New model EHCs came into force on 21/04/21.
So what does that mean?
The latest news and updates will appear here. Last updated 28/07/21.
The latest news and updates will appear here. Last updated 28/07/21.
All change! EU regulation 2016/429 is a large and complex piece of legislation, intending to consolidate and update a number of other regulations. The main imminent change is that as of 21/04/21, there are a series of new model export health certificates in use.
Some key points are:-
A
NB we have been made aware of Spain introducing some additional requirements – despite the whole purpose of the single market being uniformity. Please see guidance and form.
On 1/7/21, APHA released some new model EHCs on form finder and guidance notes, however these cannot be used until 1/8/21, at which point they will run concurrently until 21/8/21, from when the old ones cannot be signed.
Main changes for PX exports are
8371 replaces 8296 for fresh poultry
8369 replaces 8272 for fresh lamb
8368 replaces 8261 for fresh beef
8370 replaces 8260 for fresh pork
8359 replaces 8293 for eggs
8369 replaces 8292 for egg products
8354 replaces 8285 AND 8284 for dairy from category B and C countries
8353 replaces 8287 raw dairy
8383 replaces 8257 for meat preparations (must still be frozen)
8384 replaces 8254 for meat products AND 8345 for rendered fat/greaves
8385 new EHC for meat products requiring specific heat treatment
8364 replaces 8270 for fish/fishery products – bivalve molluscs
8361 replaces 8270 for fish/fishery products – other
8390 replaces 8277 for gelatin
8396 replaces 8276 for collagen
8391 replaces 8272 for honey
8399 replaces 8273 for highly refined products
 
These are defined as PROCESSED products of animal origin, together with plant material that is not present just for technical/manufacturing reasons or to give special characteristics or flavour.
From 21/4/21, the key points are:-
From this, we can use the chart below to decide which, if any EHC is needed.
This means there are effectively 2 composite certificates now. One is the veterinary certificate, used for higher risk products such as those containing any meat, or not shelf stable. The other is the lower risk document or ‘private attestation’ which must be signed by a representative of the importing company. The PA requires a full breakdown of ingredients by %.
NB some ‘shelf-stable’ products may be transported chilled/frozen for convenience/shelf life; the EU have confirmed that shelf-stable rules still apply. However the private attestation only has one box, ‘ambient’. Therefore advice from the BCP should be sought.
Non shelf stable composite products containing ONLY honey, gelatin or snail as POAO require that individual EHC and not the composite EHC. However if it contains at least one of meat/dairy/egg/fish, as well as honey/gelatin/snail, then it can be certified as a composite without the additional honey/gelatin/snail EHC.
Private attestation download here.
The old list in Annex II and article 6 is no longer in force. EU has released delegated regulation 2021/899, together with an annex and a Q+A guide to determine whether a product:-
a
These can be downloaded below.
Annex to 2021/899 (products exempt from BCP control but still needing an attestation)
DEFRA have issued guidance regarding completion of the private attestation and also regarding high risk foods not of animal origin (HRFNOAO).
Please note – the EU and DEFRA contradict each other on some points. We would advise using the EU guideline in this case.
*** IMPORTANT UPDATE – SHELF STABLE COMPOSITES ***
Previously, EU legislation required any shelf stable composites, NOT containing meat, but including dairy – travelling with a private attestation, that the dairy must have been sterilised or UHT treated (as per annexes XXVII+XXVIII of EU reg 2020/692).
On 16/04/21 the EU released guidance stating that this would NOT apply to dairy from approved countries/establishments, or derived from EU. The new model private attestation has not yet been released, but in the interim, the guidance below indicates that the relevant point 10 can be amended (column C of EU reg 605/2010 or 2021/404) or deleted (columns A or B).
Dairy (NON approved countries/establishments only)
Egg
Either way, both GB OVs and the OVs at the BCPs will be dealing with new and unfamiliar EHCs and regulations, which has the potential to lead to queries and delays. There is also the potential for a wide range of products that are currently exempt, to need a veterinary signed EHC. We are in regular contact with DEFRA regarding this matter and will update exporters as soon as we know any more.
Remember that we CANNOT sign an EHC once goods have left the UK.
Why should I chose Amivet as my official vet?
There are relatively few vets who specialise 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 have a large team of official vets and certification support officers throughout the UK and we aim to be as flexible as possible. You will also get a named contact, so you will get a familiar contact that can get to know and understand your business. For further information and a free, informal discussion about your export requirements, including what products you may need an EHC for, please contact us.
Work with us – we will try our very best to come up with a unique solution for every client that works for both parties.
You may be eligible for up to £2,000 as a grant towards ‘professional advice’ regarding Brexit through the Brexit SME support fund, run by HMRC and PWC.
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