Preparing for new UK Import Controls

Post-Brexit checks on goods delayed 15th Dec 2021

The checks, which would have involved significant additional requirements, particularly for food and drink exporters, are being delayed while talks on the Northern Ireland protocol continue between the EU and UK.

Mr Varadkar said it was a “welcome and sensible move which will be good news for Irish exporters and farmers, especially at this time of year”.

He added: “Advice on preparing for future customs checks is available from Enterprise Ireland.”

However, the Department of Foreign Affairs was more cautious.

In a statement to The Irish Times, a spokesman for the department said: “The UK government has announced it is postponing the introduction of additional checks for goods moving from the island of Ireland to Great Britain, which had been planned for January 1st, 2022.

“These checks have only been delayed, not cancelled, so Irish businesses exporting to the UK should continue to prepare for their introduction in due course.”

There is some unease in Government circles about the British government unilaterally treating Irish goods differently to goods from other EU countries. Officials stressed that Ireland had not sought the British move.

The UK left the EU trading bloc at the start of this year, but delayed the implementation of some checks, allowing importers of goods from the EU to delay making advance customs declarations and paying the relevant tariffs.

This was due to end on January 1st, but an extension has now been granted in relation to imports to the UK from Ireland. The imposition of additional requirements on food and drink exporters to the UK are also to be delayed. Notice of exports of food, drink and products of animal origin were due to have been given in advance.

The news will give more time to Irish exporters, who had been preparing for the new regime to come into force on January 1st.

Carol Lynch partner in BDO’s Customs and International Trade Service division, said this was good news for Irish exporters, who will not now need to lodge declarations in advance of departure of the goods from Ireland, while food exporters will not face immediate new Sanitary and Phytosanitary (SPS) checks. The UK announcement did not give a new date for implementing the checks, saying it was contingent on talks on the protocol.

One issue to be clarified, according to Lynch, would be how the UK would separate out Irish goods from those from the rest of the EU, which would face the new rules from January 1st.

The checks due to come in on January 1st are designed to bring post-Brexit customs arrangements between the UK and EU into line with those with the rest of the world.

However, Brexit minister Lord Frost said the existing arrangements in relation to imports from the island of Ireland would continue on a temporary basis for goods crossing the Irish Sea for as long as the discussions on the protocol are ongoing.

Update on Moving Goods from EU to Great Britain

The UK’s HMRC has published an eight-page document with information for hauliers, intermediaries and drivers using the short straits to move goods from the European Union to Great Britain from 1 January 2022.The document outlines procedures that must be complied with at different stages (pre-departure, at the border, during the crossing and on arrival) to move goods from the EU to GB without issue.

Download Document Here

Updated Border Operating Model Published

From the UK Government:

New Phased Approach to Import Controls for Products of Animal Origin and Animal By-Products from the European Union (EU) The Border Operating Model has been updated and confirms the UKs approach to import controls from July 2022.Following the [UK] Government’s announcement in September 2021 that EU to GB Sanitary and Phytosanitary (SPS) import controls will begin from 1 July 2022, we can now share the approach and timetable for these changes.We will introduce certification, documentary, ID and physical checks, by commodity groups for products of animal origin, animal by-products, plant and plant products, in three phases between 1 July and 1 November 2022.The timetable is as follows:From 1 July, certification and physical and identity checks will be introduced for:• All remaining regulated animal by-products• All regulated plants and plant products• All meat and meat products• All remaining high-risk food not of animal origin.From 1 September, certification and physical checks will be introduced for all dairy products.From 1 November, certification and physical checks will be introduced for all remaining regulated products of animal origin, including composite and fish products.Live animal checks will also begin in stages incrementally moving from the point of destination to border control posts from 1 July 2022 as facilities become available and are appropriately designated.This phased approach does not replace any existing import controls already in place and you should continue to follow these for importing your consignments.We will provide further information from early 2022 about the phased approach and the actions you can take to prepare. In the meantime, please ensure you are prepared for the pre-notification requirements from 1 January 2022.Requirements from 1 January 2022From 1 January 2022, all POAO and ABP consignments need to be pre-notified on the Import of products, animals, food and feed system (IPAFFS). If you haven’t done so already, please register for IPAFFS on gov.uk. There is information on how to register – video and guidance.

