We have included here a selection of the most common questions we are receiving regarding Brexit. Should you have any further questions not covered here, please email to firstname.lastname@example.org
What is happening on 31/12/20?
The Brexit transition period ends, the UK is a third country and will not be in the single market or customs union. Many products of animal origin will therefore need export health certificates to travel to EU and NI.
What if we get an FTA?
DEFRA and the UK chief vet have confirmed that EHCs will still be required. An FTA may reduce the level of checks at the EU, but countries where we have FTA now eg Japan, Canada still need EHCs. It is possible they could be more straightforward EHCs to sign.
What will we need an EHC to export?
There are over 100 new EHCs for export to the EU. Fresh meat, ‘meat products’, ‘meat preparations’, fish, egg, honey, gelatin, collagen, ‘composite product’, pet food, animal by products – and many more. This link can be used to search and download specimens.
Fresh meat – raw, unprocessed and chilled or frozen
Meat preparation – mince, burgers, sausages, fresh meat with minimal change eg a coating
Meat product – bacon, biltong, cooked chicken slices – undergone processing sufficient to clearly not be recognisable as fresh meat
What is a composite product?
It is defined as processed POAO together with plant material that is a vital component and not there to add flavour or for processing eg BLT sandwich, lasagne, pork pie, chicken burrito. However it is a very complex area and we have experts on hand who have advanced training in this area.
What about labelling?
The health mark will need to be ‘GB’, not UK or United Kingdom. There are also other labelling requirements.
Where can my goods enter the EU?
They must enter via a border control post. The BCP must accept that particular commodity – not all do so. The BCP must be prenotified up to 24 hours in advance via TRACES.
Where do I get an EHC from?
EHCs are issued by the Animal & Plant Health Agency via its online application system – EHC online (EHCO). Bulk or cloned applications may be made. For many loads, especially mixed/complex loads, the actual details of the exact products, final quantity, weight etc can be added on a ‘schedule’ at loading and so do not need to be known at time of application.
APHA will issue a copy to the OV, who will download and print it, before signing and stamping.
Who can sign my EHC?
Most EHCs must be signed by an official vet – who are appointed by APHA to carry out this work on behalf of DEFRA. A few products, mainly fish, can be certified by a food competent certifying officer (FCCO) – usually an environmental health officer.
OVs can utilise Certification Support Officers to carry out some identity and documentary checks under their direction but CSOs cannot sign EHCs in their own right.
What does the OV need to sign the EHC?
It very much depends on the EHC requirements, but would usually include details such as:- identity, labelling, country of origin, processing details, disease freedom. There is a lot of paperwork and traceability involved – there is much more to it than just turning up, looking at the goods and signing.
We CANNOT sign an EHC once the goods have left GB.
How long will it take?
It can vary hugely, depending on the type and number of products, the layout of the depot, the availability of supporting documentation, plus the OV’s familiarity with the goods and the EHC.
It will also depend on the BCP and the final destination, as the EHC also needs to be printed in those languages too. We understand that any countries of transit between BCP and final destination do not need their own language copy.
Does the OV need to examine all the goods?
There is an expectation that the goods will need some form of identity check by an OV or CSO such that they can be satisfied that what they are certifying is correct. In practical terms, if you are shipping 10,000 cans of custard every day and we are familiar with your goods and processing, we are not going to examine every can.
What happens at the BCP?
EU law specifies that the OV will scrutinise every EHC and carry out 100% identity checks on the vehicle and seal and then a risk based physical check on the goods inside (which may include temperature checks and sampling for microbiological analysis) – of between 5 and 30% of consignments. Given some BCPs are not yet built, nor their classification decided, this is inevitably going to lead to delays.
For mixed consignments of retail goods eg a typical supermarket lorry, the UK has the GEFS scheme. For processed POAO with a stable supply chain, we may be able to carry out an inspection of the manufacturing premises every 30 days which will reduce the need for additional evidence for every batch during that time. However, EHCs are still required for groupage consignments – but the EHC may be easier for us to sign.
Less than load (LTL) freight/consolidation
A lot of freight goes LTL. An OV could certify one pallet that is loaded onto a vehicle, however they cannot enter a seal number as it will not be known at that time. EU law does not insist on a seal number (unless the specific EHC requires it) however it may lead to delays and more checks at the other end. An OV at the final loading may be able to certify, based on supporting documents from the other OVs or CSOs who have checked the goods and paperwork.
The exporter must also be aware that if other products are loaded afterwards and these fail a BCP check, it is possible the entire vehicle contents may be refused and need to be destroyed or reexported – even if your EHC is correct.
How many EHCs might one vehicle need?
Worst case – a supermarket shipping raw milk goods, pasteurised milk goods, eggs, egg products, poultry, fish, honey, beef, lamb, pork, venison, game, gelatin, composite products, meat products, tinned pet food, canned pet food on one lorry may need 17 or even more EHCs just for that one lorry. If they have more than two consignees, this could be 34. If they are shipping to Spain but via Calais, they also need French and Spanish versions. That means 102 EHC versions for 1 vehicle!
Must the EHC go with the load?
EU BCPs are advising that the original wet signed EHC must be presented to the BCP before or at the same time as the consignment. DEFRA are advising the EHC must travel with the load which can cause issues if drivers change etc
We believe the EHC can be sent separately to the BCP if needed.
Can the EHCs be done electronically?
Technically – yes. TRACES and IMSOC do allow e-certs and many 3rd countries use this option. We have asked DEFRA this question and have been told it is not possible.
Therefore we have to use printed, wet signed EHCs.
A scanned EHC copy will be made and sent to the exporter. The BCP must be notified electronically, and the CHED part 1 completed on TRACES, potentially up to 24 hours in advance of arrival of the shipment. EU law gives the BCP some discretion to reduce this to 4 hours.
What if the driver loses the original EHC?
EU law insists the original copy must be presented at the BCP, so a ‘cancel and replace’ would be needed. APHA are not providing an out of office emergency service for this so this will not be issued until the next working day.
What happens if the EHC is rejected?
It is is rejected due to a ‘typo’ or admin error, then EU law allows a ‘cancel and replace’ as above. However major errors, or the wrong EHC being sent will require the goods to be destroyed or reexported.
What about the volume of goods?
It will certainly be a challenge – we have extra OVs and CSOs on standby to cope with the extra volume and are aware that it may be a 24/7 operation in some cases.
Why should I chose Amivet as my official vet?
There are relatively few vets who work exclusively in the export certification field and it is important to choose someone who has experience. At Amivet Exports we are more than happy to work with clients to offer a ‘tailor made’ service. We also have connections with many people in in the industry, trade associations etc
How can I make it easy?
No simple answer on this one without completely reworking your distribution systems. There will inevitably be delays and teething problems.
There is a commercial ‘app’ available that can track and capture much of the information required. We have assisted in its development and can put you in touch with the developer if you wish to explore in more detail what it can offer
So please get in touch if you have any further questions….