Category Question Answer
Health Certificates With reference to the changes to the Export Health Certificates (EHC) from 21st April 2021, we don't export the goods as the owner arranges this. As a public cold store we are registered with the local council and FSA - do we need to register in any way for the EHCs? It is the exporter themselves who must apply to APHA with the draft certificate and application form. These are then sent to the Official Veterinarian, who will inspect the goods, and then check and sign the EHC.
Import We have just started deliveries of our plant based products to our customer and have to prepare for next deliveries "post Brexit". We understand that we require an import agent who can import out products in the UK and take care of the paperwork. We are struggling to find a custom agent that will take on new customers. Can you recommend an import agency or solution to safeguard ongoing supplies to our customer? We assume you require a customs agent as they would ensure that the documents are completed and the consignment clears port health. Unfortunately, we are aware that there isn't a lot of spare capacity in this area. We don’t have anyone who we could specifically recommend but there is a list of Customs Agents (also known as Customs Brokes) by clicking on below link:
https://www.export.org.uk/page/CustomsBrokerRegister
Labelling We've been asked to 'oversticker' an EU address over our UK one. Would this be legal in GB and EU? Over-stickering is acceptable because of labelling changes for products placed on the GB market. Please ensure that the new label is clear, understandable and legally compliant and that it doesn't interfere with mandatory info already on the pack. The over-sticker must obscure or obiterate the old info (ie anything that would not be classed illegal). NB: There is a 21 month deoration until 01.10.2022 to make labelling changes on packaging for goods place on GB market (ie England, Scotland, Wales).
As regards the EU market - it's not expected that they will find over-stickering an issue but as far as we are aware we do not have this in writing from the EU. To be on safe side it would be a good idea to double check with the local authorities in the EU countries you are dealing with or whichever member state markets your products if they are to be sold going forward.
Sample Documentation Have you heard anything about if there is a requirement for food samples being accompanied by any particular documents?  This will be a problem if the procedures to follow are the same as exporting from a third country to the EU. If importing from third country would expect this to be treated the same as GB to NI. Trade samples and samples intended for 'research and diagnoses' and display items are covered by animal by-products legislation. These samples and items can be imported from third countries if the appropriate procedures are following. These are set out in the Importer Information Notes, issued by the Animal and Plant Health Agency (APHA):
* *_Import of Trade Samples. Import Information Note (IIN) ABP/8B_*:  Click Here
* *_Import of Research and Diagnostic Samples from Third Countries. Import Information Note (IIN) ABP/30_*:  Click Here
* *_Import of Display Items from Third Countries. Import Information Note (IIN) ABP/29_*: Click Here
Export/Import If our company send pork products from Poland directly to Republic of Ireland / Northern Ireland via France (not coming into the UK at all) then do we in the UK need to do an IPAFFs notification for the polish vets to complete a vet certificate to export. The pigs will be sourced from ASF regions so will be POAO under safeguard measures. Would the fact that the product had been exported from the EU to the EU mean that no vet certificate would be needed? In short the answer to your question is no you don’t need to use IPAFFS in this instance. IAFFS is the system the UK has put in place to notify UK authorities of movements of live animals, germ plasm and certain other commodities into the UK from third countries. It replaces the EU's TRACES system (Trade Control and Expert System) which we used when we were part of the EU. For movement of the goods within the EU you may find the following useful: Click Here. NB: It states that there may be licensing or certification requirements that apply to food or agricultural product dispatched within the EU. You may need to contact the customs authorities in the country of destination in individual cases. For more information on trading in agricultural and food products, read international trade products and schemes.
Health Marks We are sending Scampi to Singapore with old health market labelling containing UK and EC. Although we cannot send this to EU, we have 18 months to use it up in the UK - could we stil send this to Singapore or are there labelling changes there too? Please click the following link for further information on trade with Singapore: Click Here A UK Singapore agreement has been reached which maintains the effects of the EU-Singapore FTA which can be found here: Click Here.

Also see: Click Here - there is a link where you can find your local trade advisor by postcode. Click Here

The Singapore Food Agency (SFA) is the body responsible for food safety and regulation. You can find more detail here: Click Here.