Pre-notification – you must pre-notify your consignment on IPAFFS, at least 4 hours in advance of arriving into Great Britain. The 4 hours arrangement will remain in place until 30 June 2022.

Read the full Trader Update Here

Brexit Import Controls – Update Nov ’21

In addition to the necessary customs formalities, Irish exporters exporting to, or through the UK, excluding Northern Ireland need to comply with several new UK requirements. All businesses wishing to export to the UK must be listed as an “approved establishment” on the EU TRACES system. In addition, your UK importer will have to pre-notify the UK authorities of the goods being imported and you will have to get the appropriate health certificate(s) from the Irish authorities which must accompany the goods when they are being exported.
Since 1 January 2021 EU exporters have been required to pre-notify exports to the UK authorities using the Good Vehicle Movement Service (GVMS) or to avail of temporary storage at the point of import while import formalities are completed. Certain limited categories of plant and animal products, which the UK considers to be high risk (e.g. live animals, germinal products and high risk plants and plant products), also already require pre-notification to the UK authorities (using its Imports of Products, Animal, Food and Feed System (IPAFFS- the UK equivalent to the EU’s TRACES)) by the UK importer and an Export Certificate which must accompany the consignment being exported.
From the 1 January 2022 the UK will introduce import the requirement for pre-notification of agri-food imports on the IPAFFS system.
There will also be remote documentary checks for products of animal origin, regulated plants/plant products, animal by-products, and high-risk food and feed not of animal origin. There will also be IPAFFS pre-notification requirements.
From 1 July 2022 there will be new requirements for export certificates for ‘health and catch’ including products of animal origin, animal by-products, high-risk food and feed not of animal origin, certification of inspection needed for organic food, and germinal products. Phytosanitary certificates will also be required from this date. There will also be entry through Border Control Posts for live animals, regulated plants/plant products, high risk plants and plant products, products of animal origin, animal by products, high risk food and feed not of animal origin, and germinal products. There will be checks performed at the Border Control Posts for all the aforementioned too.
No new procedures apply to goods moving between Ireland and Northern Ireland because of the Protocol on Ireland / Northern Ireland.
Please note that the type of health certificate required for individual categories of products may differ and therefore consignments with different products may require a number of health certificates. For further information on how to apply for an Export Health Certificate (EHC), please contact the competent authority:

A range of Government supports are available, including training and grants, to help your business deal with these changes. However, you will also need to engage with your UK importer and with the UK authorities.

On 1 April, the UK will introduce new import controls on certain categories of EU goods, including plant and animal products. This will mean that, in addition to the necessary customs formalities, Irish exporters exporting to the UK need to have their UK importer pre-notify the UK authorities of these goods, get the appropriate Export Health Certificate(s) from the Irish authorities and move the goods together with the Export Health Certificates(s).

These new UK import controls will impact on exporters of all products of animal origin, including all meat, dairy, fish and composite products incorporating products of animal origin, as well as regulated plants and plant products. It’s crucial that exporters fully understand these new UK import requirements and ensure everyone in the supply chain, including their UK importer(s), is clear on their roles and responsibilities and can meet them.

A range of Government supports are available, including training and grants, to help your business deal with these changes but you will also need to engage with your UK importer and with the UK authorities in respect of UK import controls.
Food Safety Authority of Ireland update.

Changes to exporting to the UK
Exporting meat, meat products and composite products
Exporting live animals, including equines, germinal products and hatching eggs
Exporting plants and plant products
Exporting forestry plants, wood and wood products
Exporting fish and fish products
Exporting dairy products
Exporting honey products
Exporting table eggs
Landbridge

Changes to exporting to the UK

For goods exported to the UK, excluding Northern Ireland, the UK is progressively introducing new requirements from 1 January, 1 April and 1 July 2021. This approach is set out in detail in the UK in the UK Border Operating Model.

From the 1 April 2021, the UK will implement sanitary and phytosanitary (SPS) requirements on imports of:

Products of Animal Origin (POAO) for human consumption, including meat and meat products, dairy products, fish products, honey, table eggs and composite products.
Regulated plants and plant products.

