Exports of live animals and Products of Animal Origin (including EHC requirements) - Brexit Q&A

You can use the menu on the right hand side of the screen to skip between questions. Last updated on 12 Sept 2019.

If the UK leaves the EU without a deal, the UK is likely to have to apply full third country export rules when exporting animals and products of animal origin to the EU, including the ROI. This means that a large number of products will no longer be able to be exported from the UK to the EU on a commercial document but will require an export health certificate (EHC).

What exports will need an export health certificate (EHC)?

The following will need an EHC,

  • All products of animal origin (i.e. milk and milk products, meat and meat products, eggs and egg products, fish and fish products)
  • Animal By-products
  • Certain composite products*
  • Live animals – including horses and pets

Further information can be found at the link below:

*composite products are defined in Article 2(a) of Commission Decision 2007/275/EC as “a foodstuff intended for human consumption that contains both processed products of animal origin and products of plant origin and includes those where the processing of primary product is an integral part of the production of the final product”

*where the product being exported meets the requirements of Article 6.1 of Commission Decision 2007/275/EC.

Is it correct that if I am exporting a product where more than half of its content  is dairy, egg or fish, it needs an export health certificate, whereas if it less than half then it doesn’t 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. 

Do all meat products need certified?

Yes, all meat products need certified.

Do bakery products need an export health certificate?

An export health certificate will be required if the bakery products contain any meat (e.g. meat pies, sausage rolls) or fall within the definition of those composite products requiring certification. See above.

Your district council Environmental Health Officer should be able to give further advice on the certificates required.

Where can I find export health certificates (EHCs) for trading with EU Member States?

Applications for an EHC for exports from NI to the EU should be made online via DECOL (DAERA Export Certification On-Line). The system links to Defra’s form finder which will list all of the relevant certificates.

Model certificates can also be found in the relevant EU legislation.

Further information can be found at the link below:

 

Your Official Veterinarian (OV) or local council Environmental Health Officer should also be able to provide further advice.

How do I find out what category my product fits into?

Each export health certificate states what it is for and the associated notes for guidance, available on form finder, define the scope of the certificate.

Additional commodity specific guidance is also available at the links below:

What do I need to do to get an export health certificate?

You should register your interest to export with your enforcement authority (DAERA or local council Environmental Health Officer), if you have not already done so, as all exporting businesses must be included on the list of premises eligible to export to the EU. You then apply on-line on DECOL for an EHC.  Further information can be found in our animal exporting section.

Necessary checks are likely to include a site visit from a DAERA Trading Support Certification Officer to ensure the product complies with the requirements of the certificate and that the business can demonstrate this via documented evidence.

Is there anything I can do now to be prepared in advance of EU Exit?

Each business wishing to export products of animal origin to the EU must notify its enforcement authority (see above) to ensure the business is included on the list of premises eligible to export to the EU. Food business operators should clarify the requirements for eligibility with their enforcement authority.

In addition, when available, the business should study the relevant certificate(s) and notes for guidance to ensure that their product complies with its requirements, for example, in relation to the origin of the product, and ensure they have robust standard operating procedures in place and implement internal verification procedures to demonstrate compliance with the requirements.

Who can sign export health certificates?

Certifying officers include DAERA veterinarians, DAERA Fisheries Officers, local council Environmental Health Officers and DAERA authorised private veterinary practitioners (Authorised Veterinary Inspectors). Who signs the certificate will depend on the commodity being exported. Your enforcement authority should be able to advise you on the appropriate certifying officer for your product.

How long should it take to get these export health certificates?

Exporters will have to apply on DECOL (DAERA Export Certification On-Line) for export health certificates. Appropriate advance notification (currently 3 working days for exports to third countries) should be given to allow the necessary level of documentary and/or physical checks to be carried out and permit certificates to be issued.

DAERA will attempt to prioritise applications as quickly as possible, however, on all occasions 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 as early as possible in advance of issue.

Will DAERA have an adequate resource to complete all of the export health certificates that may be required?

