relevant to the consignment should be provided at this stage. However it is possible to provide further and final details, for example, the weight, or batch numbers of the product prior to final loading and issue of the SHA. Any delay in provision of this information will result in a delay in issue to the SHA.

Once meat is moved from GB to NI for processing can by-product of that meat e.g. bones be shipped to the ROI without certification?

Once product has entered NI from GB, with the appropriate EHC, and is placed on the market here, it is able to move freely within the EU market, including to Ireland. If the bones are sent as Category 3 Animal By Product, then they can move on a commercial document, however there are specific requirements for movement of some other types of Animal By Product.

Is there a legal requirement for the SHA to physically accompany the consignment or can it be sent electronically?

Where agreed with the certifying officer in GB, a copy may be transmitted electronically.

Who is responsible for ensuring loads are accompanied by the necessary paperwork?

It is the responsibility of the exporter to make storage depot operators and hauliers aware of the need for this additional documentation, where it is required. It is also the responsibility of the exporter to make arrangements to obtain a SHA. If this process is contracted to a third party, then that third party must be in a position to supply all the relevant production and traceability information required by the certifying officer. Further information on provision of SHAs can be found at SHA Online - Apply for a Support Health Attestation.

Will animals moving to the EU via the GB land bridge need to be offloaded at the port of departure?

Animals moving to the EU via the GB land bridge will not be unloaded. The accompanying documentation will be endorsed, there will be a visual inspection of the animals from outside the mode of transport and the load will be sealed. Animals will only be unloaded if there is evidence of a welfare issue.

I move product to GB for further processing and return it to NI on a daily basis can I get one SHA to cover such moves for a week/month or do I need one for each load?

You can use one SHA to cover such moves for a week/month only if the product is fish. Products for further processing do not qualify for GEFS, and an SHA cannot be issued to cover more than one production batch/ day’s production, so in most cases one will be required per consignment.

I am not sure what my GB customer will do with the product I ship from NI do I need to apply for a SHA just in case? 

Processors should try to establish, as far as is reasonably possible, what the final destination

of their product will be, after arrival in GB. Where this cannot be established, and there is a reasonable chance that the product may be exported to EU/NI at a later date, then an application for a SHA can be made. However we would urge all processors to keep in regular contact with customers and distributors in GB  for an up to date position.

Is anything changing regards moving live fish from NI to EU via GB?  I presume a SHA is not required?

Post transition, for movements of live fish from NI to EU via GB:

  • Annex IV Part A of (EC) 1251/2008 will apply to aquaculture animals for farming, relaying put and take fisheries and open ornamental facilities
  • Annex B of (EC) 1251/2008 will apply to ornamental aquatic animals intended for closed ornamental facilities.

Is there any changes to the paperwork required to move composite products such as chocolate or which normally only need a commercial document?

Additional documentation is not needed to move these products from NI to GB, unless they will be onward shipped to EU/NI.

Information on which composite products will require an export health certificate to enter NI/EU after 1st January 2021 can be found at Gov.uk - Export or move composite food products to the EU or Northern Ireland from 1 January 2021.

What paperwork will be checked at GB ports both for moves from NI directly to GB and these via the GB land bridge?

There are no additional SPS checks applicable to goods entering GB from NI. This applies to product destined for GB as final destination and for consignments transiting the GB land bridge.

Questions from 23 November EU Exit Stakeholder event

The following questions are from the second EU Exit Stakeholder event on 23 November 2020.

Pork

What will the new requirements be for export of pork meat from GB to the EU (including NI), after 1st January 2021?

Pork moving from GB to EU/NI will have to be accompanied by an export Health certificate. This also certifies that the meat has either been tested or subjected to the specified cold treatment. Currently, as stated in the UK Notes for guidance for EU EHC 8260, the UK has not been awarded the necessary listing for official recognition by the EU of controlled housing conditions in the UK. Therefore porcine meat moving from GB to EU/NI must be tested for Trichinella, with a negative result, or be subject to cold treatment in accordance with Commission Implementing Regulation (EU) 2015/1375 of 10 August 2015 (repealing and replacing Regulation 2075/2005/EC) . Cold treatment does not need to be applied in NI. This can be done before final dispatch in GB.

 Will the requirements change for movement of pork meat from ROI to the NI, after 1st January 2021?

Pork can move from ROI to NI as it currently does, without additional trichinella paperwork, if it is to be consumed in NI. 

Will the requirements change for movement of pork meat from NI to GB, after 1st January 2021? What will the new requirements be for the movement of pork from NI to GB and then onto the EU (or back to NI), after 1st January 2021?

Pork can move from NI to UK(GB) as it currently does, without any additional paperwork, if it is to be consumed in GB. If it is subsequently exported from GB to EU/NI the meat will either have to have been tested, and certified as such before movement from NI to GB, or else subject to cold treatment either in Ni or GB prior to export from GB to EU.

What are the trichinella-testing requirements for pork meat that was produced before the 1st January 2021 and was not trichinella tested to be exported after the 1st January 2021?

Product placed on the market in NI prior to the end of the Transition Period (TP) can reach the end user on either the UK or EU markets after 1st January 2021. However product which is placed on the market in GB, before the end of the TP and is exported from GB after the end of the transition period will need to comply with either the Trichinella testing or cold treatment requirements prior to export. This means that Product originating in NI and re-entering NI from GB or onward to EU will either have had to be tested in slaughter plants, or be subject to cold treatment before it leaves GB. This cold treatment can occur at any point in the supply chain, i.e. either in NI before it moves to GB, or in GB before it re-enters NI.

Documentation

How can I establish what EHC certificates will apply to my products?

All of the GB to EU/NI EHCs can be found at https://www.gov.uk/export-health-certificates. If you still have difficulties in establishing which EHC applies to your products, please consult your enforcement authority.