These requirements include pre-notification on IPAFFS – the UK equivalent to the EU’s TRACES – and the provision of relevant export health certificates.

Exporting meat, meat products and composite products

From 1 April 2021, consignments of meat, meat products and composite products exported to Great Britain (GB) must be pre-notified on IPAFFS and also accompanied by an export health certificate (EHC).

Exporting businesses must ensure that they are registered on TRACES to apply to the Department for an Export Health Certificate.
The GB-based importer will need to register with IPAFFS and submit advance notification of import to IPAFFS.
The exporter will make the application for an EHC in TRACES and also alert their relevant Veterinary Office (VO) of the upcoming export via email. The exporter will insert all the consignment details on TRACES.
Staff in the relevant Veterinary Office will review the application and issue the EHC if requirements are met.
The EHC is generated, signed, and stamped by certifying Official Veterinarian(OV) and the original EHC is made available to the exporter.
The Irish exporter will email a scanned copy of the signed EHC to the GB importer.
The GB importer will upload the EHC onto IPAFFS. This must happen before the consignment arrives in GB.
GB import documentary checks will occur remotely, with identity and physical checks undertaken at the point of destination on a risk basis.
Both the exporter and importer must also comply with Customs requirements. Please see here for details – Revenue – HMRC.

Exporting live animals, including equines, germinal products and hatching eggs

See full information on each individual commodity on Gov.ie Trading in animals and animal products page.

For horses see here, and get information here on pets.

Exporting plants and plant products

EU exports of regulated plants, fruit and vegetables must comply with new phytosanitary requirements, including phytosanitary certificates. If you export plants, fruit and vegetables to the UK, excluding Northern Ireland, you should:

Check whether a phytosanitary certificate is required by checking on Gov.ie website and reading their Trader Notices.
Apply for a phytosanitary certificate via the Export Certification System (ECS) here.
Give at least 14-days notice prior to export to the Department to allow inspectors to arrange an inspection to see if your plants require laboratory testing of samples to ensure they are free from pests and diseases or inspections during the growing season.
Know that consignments of high risk plants, plant products and used machinery must be pre-notified to the UK’s PEACH system and accompanied by a phytosanitary certificate issued by the Department.
Register with the Department if you are exporting plants, plant products or used machinery from Ireland or intend to export these goods to the UK, excluding Northern Ireland.
Contact the UK National Plant Protection Organisation (NPPO) to confirm phytosanitary requirements for plants or plant products.
When you receive original phytosanitary certificate in the post, retain the duplicate for records and post the original to your UK customer who will send it to UK NPPO (DEFRA).

Exporting forestry plants, wood and wood products

Exports of forestry plants, wood and wood products must comply with new phytosanitary requirements, including phytosanitary certificates. If you export wood or wood products to the UK, excluding Northern Ireland, you should:

Register with the Department as a Professional Operator.
Access the Export Certification System (ECS) to get phytosanitary certificates.
Establish whether the commodity you are exporting is a regulated commodity and what the specific requirements for its entry.
From 1 January 2021, any commodity exported that requires is a plant passport needs to be accompanied by a phytosanitary certificate issued by the Department.
If the commodity for export is a regulated commodity, you will need to be officially certified by the National Plant Protection Organisation (NPPO) which is the Department in Ireland and which will involve an inspection and the provision of a phytosanitary certificate.
Give at least 14-days notice prior to export to the Department to allow inspectors to arrange an inspection to see if your consignment requires laboratory testing.

Exporting fish and fish products

From 1 January 2021, in terms of anti-illegal, unreported and unregulated fishing (IUU) fishing, most wild-caught fin fish travelling to the UK will require a Catch Certificate and potentially other commercial and supporting documents – see Gov.ie for details.