All pre-packed food products for sale in Singapore must be labelled according to the general labelling requirements of the Food Regulations: Click Here

Import/Export If we were to form an EU company in the Republic of Ireland (ROI) would we be able to import and custom clear the raw material into the EU once product complete? Will the raw material arriving in the EU clear EU port health using an EU issued health certificate from the origin in question i.e. outside of the EU? Would a UK health certificate need to be issued for the stock to be transferred to our UK factory for processing or inward processing relief cease the need for UK health certificate? The current Defra position is that an incoming EHC is not required for Product of Animal Origin (POAO) to enter the UK from the EU. DEARA advise 'If onward export certification is required, inward support certification may be needed, depending on the requirements specified on the export health certificate (EHC). You shoud consult with the Certifying Veterinary Oficer. We advise that processors should obtain any necessary incoming veterinary certification which may be essential to support onward export veterinary certification, as advised by the Certifying Veterinary Office, prior to processing of the product. We also advise that the request for inward veterinary certification should be made in advance of the product being dispatched from the approved premises, to enable the certifying officer, or their representative, to carry out necessary checks where applicable. This applies both within the UK and other countries of origin and for all third country exports.
Import/Export We import and process frozen seafood from outside of the EU to our customers' specifications and sell the finished item to them. We import raw material, whether in shell or not, not cooked for processing. As the raw material is not EU/UK origin then do we quaify for free trade with EU? The Trade and Cooperation Agreement guidance notes on the rules of origin confirm that if raw material is not EU/UK origin then you do not qualify for preferential (zero rate) tariffs. However, there are guiding principles/provisions and conditions which do allow ‘originating status’ to be acquired. One such principle is that for fish caught outside of UK/EU waters requirements are laid out whereby it can meet the 'wholly obtained' provision and therefore quality for preferential tariffs (zero rate). Bilateral cumulation also talks about the use of EU inputs which allows UK businesses to count EU ingredients as 'originating' in their product. Products produced from 'originating' ingredients in the EU and further processed in the UK can then be exported back to the EU preferentially.
Health Certificates (EHCs) We weren't accepted as an authorised trader but have successfully completed EHCs for our first deliveries in January 2021. We have multiple lines, across a number of POAO, we aren't detailing the specific trade information for each batch but have provided a list of all the plants we use. Is anyone else querying this and are details being provided by batch for EHC rather than all potential sources? We would appreciate advice on this as our contacts are part of the authorised trader scheme and aren't required to complete EHCs yet. This query is quite complex to answer but it is our understanding t this time that you should supply the information for each batch otherwise you will run the risk of the EHC not being signed. However, we would advise you referring to https://www.gov.uk/transition for the most up-to-date information.
NI -Trader Support Scheme Can you confirm who completes the STAMNI form and what other documentation is required re. GB to NI movement of goods? (11.01.2021) Please click the following link to access the Trader Support Scheme: https://www.gov.uk/guidance/trader-support-scheme. NB: applications are now closed for applying for the scheme so if you haven't received either confirmation from Defra or the supermarket you are dealing with confirming that you are on the list then you are not authorised. Please check with the haulier you are using as they may be on the authorised trader list and this may be a route you can use.

As regards authorised traders and who can complete the STAMNI form - please see below summary - this relates to goods being moved between GB and NI. Originally there was a requirement for the Board Director of the authorised trader to sign the form but Government has now accepted that another senior person can be delegated by the Board Director possibly someone at point of despatch of goods. If you are on the authorised trader list then you will have been given a registration number that will be used when notifying DAERA of goods moving from GB to NI.

From 01.01.2021 all consignments from GB to NI moving as part of a retail supply chain by an authorised trader must be accompanied by the STAMNI Compliance Declaration. There will be an easement on full certification requirements on these products for only 3 months as per the terms of the Command Paper. All P&R POAO consignments must be accompanied by the P&R Compliance Declaration - both documents are issued per lorry and can be signed by a trader-designated employee and do not required vet signatures.

From 25.01.2021 all P&R POAO consignments must be accompanied by the P&R Official Certificate. This is issued per lorry but must be done by an authorised certificer, eg an OV.

