1. Can you help export my cat/dog/horse?
We get a lot of enquiries about this. Unfortunately, we are generally unable to assist with live animal exports of the above species. APHA requires official veterinarians to be registered on alternative export panels in order to certify these species. We would recommend you contact our sister practice, Petair UK.
Some of our OVs however, do hold additional panels, meaning we can help with some niche exports, such as avian exports (poultry and hatching eggs etc), as well as a laboratory and zoo animals, including captive birds.
2. What did “Brexit” mean for exports?
The UK has left the EU and is now is a “third country”. Mainland GB is not be in the single market or customs union, so many products of animal origin now need export health certificates to move to the EU.
3. What about Northern Ireland?
This is where it gets complicated. Due to the open land border between the North and South of Ireland, NI effectively remains part of the single market. The Windsor Framework, introduced 1/10/23 aims to minimise the impact of this, but in summary, there are strict rules about what can and cannot be moved from GB to NI, and what documents are required.
4. What is an EHC?
An Export Health Certificate (EHC) is an official UK Government document, issued by the Centre for International Trade in Carlisle (part of APHA). The EHC is signed by an official veterinarian (OV), that confirms that certain food or animal products meet the import requirements of another country.
The EHC will be in English and may also be in the language of the destination country.
5. What needs an EHC to export?
There are over 1,200 EHCs available, covering the EU and most other countries all around the world. Generally speaking, the following commodities may require certification.
6. What is triangular trade?
This is the import from one country (eg New Zealand) to a other country (eg UK) and then on to a third country (eg EU). In most cases, this is prohibited for export to the EU, unless the goods have been further processed in the UK (eg heating, smoking, curing, maturing, dying, marinating, extraction, extrusion or a combination of these processes. Products simply sliced and/or rewrapped cannot be exported.
EU origin goods that are simply stored in the UK and not changed at all, may be eligible to go on the storage EHC 8461. ROW goods are not eligible.
This is a complex area and there are some exceptions that we are happy to advise on.
7. What is a composite product?
It is defined as “a foodstuff intended for human consumption that contains both PROCESSED products of animal origin and products of plant origin and includes those where the processing of primary product is an integral part of the production of the final product” eg BLT sandwich, lasagne, pork pie, chicken burrito.
This is distinct from a ‘compound product’ made from unprocessed goods e.g. fresh beef steak with a butter pat that will require 2 or more EHCs.
8. What is a private attestation?
Certain composite goods (eg shelf stable and not containing meat) for export to the EU, may not require an EHC but can instead travel with a ‘private attestation’, signed by the importer.
9. What about labelling?
Any health or identity mark on the packing will need to be ‘GB’ or ‘United Kingdom’, not ‘UK’.
10. Who can sign my EHC?
Most EHCs must be signed by an official vet – appointed by APHA to carry out this work on behalf of the UK Government. 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 EHC in their own right.
11. What evidence does the OV need to sign the EHC?
This will vary from EHC to EHC, but may include evidence of:-
- Country of origin/any movement during rearing
- Veterinary support health attestations
- Health mark
- Production records/processing details
- HACCP plans
- Temperature records
- Disease freedom checks
- Import documents
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.
Please note that we CANNOT sign an EHC once the goods have left GB, so supporting documentation and traceability need to be in good order, in plenty of time.
12. Does the OV need to examine all the goods?
Where reasonably practicable, the OV or CSO will check as much product as possible. However, 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 item.
Obviously the larger the load and the bigger the list of SKUs, will mean the process can take longer. The time taken can also vary due to other factors such as warehouse efficiency, lorries arriving on time etc
13. What is the UK’s animal health status?
The UK generally has a high health status and is currently clear of diseases such as foot and mouth, swine fever and lumpy skin disease.
‘Bird flu’ (HPAI) has caused the UK to be split into various regions which has caused complications for fresh poultry and poultry product exports.
14. What is a BCP?
In EU law, a BCP is a ‘Border Control Post’ that acts s a point of entry and must accept the specific commodity. The inspecting veterinarian 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.
15. What is the groupage/GEFS scheme?
For mixed consignments of retail goods eg a typical supermarket lorry, the UK has the GEFS scheme. This covers processed POAO with a stable supply chain, we may be able to carry out regular inspections of the manufacturing premises to allow us to sign a single attestation every 30 days, rather than a batch specific document every time. EHCs are still required for groupage consignments – however the GEFS scheme makes the process easier.
16. Groupage/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 vehicle 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 – and some BCPs do insist on it, along with details of transport. There is the option of using ‘pallet seals’ in such cases.
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 (linear or hub+spoke groupage models).
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 individual EHC is correct.
17. Does the vehicle need a seal?
For the majority of EHCs, this is not a legal requirement, however BCPs very much prefer a lorry number and seal number as this can be used in place of an identity check on the goods, to speed things up. This ‘official seal’ must be applied under veterinary supervision.
Some BCPs seem to be more lenient than others and will accept EHCs without lorry/seal details but again we are seeing inconsistency.
18. Can the EHC be done electronically?
Technically – yes. However, this is not widely available yet for us in the UK. There is a system which is currently being trialled for certain EHC types to Northern Ireland.
For EU exports, the importer or agent must complete a TRACES entry and create a CHED part 1, to pre-notify the BCP of arrival, potentially up to 24 hours in advance. EU law gives the BCP some discretion to reduce this to 4 hours.
20. What happens if an EHC is rejected?
This would depend on circumstances. If it is rejected due to a ‘typo’ or admin error, or is lost in transit, then we may be able to issue a ‘cancel and replace’ EHC.
However major errors, or the wrong EHC being sent, may require the goods to be destroyed or returned to the UK.
21. What about importing goods into GB?
We do not specifically advise on imports, however in many (but not all) cases it mirrors the export process. GB is in the process of introducing its “Target Operating Model” although this has been delayed.
22. How can I make it easy?
There is no simple answer on this one without completely reworking your manufacturing and distribution systems. There will inevitably be delays and extra costs.
- Organise your loads so all the dairy is on one lorry, the meat on another etc, where possible
- Ship in bulk
- Arrange your shipments in as short a window as possible to minimise vet time on site
- Ship from the same depot on the same day(s) each week to help with resourcing OVs
- Consider direct EU to EU shipping of goods where possible
- Work with your suppliers to ensure paperwork is correct and prompt.