If you export fish or fish products to the UK, excluding Northern Ireland, these are the changes:

From 1 April 2021, consignments of fish as products of animal origin for human consumption exported to GB must be pre-notified to the new UK IT system – Import of Products, Animals, Food and Feed System (IPAFFS) and accompanied by an Export Health Certificate (EHC). Please note that some such consignments already require Catch Certificate since 1 January and continues after 1 April along with health certificate requirement.
The GB importer will need to register with IPAFFS and submit advance notification of import to IPAFFS.
Irish exporters with fish consignment for export should apply through a SFPA regional port office for an EHC.
SFPA staff will review the consignment details provided by the exporter.
The SFPA Certifying Officer will verify if requirements of the certificate are met through documentary and potentially Physical Consignment Controls.
Once the EHC is generated, signed, and stamped by the SFPA Certifying Officer the original EHC will be made available in hard copy to the exporter; This EHC should physically accompany the consignment.
A scanned copy of the signed EHC is provided by the exporter to the GB importer.
The GB importer will need to upload EHC onto IPAFFS. This must happen before consignment arrives in GB.
GB documentary checks will occur remotely, with identity and physical checks undertaken at the point of destination on a risk basis.
Irish exporters, who have previously exported primary products to GB, should be aware that the UK EHC does not provide for such exports from registered establishments. This means that exports of live bivalve molluscs going from an aquaculture farm or fishing vessel accompanied by a registration document, or gutted iced finfish from a fishing vessel, cannot occur after 1 April 2021. Instead such products will need to be exported from an approved establishment in Ireland having met any human consumption criteria, in order to reach the UK certification requirements.
Exports of fish to UK by direct landing of Irish fishing vessels are not covered by this guidance, and when fresh do not require EHC. Please see the SFPA website.
Both the exporter and importer must also comply with Customs requirements. Please see here for details – Revenue – HMRC.

For further information on fish and fish product exports, visit here.

Exporting dairy products

From 1 April 2021, consignments of dairy products exported to GB must be pre-notified to the new UK IT system – Import of Products, Animals, Food and Feed System (IPAFFS) and accompanied by an Export Health Certificate (EHC). If you export dairy products to the UK, excluding Northern Ireland, these are the changes:

The GB importer will need to register with IPAFFS and submit advance notification of import to IPAFFS.
Exporters will need to apply for an Export Health Certificate (EHC) through the Department’s Dairy Products Certification System (DPCS).
Once the EHC process is completed, the original EHC is made available in hard copy to the exporter.
The IE exporter will email a scanned copy of the signed EHC to the GB importer.
The GB importer will upload the EHC onto IPAFFS. This must happen before consignment arrives in GB.
GB import documentary checks will occur remotely, with identity and physical checks undertaken at the point of destination on a risk basis.
Both the exporter and importer must also comply with Customs requirements. Please see here for details – Revenue – HMRC.

Exporting honey products

From 1 April 2021, consignments of honey products exported to GB must be pre-notified on the new UK IT system – Import of Products, Animals, Food and Feed System (IPAFFS) and also accompanied by an export health certificate (EHC). If you export honey products to the UK, excluding Northern Ireland, these are the changes:

Exporting businesses must ensure that they are registered with the Department and on TRACES to apply to Department for an EHC.
The GB importer will need to register with IPAFFS and submit advance notification of import to IPAFFS.
The exporter will make the application for an EHC in TRACES and also alert the Honey Inspectorate, located in the Department’s laboratory in Backweston, of the upcoming export via email. Applications for EHC should be made three workings days before export date.
Department staff will review the application and issue the EHC if requirements are met.
The EHC is generated, signed, and stamped by the Certifying Officer and the original EHC is made available to the exporter.
The Irish exporter will email a scanned copy of the signed EHC to the GB importer.
The GB importer will upload the EHC onto IPAFFS. This must happen before consignment arrives in GB.
GB import documentary checks will occur remotely, with identity and physical checks undertaken at the point of destination on a risk basis.
Both the exporter and importer must also comply with Customs requirements. Please see here for details – Revenue – HMRC.