From 15.02.2021 each P&R consignment must be accompanied with the P&R EHC Model Certificates. Per standard EU-model EHCs, the certificates from this point will be issued per product rather than lorry and will need to be signed by an authorised certifier eg an OV. These are not currently on the showcase site but will be available in due course.

For further information please go to: https://www.gov.uk/transition.

NI -Trader Support Scheme Could you please provide detail of the Trader Support Scheme for goods between GB and NI? (11.01.2021) Please click the following link to access the Trader Support Scheme: https://www.gov.uk/guidance/trader-support-scheme. NB: applications are now closed for applying for the scheme so if you haven't received confirmation from either Defra or the supermarket you are dealing with confirming that you are on the list then you are not authorised. Please check with the haulier you are using as they may be on the authorised trader list and this may be a route you can use.
Wood Packaging Materials (WPM) Does frozen goods being transported on wooden pallets from UK to Northern Ireland need to meet ISPM15 guidelines and the pallets need to be heat treated and carry the ISPM15 stamp? Currently wood packaging material (WPM) moving between the UK and EU (includes NI) does not need to be subject to any specific treatment or controls. However, as of 1st January 2021 this will change and all WPM moving between GB and the EU (including NI) must meet ISPM15 international standards by undergoing heat treatment and marking.

Current UK Government guidance advises that checks on solid WPM imported into the UK will continue to be carried out on a risk-targeted basis only. The plant health risk from WPM imported from EU and NI is low and is not expected to change from 1st January 2021.

ISPM15 international standards apply to solid WPM such as packing cases, boxes and crates, drums and similar packing, pallets, box pallets and pallet collars and dunnage (loose wood used to protect goods and their packaging). These standards, however, do not apply to processed woods like plywood, raw wood less than 6mm thick or cardboard or other packaging materials.

You should specify the requirements for solid WPM in your contract with exporters. This will help protect you if the packaging fails inspection. Should packaging fail inspection and you're given an option to treat it - you can either find a company authorised to ISPM15 standards to carry out treatment or send the WPM back to the supplier.

WPM treated to ISPM15 standard will bear 2 marks on opposite sides of the pallet. These will be visible and legible and appear on the block, stringer or lead board of the pallet and should suffice to prove the pallet is compliant with ISPM15. Should the ISPM mark not be legible then the WPM may fail an inspection.

For more information on ISPM15 International Standards please follow this link: https://www.ippc.int/en/publications/regulation-wood-packaging-material-international-trade-0/
For more information on Government Guidance please follow this link: https://www.gov.uk/guidance/importing-and-exporting-plants-and-plant-products-from-1-january-2021

Labelling We produce frozen veg, fruits and herbs in EU and export to multiple countries under own brand. Our current labelling mentions our EU address, do we need to add UK address? If so, can we add it next to our EU address without any other remark? Or add 'Imported in the UK by **our company name** and address? The Government recently published updated guidance on labelling requirements from 1st January 2021. A summary article with links to the full guidance can be found on our website here:  Link The latest guidance states that there will be a derogation of 21 months after the end for transition period for pre-packaged foods being placed on the GB market meaning you can continue using an EU, GB or Northern Ireland address for the food business operator on pre-packaged food sold in GB until 30th September 2022. However, from 1st October 2022, all pre-packaged food sold in GB must include a UK address for the food business operator. If the food business operator is not in the UK, it must include the address of the importer. (Note: we do not know if the EU will allow any derogation period – but we are presuming not and therefore if goods are to be sold on the EU market then you must have an established EU address for the Food Business Operator or EU importer on the packaging or food label).

To answer your question specifically - Yes, you will need to add your company address as you are not located within the EU.

Do we need to add a UK address for this? YES – see notes above. Allowing for the derogation period, from 1st October 2022, all pre-packaged food sold in GB must include a UK address for the food business operator OR the importer into the UK – As you are not registered in the UK you should use your Company UK address.

To answer the second part of your question - if so, can we add it next to the Belgian address, without any other remark? The UK Government were taking a pragmatic approach to the use of 2 addresses during the transition period. I know they had previously said they would allow the use of two addresses on pre-packed foods placed on the GB market during the transition period - one being an importer address into the EU27 and the other an importer into the UK thus allowing a product to be marketed in both EU27 countries and the UK. However, we are not sure if this will be acceptable from January 1st 2021.

