ANIMAL HEALTH REGULATION

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 will be a series of new model export health certificates in use. 

Some key points are:-

• Can be used from 21/04/21
• Layout is more standardised in part I
• 4 month transition period until 20/08/21 where either old or new EHC can be used (with some exceptions)
• Model EHCs can be found using this link  in reg 2020/2235 (implementing 2016/429 and 2017/625)
• APHA have started releasing these on EHCO from 01/04/21
• 8350 is the new composite EHC
• 8352 is the new model private attestation
• 8366 is the new farmed game – bovine/camelid/cervine
• 8367 is the new wild – bovine/camelid/cervine
• 8382 is the new porcine mechanically separated meat
• The application and certification process will remain unchanged
• Only one country of origin can be specified on one EHC
• Meat products – there are now 2 EHCs – one for goods requiring a non-specific treatment, and one for those requiring a specific treatment
• Composites have the most changes, as detailed below
• Trusted traders moving goods from GB to NI can use current STAMNI declarations until 01/10/21

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Composite 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:-

1. Is it shelf stable or not?
2. Does it contain meat?

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.

Exemptions

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:-

• Requires an EHC from a vet and is subject to BCP control
• Requires a private attestation and is subject to BCP control
• Is exempt from BCP controls but still needs a private attestation

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These can be downloaded below.

Regulation 2021/899

Annex to 2021/899 (products exempt from BCP control but still needing an attestation)

EU Q+A

DEFRA FAQs

However, a key point to note is that the exemptions/private attestations for egg and dairy products require that the dairy must have been sterilised or UHT treated (below, as per annexes XXVII+XXVIII of EU reg 2020/692); simple pasteurisation will not suffice. This would have the effect of bringing chocolate, biscuits etc into scope and although we understand anecdotally that the EU commission intends to revise guidance to exclude such products, we await formal notification.

Dairy

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 can read our FAQs here….

So please get in touch if you have any further questions….

Contact us