Exporting table eggs

From 1 April 2021, consignments of table eggs exported to the UK, excluding Northern Ireland, must be pre-notified on the new UK IT system – Import of Products, Animals, Food and Feed System (IPAFFS) and also accompanied by an export health certificate (EHC) issued by the Department. If you export table eggs to the UK, excluding Northern Ireland, these are the changes:

Exporting businesses must ensure that they are registered on TRACES to apply to the Department for an Export Health Certificate.
The GB importer will need to register with IPAFFS and submit advance notification of import to IPAFFS.
The exporter will make an application for an EHC in TRACES and on receipt of the Local Cert Reference Number from TRACES, the exporter will be required to submit an application form with supporting documents by emailing egghealthcerts@agriculture.gov.ie
The application and supporting documentation will be reviewed and if in order the EHC can be issued.
If supporting documentation is not in order, the exporter will be notified.
The EHC is generated, signed, and stamped by the certifying Official Veterinarian and the original EHC is made available to the exporter.
The Irish exporter will email a scanned copy of the signed EHC to the GB importer.
The GB importer will upload EHC onto IPAFFS. This must happen before the consignment arrives in GB.
GB import documentary checks will occur remotely, with identity and physical checks undertaken at the point of destination on a risk basis.
Both the exporter and importer must also comply with Customs requirements. Please see here for details – Revenue – HMRC.

Landbridge

From 1 April 2021, EU-GB-EU consignments transiting the Landbridge will need to meet the same import control requirements as EU exports to GB. If you export using the Landbridge, these are the changes:

Pre-notification on IPAFFS system.
GB transit health certificates.
The New Computerised Transit System should be used.
For Landbridge movements to France, pre-notification on TRACES is also required.

Get in Touch

Post-Brexit checks on goods delayed 15th Dec 2021

Update on Moving Goods from EU to Great Britain

From the 1 January 2022 the UK will introduce import the requirement for pre-notification of agri-food imports on the IPAFFS system.

There will also be remote documentary checks for products of animal origin, regulated plants/plant products, animal by-products, and high-risk food and feed not of animal origin. There will also be IPAFFS pre-notification requirements.

No new procedures apply to goods moving between Ireland and Northern Ireland because of the Protocol on Ireland / Northern Ireland.

Department of Agriculture, Food and the Marine (DAFM)

Local Authority Veterinary Service

Sea Fisheries Protection Authority (SFPA)

Marine Institute

HSE Environmental Health Service – exportcertificates@hse.ie

A range of Government supports are available, including training and grants, to help your business deal with these changes. However, you will also need to engage with your UK importer and with the UK authorities.

Exporting to the UK from Ireland

Preparing for changes to UK SPS controls

A range of Government supports are available, including training and grants, to help your business deal with these changes but you will also need to engage with your UK importer and with the UK authorities in respect of UK import controls.

Food Safety Authority of Ireland update.

Contents

Changes to exporting to the UK

Exporting meat, meat products and composite products

Exporting live animals, including equines, germinal products and hatching eggs

Exporting plants and plant products

Exporting forestry plants, wood and wood products

Exporting fish and fish products

Exporting dairy products

Exporting honey products

Exporting table eggs

Landbridge

Changes to exporting to the UK

For goods exported to the UK, excluding Northern Ireland, the UK is progressively introducing new requirements from 1 January, 1 April and 1 July 2021. This approach is set out in detail in the UK in the UK Border Operating Model.

From the 1 April 2021, the UK will implement sanitary and phytosanitary (SPS) requirements on imports of:

Products of Animal Origin (POAO) for human consumption, including meat and meat products, dairy products, fish products, honey, table eggs and composite products.

Regulated plants and plant products.

These requirements include pre-notification on IPAFFS – the UK equivalent to the EU’s TRACES – and the provision of relevant export health certificates.

Exporting meat, meat products and composite products

From 1 April 2021, consignments of meat, meat products and composite products exported to Great Britain (GB) must be pre-notified on IPAFFS and also accompanied by an export health certificate (EHC).

Exporting businesses must ensure that they are registered on TRACES to apply to the Department for an Export Health Certificate.

The GB-based importer will need to register with IPAFFS and submit advance notification of import to IPAFFS.

The exporter will make the application for an EHC in TRACES and also alert their relevant Veterinary Office (VO) of the upcoming export via email. The exporter will insert all the consignment details on TRACES.

Staff in the relevant Veterinary Office will review the application and issue the EHC if requirements are met.

