New UK Import Controls upcoming changes

Updated timeline for changes announced 15th December 2021

On the 15 December 2021, the UK Government announced that the new UK customs and SPS import requirements which were due to apply to imports to Britain from 1 January 2022 have been postponed in respect of imports of goods from Ireland. The full UK Government statement on this can be accessed here.

This announcement means that the current arrangements for importing goods to Britain from Ireland will now continue to apply after 1 January 2022 and until the UK Government provides further information. Further detail on this announcement in respect of agri-food goods, based on information provided by the UK Government, is set out below:

For animal product controls this means:

• The new pre-notification requirements being introduced on EU imports from 1 January 2022 for Products of Animal Origin and Animal by-Products will not apply to goods imported from the Republic of Ireland to Great Britain.
• Existing requirements (introduced in January 2021) for Live Animals, Products of Animal Origin (POAO) under safeguard measures, germinal products and high risk Animal By-Products remain unchanged, i.e. imports of these goods from the Republic of Ireland (ROI) to GB and indirect movements from Northern Ireland (NI) moved via the ROI to GB, will continue to require pre-notification, to be accompanied by appropriate documentation and certification, and will continue be subject to risk-based import checks.
• Direct movements from NI to GB of NI Qualifying animal products, will continue to have unfettered access to GB

Requirement

Register for Import of products, animals, food and feed system (IPAFFS)

Action

To register for IPAFFS you will need the following:

• To decide who is the Responsible person. The Responsible Person must be UK-based and is responsible for obtaining all necessary documentation from the Irish exporter and uploading this to the IPAFFS system.
• A UK Government gateway ID. You need to register on HMRC to receive a UK government gateway ID. The importer of record should be the person responsible for adding the details to the IPAFFS system. Please work with your GB clients to ensure compliance of these requirements, as certain incoterms will bestow responsibilities for each party to the transaction. Any failure to notify IPAFFS will delay and add cost to the shipment
• The Economic Operator Responsible for the Consignment (Registered) in the EU notifies the arrival of the consignment by completing Part 1 of the common health entry document (CHED) to be submitted to the BCP on entry to EU

Note – IPAFFS is the system used for notifying UK authorities of movements of live animals, germplasm and certain other commodities into to the UK from Third Countries. EU rules will not change for direct shipments.

Requirement

Shipments of Products of Animal Origin (POAO) to or transiting through the UK (excluding Northern Ireland) require the below.

There are different requirements for products with final destination Great Britain and for those goods just transiting through the UK. Please familiarise yourself with the different requirements as outlined below.

Action

For destination GB Shipments will require:

• A Common Health Entry Document (CHED-P) form for fishery products (How to create a CHED (Common Health Entry Document) and how to use TRACES – step-by-step guides – YouTube )
• An electronic version of the Health Certificate document is sent to your UK import licensee (excluding Northern Ireland)
• A commercial invoice
• A Responsible Person to provide pre-notification through the UK’s Import of products, animals, food and feed system (IPAFFS), before the shipment arrives in the UK (excluding Northern Ireland).
• Pre-notification to specify what is being imported, the date of import into the UK ( excluding Northern Ireland) and the place of destination. Import of products, animals, food and feed system (IPAFFS) – GOV.UK (www.gov.uk)
• A digital copy of the Health Certification to be uploaded on Import of products, animals, food and feed system (IPAFFS).
• All other documentation relating to the export of fish (i.e. catch certificates and processing certificates) has been submitted to the UK authorities for the consignment

For shipments using the Landbridge to export to France

• To transit through the UK into France – Pre-notification on Traces NT before the shipment arrives in France
• Live animals & germinal products must be accompanied by an intra-union trade certificate and the RFC must give 24 hours’ notice prior to arrival through TRACES
• Animal by-products must be transferred in a container that is sealed
• High risk animal by-products (category 1,2,3 PAP) must be notified to the BCP prior to arrival through submitting the appropriate CHED

Requirement

The UK Department of the Environment Food and Rural Affairs (DEFRA) may carry out a series of inspections on Products of Animal Origin (POAO) shipments at a pre-determined destination within Great Britain.

Action

Be prepared for documentary, identity and physical checks

• 100% documentary check

• 20% identity checks

• 5% physical audit

Current guidance is that costs incurred for health inspections will depend on whether appropriate pre-notifications have been completed. Import of products, animals, food and feed system (IPAFFS) – GOV.UK (www.gov.uk)

BIM Brexit Webinar upcoming custom changes

Watch BIM Brexit webinar Exporting seafood to and through Great Britain from 1st Oct 2021 – broadcast 2nd September 2021