DAERA is doing its utmost to meet its key objectives of keeping agri-food products flowing and has already recruited additional resources and trained existing staff to increase its capacity and capability. While we anticipate that current trade will adjust, it is difficult to gauge demand for certification as businesses may not make decisions until post Brexit. We are currently assessing the resources available and how we will prioritise based on the potential scale of the demands.

If I produce one day for delivery the next, 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. You should apply in advance for EHCs that you reasonably expect to need. DAERA will progress applications as quickly as possible. If an application is made, and the consignment is not exported, you should notify DAERA as soon as possible.

Can DAERA facilitate the ‘out of office hours’ requirement for certification that may be needed?

This matter is currently under consideration as part of DAERA’s Brexit Contingency Planning.

Will there be a 24 hour presence available from local councils to sign off  Export Health Certificates or will site visits be required?

You should clarify the position directly with your local council. For most products of animal origin, a DAERA Official Veterinarian will issue the Export Health Certificate. In general, site visits will be required to facilitate inspection of the product as well as confirmation of details prior to issue of the certificate.

Does DAERA require a health certificate at time of import of products of animal origin from the EU to the UK?

 It is not anticipated that an incoming EHC will be required for product of animal origin to enter the UK from the EU.  However, if onward export certification is required, inward support certification may be needed, depending on the requirements specified on the export health certificate.

Scanned copies of inward export health certificates will be accepted, with a hard copy to follow.

For onward export, should the incoming export health certificate be available prior to production?

Processors should obtain any necessary incoming veterinary certification which may be essential to support onward export veterinary certification, as advised by the Certifying Officer prior to processing of the product in NI. The request for inward veterinary certification should be made in advance of the product being dispatched from the approved premises to enable its certifying officer or 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 health certificates be required to export POAO from NI to GB for onward export to a Third Country / EU?

You should contact your customer or the official veterinarian at the premises of intended dispatch in GB to establish what certification is needed from NI to GB to support onward export to the EU or another Third Country.

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

It is anticipated that Third Country trade will remain largely unaffected. Trade is a reserved matter and DEFRA is working to maintain access to all existing third country markets.

Do consignments entering the EU from the UK have to go through a border inspection post?

Current EU legislation provides that all animals and POAO entering the EU from a third country must be presented at a Border Inspection Post. You may wish to consult the authorities in the receiving country for further information about entry into the European Union.

What happens if I export a number of different commodities (e.g. meat, fish, eggs or products containing these) to a number of different locations in another EU Member State?

One export health certificate is issued for one particular commodity (e.g. various cuts of frozen pork), however, each individual commodity within a consignment must be covered by its own commodity specific certificate e.g. pork or beef or lamb or meat preparations. A certificate for each commodity must also be issued per delivery address in the EU.

To facilitate certification, it is strongly advised 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.

What do I do if I 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.

It is strongly advised 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 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.

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?

You should contact the distribution centre in ROI for advice on this matter.

I understand that if I have a site in the ROI I only need a certificate from our site in NI to the site in ROI 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 a certificate from the site in NI to the site in ROI will suffice.  

However, where the receiving site in ROI is a registered or retail premises, you may wish to contact the authorities there the for advice.

What happens if there are different processing requirements for e.g. UK and EU trade?

Where there is an additional need to ensure certain 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.

Processors should have robust standard operating procedures in place, outlining how segregation is maintained, and implement internal verification procedures to demonstrate compliance with the requirements.

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 be able to register with TRACES to export to the EU or is there a different system that I will need to register with?

The EU will expect notification of imports to the EU through the online TRACES system. This will be the responsibility of the importer who will have to submit the first section of the CVED (Common Veterinary Entry Document) along with any necessary supporting documentation such as the Export Health Certificate at least 24 hours before the consignment arrives at the EU point of entry.

If I sell to a third  party with a base in NI and it in turn exports the product to the ROI, who is responsible for applying online for the health certificate

In most cases the exporter of the goods will have responsibility for applying for the Export Health Certificate. However, if the commercial contract is between a distributor and the ROI customer, it would be the responsibility of 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.

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