From a UK trading standards perspective, we believe any concerns would be over potential confusion. Conversations with enforcement officers regarding the fact that information must not be misleading, ambiguous or confusing. There is a risk that it is unclear by printing another address on the label, and also of course, a risk that if you are over-printing this might be open to printing error. There may also be a risk of food products being halted at the UK border and if there was an incident, from a food traceability perspective, 2 addresses may be seen as a confusion.

Labelling We produce frozen veg, fruits and herbs in EU and export to multiple countries under customer's private label. Our current labelling mentions the customer's address (owner of the brand) - can we keep it like this or does our customer need to update their artwork? The Government recently published updated guidance on labelling requirements from 1st January 2021. A summary article with links to the full guidance can be found on our website here: Click Here  The latest guidance states that for pre-packaged foods being placed on the GB market there will be a derogation period of 21 months after the end of the transition period – this means that you can continue using an EU, GB or Northern Ireland address for the food business operator on pre-packaged food sold in GB until 30th September 2022. However, from 1st October 2022, all pre-packaged food sold in GB must include a UK address for the food business operator. If the food business operator is not in the UK, it must include the address of the importer. (Note: we do not know if the EU will allow any derogation period – but we are presuming not and therefore if goods are to be sold on the EU market then you must have an established EU address for the Food Business Operator or EU importer on the packaging or food label).

To answer your specific question - Customer’s private label, Current situation: the packaging mentions the address of the customer (owner of the brand). New situation: can we keep it like this? Or should we ask the customer to update their artworks? – From 1st October 2022 all pre-packaged food sold in GB must include a UK address for the food business operator or the importer into the UK. If these pre-packaged foods are the customers own branded products and it is their address on the label then they are food business operator that is responsible for the food. If their address is a registered UK address, then NO they do not need to update the address on the artwork.

Labelling What address should be on the label on importing bulk product from outside EU to sell to customers in UK? This must be either a UK registered adddress of a food business operator (FBO) or the importer into the UK
Labelling What address should be on the label on importing bulk product from outside EU being shipped direct to customers in Northern Ireland and Republic of Ireland but do not enter UK? For Northern Ireland (NI) - a registered address in Northern Ireland of a food business operator (FBO) or the importer into NI.
For Republic of Ireland (ROI) - this needs either an EU registered address (this can be ROI registered FBO address or other EU member state address) or the importer into the ROI or for the purposes of labelling, due to the NI Protocol you should be able to use a NI registered address as a valid EU address.
Labelling What address should be on the label on importing bulk product from outside EU and enters UK for re-packing/sleeving * and then be sold to Republic of Ireland as chilled product? It will be sold in Retailer's packaging to the Retailer? ** * At the point when product enters UK this will need a UK registered address of a food business operator (FBO) or the importer into the UK.
**If the Retailer is in the Republic of Ireland (ROI) and it is their brand in their packaging then use their address. Otherwise, it should either have an EU registered address (which can be ROI registered FBO or other EU member state address) or the importer into the ROI.
Labelling What address should be on the label on importing bulk product from ouside the EU and enters UK* and sold onto customers in EU**? *At the point when product enters the UK this will need a UK registered address of a food business operator (FBO) or the importer into the UK.
**At this point an EU registered address or the importer into the EU.
Labelling Where should the label information appear on pre-packed products, on the outer or primary packaging? Please click following link for the information you require:

https://www.gov.uk/guidance/food-labelling-giving-food-information-to-consumers

Labelling Is there a requirement to add 'kill dates' on outer case labels for EHC data? The following composite products destined for the EU Market must be accompanied by an Export Health Certificate if they contain:
Any amount of processed meat product as referred to in article 4(a) of Decision 2007/275/EC;
Half or more of any one processed POAO as referred to in article 4(b) of Decision 2007/275/EC, other than processed meat;
no processed meat and less than half of their substance of processed milk product where the final composite products do not meet the requirements of Article 6 of Commission Decision 2007/275/EC as referred to in article 4(c) of Decision 2007/275/EC
See: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32007D0275&from=EN
For example, you will find below a link to an EHC for poultry meat and poultry products which does ask for information on slaughter:
https://assets.publishing.service.gov.uk/media/5f68b887e90e077f5fd1a3bb/Draft-8296_English_V1.pdf
https://www.gov.uk/export-health-certificates/export-poultry-meat-to-the-european-union-certificate-8296

