Export Health Certificates - Brexit questions & answers

Can the UK start exporting to the EU as soon as we exit in a No Deal scenario?

No, the UK must become listed as a Third Country by the EU before exports can commence.

Are there Export Health Certificates for trading with EU Member countries?

Yes, there are Export Health Certificates (EHCs) which UK can use to export to EU Member States (MS), once the UK has become listed as a Third Country. Once listed this means the UK is then eligible to export products to the EU MS, so long as the products meet the importing requirements set out by the EU. These EHCs are available on Defra Formfinder.

How do I apply for an EHC?

For guidance on applying for an EHC please go to the Export Application Process.

Will further training be provided to Vets?

Yes.  Additional training is being provided to veterinary officers in DAERA. In addition, DAERA is training Trade Certifying Support Officers (TCSOs) to assist and support veterinary Certifying Officers as a contingency measure. However TCSOs will not assist with exports of live animals.

Can DAERA facilitate the ‘out of hours’ raw milk certification that is needed?

As part of Brexit Contingency Planning, it may be necessary to extend office opening hours in the event of No Deal.  Work is ongoing to determine the delivery model on Day 1.

If orders are received at 6pm for products to be exported at 8pm, how will this be addressed?

As part of Brexit Contingency Planning, it may be necessary to extend office opening hours in the event of No Deal.  Work is ongoing to determine the delivery model on Day 1.  

If a product was made on a Monday and needs to be dispatched on a Tuesday when will the EHC be ready?  Will the Department provide weekend cover?

Applications for intended exports should be made at least 3 working days in advance, although DAERA will attempt to prioritise applications as quickly as possible. On all occasions however, the necessary information to support the issuance of the certificate, both factual consignment-related information and supporting information, such as traceability or residency, will be needed in advance of issue and as early as possible.

Does DAERA require a Health Certificate at time of import of Products of Animal Origin from the EU to the UK?

The current Defra position is that an incoming EHC is not required for Product of Animal Origin (POAO) to enter the UK from the EU.  Import requirements may change in the future. However if onward export certification is required, inward support certification may be needed, depending on the requirements specified on the export health certificate (EHC). You should consult with the Certifying Veterinary Officer.

Scanned copies of inward EHCs will be accepted, with a hard copy to follow.

For onward export, should the incoming Export Health Certificate be available prior to production.

We advise that processors should obtain any necessary incoming veterinary certification which may be essential to support onward export veterinary certification, as advised by the Certifying Veterinary Officer, prior to processing of the product in NI. We also advise that the request for inward veterinary certification should be made in advance of the product being dispatched from the approved premises, to enable the certifying officer, or their representative, to carry out necessary checks, where applicable. This applies both within the UK and other countries of origin and for all third country exports, regardless of a No Deal Scenario.

Will GB require Health Certificates to allow export of POAO from NI to GB to a Third Country / EU?

We advise that you contact the Authorised Veterinary Inspector at the premises of intended dispatch in GB to establish what certification is needed from NI to GB to support onward export to EU or another Third Country.

At present, DAERA provides the export Health Certificate for goods manufactured in NI that go to GB for onward exportation to the rest of the world.  Will this now be the responsibility of APHA?

DAERA can only issue EHCs for third country export for goods being dispatched from NI directly to a Third Country. However, if the consignment travels by groupage to GB for immediate transfer to another container for onward shipment, then DAERA can issue a through-chain certificate. If, however, the product is stored in GB for any period of time, DAERA cannot issue an EHC for export to the third country and APHA and their designated AVIs will be responsible for issuing the EHC from GB directly to the third country. DAERA advice is to contact APHA. The relevant Certifying Officers in DAERA should be copied into any correspondence with APHA or AVIs in GB.

Will DAERA accept backdated Health Certificates?

Where this applies to the continual and established export of a product, where the appropriate procedures are in place, to the satisfaction of the Certifying Officer in the dispatching premises, then yes - as long as all the necessary information is provided and written confirmation from an Official Veterinary Officer is received.  DAERA would recommend that certification issued per consignment, or at most, on a weekly basis, would be best practise. Stakeholders are reminded that this is at their own risk and should always consult in advance of dispatch, with the veterinary authorities responsible for the dispatching premises. Exporters should also ensure, in advance, that the certification requested from the supplying premises meets the requirements for onward certification as specified by the DAERA Certifying Officer

Will Third Country Trade be affected in a No Deal scenario?

It is anticipated that TC trade will remain largely unaffected.  DEFRA is working to maintain affected access to all existing third country markets.