What additional documentation do I need from 1 January 2021 to - buy meat and/or dairy products from GB to sell in NI and supply directly to the ROI/EU? 

POAO moving from GB to NI will require to be accompanied by an EHC. No additional documentation or EHCs will be required to supply this product directly to customers in NI or EU/RoI

What additional documentation do I need from 1 January 2021 to: sell POAO including meat and dairy in NI that was sourced in NI but has been processed in GB?

All POAO moving from GB to NI will need to be accompanied by the appropriate EHC.

What additional documentation do I need from 1 January 2021 to - sell POAO (including meat and dairy) to a GB customer who may then sell it on to customers in NI, ROI or other EU countries?

If an EHC is required to move the product from GB to NI, your responsibility will be to provide any SHA required to your customer.

Export - NI to GB

How will Chocolate or Chocolate coated products be treated going from NI to GB and also ROI? These are shelf stable.

Current arrangements apply when moving product from NI to GB, for the GB market, or to RoI.

Export of composite products

How do I know if the product I produce is regarded as a composite product?

Current arrangements remain in place where these products are manufactured in NI for the NI, GB and RoI markets. If retailers are likely to export these products from GB to EU, or back to NI, please consult your enforcement authority re "composite products" definitions and requirements or check out the information on the FSA website ​​

GB storage

What will the requirements be, after 1st January 2021, for NI product stored in GB and moved on to EU?

Where POAO stops off/remains in GB for any length of time, i.e. do not transit through as land-bridge, then an EHC will be required to move from GB to the EU.

POAO export

Does unfettered access to GB include foods that include animal products (pies, sausage rolls etc)?

There are no requirements for any additional documentation to accompany food containing POAO manufactured in NI when moving to GB, where the product is intended to remain on the GB market

Will there be any additional requirement from 1st January 2021 for fresh meat of NI animals slaughtered in ROI and processed in NI for NI/GB markets?

Fresh meat, from NI animals slaughtered in the RoI and butchered in NI, can be placed on the market in NI and GB without any restrictions.

When the final destination of goods is to be NI, if you supply retail in NI how can you control goods staying in NI if they are taken over the border by a consumer?

There should be no problem if this is for the purchasers own use. This product cannot be purchased in NI to be placed on the market/offered for sale in the ROI.

What will the requirements be from 1st January 2021 for fresh meat from ROI processed in NI for NI/GB markets?

Fresh meat, from animals slaughtered in the RoI and processed in NI, can be placed on the market in NI and GB without any restrictions.

POAO export - ROI to NI then onto GB

What will the requirements be from 1st January 2021 for POAO originating from ROI and processed in NI for NI/GB markets?

There are no requirements for any additional documentation to accompany products manufactured in NI when moving to GB, where the product is intended to remain on the GB market.

POAO export - NI to GB

What is required to send POAO (pies, sausage rolls etc) to GB from NI via ROI? And will this change after the 1st April?

At the moment no additional requirements are needed to move POAO to GB from NI via ROI ports if product staying in GB. After 1 April, we are aware that GB will require EHCs from ROI if POAO is coming into GB from ROI but it is still not clear about the requirements for loads originating in NI. Please continue to check the DAERA website for updated information.

We have also been told that we would need to use IPAFFS to send goods from NI to GB after the 1st April 2021. Is this correct? 

It may be that you will need to use IPAFFS but we are not yet sure of the timeline. Please continue to check the DAERA website for updated information.

What will the requirements be from 1st January 2021 for POAO moving from NI to GB?

There are no requirements for any additional documentation to accompany POAO from NI to GB, where this is intended to remain on the GB market. A support health attestation may be required if this product is intended for export, or further processing for export, from GB to the EU. For more information, please refer to https://www.daera-ni.gov.uk/publications/daera-poao-ni-gb-trade-faqs

What will the requirements be, from 1st January 2021, for fishery products moving from NI to GB for further processing and then exported on to the EU?

POAO export - NI to GB and then into EU

Seafood products moving from NI to GB will not require an EHC. However, they may require some form of support health attestation to provided assurance that they comply with specific requirements of the appropriate EHC for export to the EU. Please consult your enforcement authority.

POAO export to Third Countries (e.g. China)

Can I continue to export product to third countries, produced before the 1 January 2021 with the old ID mark, from 1st January 2021?

All POAO, produced before 1 January 2021, with the current ID mark, will be eligible for export to other third countries. Some third countries may restrict this to a specific period of time no more information is available on this as yet.

Semen export

What will the requirements be, from 1st January 2021, for movement of equine live fresh chilled semen from NI to GB?

The current arrangements will remain in place for moving germplasm from NI to GB.

Transit though GB landbridge

What will the requirements be from 1st January 2021 for POAOs travelling from Northern Ireland to the EU transiting through GB landbridge?

POAO travelling from NI to EU via GB landbridge can travel with commercial documentation only and will not require a seal. Pre-notification will be required for entry into the EU. Pre-notification may also be required by the GB authorities. Further information to follow.
Landbridge consignments must travel directly from NI to the EU (can also travel via RoI) with no storage, consolidation, unloading of product or addition of product, in GB.

What will the requirements be from 1st January 20201 for POAO originating from GB, processed in NI and exported on to the EU? What if the products reach EU through GB landbridge?

POAO moving from GB to NI will require to be accompanied by an EHC. This means that it can be move freely within the EU. (See above re landbridge requirements).

What will the process be to act as an importer of ingredients of animal origin such as dairy from GB to NI?

This would depend on the type of ingredients you import please refer to information in the animal product and plant product pages for further advice.

Do prepacked meat products from GB require an Export Health Certificate?

Yes – as a movement of product of animal origin prepacked meat products require certification under EU law.

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