In conclusion it would be advisable to add the 'kill date' as the border inspection post has to verify that the composite products originate from a third country that is authorised to export such products (ie composite products containing processed products of animal origin) into the EU

It is also advisable to check with APHA:
APHA Centre for International Trade in Carlisle:
Email: ssc.carlisle@apha.gov.uk Tel: 03000 200301
Another useful link is:
https://www.gov.uk/guidance/exporting-animals-animal-products-fish-and-fishery-products-if-the-uk-leaves-the-eu-with-no-deal

Labelling We are finalising packaging for Retail products - these have been manufactured in the UK but will be sold in Ireland at a Retailer - are there any clear rules regards the changing of Health Marks to GBXXXX? Are there deadlines for supply as opposed to remaining on the market if they are different? The most current guidance as of mid-September 2020 is as follows:
https://www.food.gov.uk/business-guidance/guidance-on-health-and-identification-marks-that-applies-from-1-january-2021.

Further Government guidance is due out imminently, but as of 08/10/20 has been delayed.
As it currently stands, any changes to labelling will only come into effect after 31st December 2020 at the earliest but the exact date will depend on details agreed in any trade deal.

Health/identification marks, including timings, are part of the trade negotiations and at the moment Government is still in negotiations. The current 'UK AA1234 EC' format health/identification mark must continue to be used on all products produced in the UK as we are still bound by EU legislation. This also means that the 'GB format' mark must not be used during the transition period. The UK Government were considering allowing FBO's to use it earlier than 31st December 2020 for product placed on the GB market but have confirmed this would not legally be allowed. Government have however confirmed that product in old packaging will be allowed to be sold on the GB market for a period of 21 months after December 31st 2020. As yet, we do not have confirmation as to whether the EU will allow the same period of derogation. We will update this information as and when further guidance is issued.

Import/
Export
How do I import and export goods between Great Britain and the EU from 1 January 2021? Business exporting live animals or products of animal origin from Great Britain to the EU will require an Export Health Certificate (EHC) from Friday 1 January 2021. EHCs will be available via the online digital system known as EHC Online. Exporters will be able to apply for their EHC online and in most cases have them approved digitally by a certifying officer (CO). The EHC Online system is available via gov.uk. There are more than 100 EU export health certificates being developed and exporters will be able to see and decide which are applicable for their goods or consignments. For more details and to register please see www.gov.uk/export-health-certificates
Import How do I import goods from EU27 to Great Britain? Business exporting live animals or products of animal origin from Great Britain to the EU will require an Export Health Certificate (EHC) from Friday 1 January 2021. EHCs will be available via the online digital system known as EHC Online. Exporters will be able to apply for their EHC online and in most cases have them approved digitally by a certifying officer (CO). The EHC Online system is available via gov.uk. There are more than 100 EU export health certificates being developed and exporters will be able to see and decide which are applicable for their goods or consignments. For more details and to register please see www.gov.uk/export-health-certificates
Please click on the following link for step by step flowcharts from gov.uk: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/910155/How_to_import_goods_from_the_EU-into_GB_from_January_2021.pdf
Export How do I export goods from Great Britain to EU27? Business exporting live animals or products of animal origin from Great Britain to the EU will require an Export Health Certificate (EHC) from Friday 1 January 2021. EHCs will be available via the online digital system known as EHC Online. Exporters will be able to apply for their EHC online and in most cases have them approved digitally by a certifying officer (CO). The EHC Online system is available via gov.uk. There are more than 100 EU export health certificates being developed and exporters will be able to see and decide which are applicable for their goods or consignments. For more details and to register please see www.gov.uk/export-health-certificates
Please click on the following link for step by step flowcharts from gov. uk: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/910156/How_to_export_goods_from_GB_into_the-EU_from_January_2021.pdf

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