Much as we would love to help everyone get their EHCs signed straight away, we do have a responsibility to ensure that they are accurate and correct. This does mean there will be times where we have to delay signing until we get further documents or proof, certain items may need removing from the load, or in some cases, we may refuse to sign the EHC altogether.
The consequences of signing an incorrect EHC can be severe:–
We will always work with you at every step to ensure compliance and will suggest alternative options where they exist, but some requirements are ‘black and white’ with no margin of error.
Some common reasons that we may not be able to sign an EHC are listed below, along with some potential solutions:-
Some certificates eg dairy to China, or poultry to Singapore, insist that the product must be of UK origin. Some certificates will allow any EU country; others may allow non-EU countries (subject to equivalence of standards and disease status). Please check with us first.
We will need full traceability of the goods from the raw material to processing to the finished goods, to ensure that the standards of the EHC have been kept throughout the entire process.
Some EHCs have very precise requirements about this in terms of time and temperature. An example is dairy to India, where standard pasteurisation at 72’C for 15 seconds is inadequate to kill M avium paratb. Pasteurisation for 25 seconds is required or we will need evidence that hood environmental, milking and hygiene practice is carried out on the farms of origin.
The labels on the packets MUST match that on the EHC and any other documents eg an import permit. Australia and China are notorious for querying even minor typographic errors. It may be possible to relabel the goods but we must be satisified that the packets do in fact contain the goods in question. Bear in mind some countries also require the label to be written in the local language.
Where we rely on a ‘mandec’, these must confirm EXACTLY what is required by the EHC. The mandecs must be signed by someone of sufficient seniority to have knowledge of the production process and that what they are signing is true. A mandec must include the phrase ‘I am aware that it is an offence to make a false declaration’. We may also need a list of approved signatories.
Some countries may require an import permit that we need to see to complete the EHC. It must be accurate and in date. Examples include Australia, South Africa and USA. Other countries may need a permit too. They can be valid for a variable length of time and a variable number of shipments.
Ideally, we would be present at every loading to inspect and then sign the EHC there and then. In some cases eg South Africa, this is an absolute requirement. For some goods/countries we may be able to ‘pre-inspect’ the goods in advance of shipping. However we cannot under any circumstances sign an EHC once the goods have left UK. This is a DEFRA rule.
It may be that an order has changed between application and inspection. In many cases we can add or delete items off the EHC and sign/stamp these changes. However this can get very messy if we are making numerous changes and come countries eg China do not accept handwritten amendments. In these cases we may need to request a ‘cancel and replace’ EHC off APHA. Alternatively, if this scenario is likely, we can use a separate schedule to list the final inventory and include this with the EHC.
Some EHCs require the UK and other countries of origin to be free of certain diseases eg bird flu, swine fever, foot and mouth disease. In the UK, we are issued with a 618NDC form to confirm this. For other countries we have to check the WAHIS database and/or carry out further checks. Any disease outbreak can cause an EHC to be cancelled with immediate effect.
Where an item contains more than one product of animal origin, you may need to get an EHC for each component eg an airline snack containing dairy and poultry may need 2 EHCs. Another example is cheese to South Africa, where the rennet must be vegetarian.
We need to carefully check any supporting documents given to us, as we must not ‘recklessly attest’ to what someone else has signed. For example, is someone gives us a mandec stating country of origin ‘France’ we may request the supporting trail of documents to back this up.
If there isn’t an EHC for your product then we can’t sign it! We have only had one fake EHC presented for signature over the years that we passed on to APHA. We will work with you, APHA and your trade association to try to get an EHC drafted, but this does take time, if at all possible.
The moral of the story is – contact us early on in the process, so that we can advise how best to proceed. There is little point spending a lot of money making a product, only to find out that it cannot be exported. You can also download our easy step-by-step guide to the EHC process.