Do consignments entering the EU have to go through a Border Inspection Post (BIP)?

According to current EU legislation all animals and POAO entering the EU from a third country, must be presented at a BIP. The Department of Food, Fisheries and the Marine (DAFM) in Dublin can give further advice on arrangements for entry into Ireland from NI.

What do we do if we have more than one retailer in the EU?

EHCs are issued from one dispatch premises to one destination premises, and multiple premises of destination cannot be entered on an EHC. DAERA strongly advises that where possible, arrangements are made to ‘export’ a consignment to one receiving approved premises in the EU, from which onward distribution within the EU can then take place on commercial Documents (CDs), issued by the approved premises where the consignment first arrives. Once products have entered the EU at a Border Inspection Post, and arrive at an approved site, the goods can travel freely within the EU under these rules, i.e. accompanied by a CD. Financial accounting and billing can take place separately to the process of issuance of CDs which are required for traceability of the product. To make such arrangements DAERA advises that the exporter consults with the importing businesses.

What happens if we are invoicing 12 different companies in ROI?

EHCs and invoices are separate systems. Once a consignment with potentially multiple drop off destinations, is consigned to one approved premises in the ROI, or EU, that premises can then facilitate distribution of the consignment to the various destinations through the provision of a Commercial Document from that premises of arrival to each onward destination. DAERA have no role in providing advice re invoicing processes.

If consignments are dispatched to one premises in the ROI, will they have to be unloaded and reloaded again before further distribution within the ROI?

DAERA advise that you contact the distribution centre in ROI for advice on this.

What happens if we have consignments with different requirements for processing, i.e. for both NI and EU trade?

Where there is an additional need to ensure Sanitary and Phyto Sanitary conditions are met for export to EU, then segregation should take place prior to processing. For example, where a residency status applies to animals slaughtered for export of meat to EU, eligible animals should be segregated in batches from ineligible, with the higher status batch processed first.

I have been informed that the TRACES system will not be accessible in the event of a No Deal, but that a different system is in development to replace this system. Will I will be able to register with TRACES to export to the EU, or is there a different system that I will need to register with?

At this stage it is unclear whether UK will have access to TRACES, but in a No Deal scenario it is possible that we will not have access to TRACES. If the UK becomes listed as a third country for export to the EU, then application for exports will take place via DECOL.

If we are exporting a product and more than half of it contains dairy, egg or fish does it need to be certified and if less than half then it doesn’t need certified?  And do all meat products need certified?

This is correct, but only if the product being exported meets the requirements of Article 6.1 of commission Decision 2007/275/EC. 

Yes, all meat products need certified.

Do we need separate certificates per commodity?

Yes. Examples of individual commodities requiring separate certification would be fresh beef, frozen pork, chilled chicken, meat products, dairy products (one EHC can include butter and cream) and composite products (can include  meat, dairy, egg, fish, etc.)

Can we export to the EU without formal third country listing?

In the absence of third country listing, the UK cannot legally export POAO to the EU.

If we sell to another 3rd party with a base in NI and they in turn export the product to the ROI, who applies online for the health certificate - the 3rd party distributor we sell to, or ourselves as the producer?

It would normally be the exporter of the goods, the company who has sold the goods on to the customer in the ROI. If the commercial contract is between the distributor and the ROI customer, then it would be the distributor. However any information relating to production of the goods, necessary for export certification, will have to be supplied to the exporter /distributor on request/ in advance, as required.

I understand that if we have a site in the south of Ireland we only need a certificate from our site in the north to the site in the south and not to the final destinations?

Yes, in some situations. Where the premises in ROI is an EU-approved site, such as a cutting plant, cold store or approved warehouse, which can receive goods and issue commercial documentation for onward shipment, then this is correct. 

However where the sister site or receiving site in ROI is a registered or retail premises, then DAERA advises that you contact DAFM or local authorities in ROI for advice.

Will there be a 24 hour presence available from District Councils to sign off or do they even need to come on our site?

You should clarify this directly with your District Council. For most Products of Animal Origin, it will be a DAERA Official Veterinarian who will issue the EHC. Except for certain products, such as dairy, site visits will be required to facilitate inspection of the product and confirmation of details, prior to issue of the certificate.

If we produce on day 1 for delivery on day two, but the certificate takes around 3 days to process, what do we do? How far in advance can we apply?

There is no limit to the advance period for application. DAERA advise that you should apply in advance for EHCs that you reasonably expect to need. If an application is made, and the consignment is not exported, DAERA requests that you notify us as soon as possible.

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