Mar 10th, 2021
7 mins
Since 1st January 2021, exporters from England, Scotland and Wales have needed to apply for an export health certificate (EHC) to export live animals or products of animal origin (POAO) to, or through:
- the EU
- non-EU countries
- Northern Ireland (NI) *
More information can be found here
*A grace period from certification for authorised traders moving food from GB to NI was in place until 1 April 2021 – The UK Government recently announced this has been extended to 1 October 2021.
Certification requirements will then be introduced in phases alongside the roll out of the Digital Assistance Scheme
You should also be aware that from 21st April 2021 Export Health Certificates (EHC’s) are to change. However, in light of the above, Defra have written to the EU Commission asking for clarity on the new EHC requirement from 21st April 2021 and guidance on the implementation period.
Please note: We still do not know for certain whether health certificates for IMPORTS into the UK will be changing as we seem to have had mixed messages. As soon as we have confirmation, we will let you know.
We are in the process of reviewing the new EHC’s and have already identified several new requirements such as:
- Differences in formatting – therefore if you have set up any automated systems to complete your EHC’s the likelihood is these will no longer work when these new EHC’s come into effect.
- Each EHC has 2 parts, and taking the composites EHC for example, only a few fields do not change in part 1 and part 2 is extremely complex with many significant changes.
- The requirement for an IMSOC reference (Information Management System for Official Control) – this is an electronic connection between EU IT systems to allow better data exchange.
- The requirement for a QR code – this seems to be linked into ( or generated though) the IMSOC code. At this point in time, we understand that the UK will not be using IMSOC codes and therefore you can ‘strikethrough’ this field. However, we are unsure as to whether the striking through of fields will cause any issues on documentation checks.
- Certifying Officers will now be expected to sign off to say they understand a number of other regulations such as the Contaminants Regulation 1181/2026
We will update you as soon as we have clarity around the implementation period of these new EHC’s. In the meantime, you should still prepare for their introduction and familiarise yourself with them as soon as possible. They can be found in the Annexes of EC Reg 2020/2235 published on 30th December (409 pages!). For example, see Chapter 50 of Annex III (page 367) for the composite products EHC. Some guidance can also be found in Chapter 4 (page 36).
On the subject of composite products, we should also highlight to you that currently Article 6 of Commission Decision 2007/275/EC provides an exemption from certification that applies to certain composite products containing less than 50% of specified processed products of animal origin. This rule will be removed with the introduction of the new EHC’s meaning many more products will fall into scope of requiring a composite EHC.
Certification requirement will be based on the risk linked to the product itself and products will be categorised as follows:
- non-shelf stable composite products,
- shelf stable composite products that contain meat products
- shelf stable composite products that do not contain meat products.
The new requirements for a composite EHC will therefore be:
- ambient/chilled/frozen – EHC required for temperature-controlled products containing any non-shelf stable dairy or egg (must be from EU-approved countries)
- If contains processed meat products – EHC required
- If on an EU list of “lower risk products” (i.e. low risk shelf-stable composite products not containing processed meat) – EHC not required
This is outlined in a draft regulation and its accompanying annex here.
Note: the list of “lower risk products” is given in the Annex.
Article 2 also now clearly defines what a “shelf stable composite product” is:
‘shelf-stable composite products’ means products that do not need to be transported or stored under controlled temperatures.