The EHC is generated, signed, and stamped by certifying Official Veterinarian(OV) and the original EHC is made available to the exporter.

The Irish exporter will email a scanned copy of the signed EHC to the GB importer.

The GB importer will upload the EHC onto IPAFFS. This must happen before the consignment arrives in GB.

GB import documentary checks will occur remotely, with identity and physical checks undertaken at the point of destination on a risk basis.

Both the exporter and importer must also comply with Customs requirements. Please see here for details – Revenue – HMRC.

Exporting live animals, including equines, germinal products and hatching eggs

See full information on each individual commodity on Gov.ie Trading in animals and animal products page.

For horses see here, and get information here on pets.

Exporting plants and plant products

EU exports of regulated plants, fruit and vegetables must comply with new phytosanitary requirements, including phytosanitary certificates. If you export plants, fruit and vegetables to the UK, excluding Northern Ireland, you should:

Check whether a phytosanitary certificate is required by checking on Gov.ie website and reading their Trader Notices.

Apply for a phytosanitary certificate via the Export Certification System (ECS) here.

Give at least 14-days notice prior to export to the Department to allow inspectors to arrange an inspection to see if your plants require laboratory testing of samples to ensure they are free from pests and diseases or inspections during the growing season.

Know that consignments of high risk plants, plant products and used machinery must be pre-notified to the UK’s PEACH system and accompanied by a phytosanitary certificate issued by the Department.

Register with the Department if you are exporting plants, plant products or used machinery from Ireland or intend to export these goods to the UK, excluding Northern Ireland.

Contact the UK National Plant Protection Organisation (NPPO) to confirm phytosanitary requirements for plants or plant products.

When you receive original phytosanitary certificate in the post, retain the duplicate for records and post the original to your UK customer who will send it to UK NPPO (DEFRA).

Exporting forestry plants, wood and wood products

Exports of forestry plants, wood and wood products must comply with new phytosanitary requirements, including phytosanitary certificates. If you export wood or wood products to the UK, excluding Northern Ireland, you should:

Register with the Department as a Professional Operator.

Access the Export Certification System (ECS) to get phytosanitary certificates.

Establish whether the commodity you are exporting is a regulated commodity and what the specific requirements for its entry.

From 1 January 2021, any commodity exported that requires is a plant passport needs to be accompanied by a phytosanitary certificate issued by the Department.

If the commodity for export is a regulated commodity, you will need to be officially certified by the National Plant Protection Organisation (NPPO) which is the Department in Ireland and which will involve an inspection and the provision of a phytosanitary certificate.

Give at least 14-days notice prior to export to the Department to allow inspectors to arrange an inspection to see if your consignment requires laboratory testing.

Exporting fish and fish products

From 1 January 2021, in terms of anti-illegal, unreported and unregulated fishing (IUU) fishing, most wild-caught fin fish travelling to the UK will require a Catch Certificate and potentially other commercial and supporting documents – see Gov.ie for details.

If you export fish or fish products to the UK, excluding Northern Ireland, these are the changes:

The GB importer will need to register with IPAFFS and submit advance notification of import to IPAFFS.

Irish exporters with fish consignment for export should apply through a SFPA regional port office for an EHC.

SFPA staff will review the consignment details provided by the exporter.

The SFPA Certifying Officer will verify if requirements of the certificate are met through documentary and potentially Physical Consignment Controls.

Once the EHC is generated, signed, and stamped by the SFPA Certifying Officer the original EHC will be made available in hard copy to the exporter; This EHC should physically accompany the consignment.

A scanned copy of the signed EHC is provided by the exporter to the GB importer.

The GB importer will need to upload EHC onto IPAFFS. This must happen before consignment arrives in GB.

GB documentary checks will occur remotely, with identity and physical checks undertaken at the point of destination on a risk basis.

Exports of fish to UK by direct landing of Irish fishing vessels are not covered by this guidance, and when fresh do not require EHC. Please see the SFPA website.

Both the exporter and importer must also comply with Customs requirements. Please see here for details – Revenue – HMRC.

For further information on fish and fish product exports, visit here.

Exporting dairy products