Jul 8th, 2021
6 mins

Defra have advised us that two new EHC’s have been published for Fish exports to the EU in preparation for changes to EU Animal Health Regulations on 21st August.

Please see below updated information on the new EHCs. This updates the guidance we provided to traders on 1 July.

Fish, crustacean and molluscs (8361, 8364)

8361 replaces 8270 – this is to be used for live fish, live crustaceans and products of animal origin from those animals intended for human consumption

8364 replaces 8249 – this is to be used for bivalve molluscs, echinoderms, tunicates and marine gastropods and products of animal origin from those animals intended for human consumption

Summary of main changes

  • The most significant change concerns who is permitted to certify (sign) the EHC.  Our interpretation of the EU rules is that if the product is of aquaculture origin, and is intended for further processing in the EU, and the species is listed in the legislation, an OV [rather than  a Food Competent Certifying Officer] must certify. Therefore, an OV must certify when Part.II.2 of the EHC is not deleted. The list of species covered by this requirement is included in the Annex to EU regulation 2018/1882. Examples of listed fish and shellfish include named species of Salmon (e.g. Atlantic) and Trout (e.g. Rainbow), all decapod crustaceans, and European Flat Oysters.
  • In addition, where certain named fish, or shellfish may act as a vector species, as they live in proximity to a listed species, they are also covered by this regulation. For example, the common edible cockle is named as a disease vector species for the European flat oyster and would require OV certification where they are in contact with (co-habiting or sharing a water supply) with European flat oysters.
  • There is also a requirement for veterinary oversight of aquaculture premises to certify the animal health status of the site and in certain circumstances (for example the export of un-eviscerated listed dead fish from aquaculture) a requirement for clinical investigation within 72 hours of loading by an OV.


Information provided to traders on 1 July:

  • Aquaculture establishments must be registered in GB, maintain records of up to 3 years regarding the species, categories and number of aquaculture animals on the establishment, their movement into and out the establishment and mortality in the establishment as set out in point II.2.2.1. All GB aquaculture establishments should already be authorised by CEFAS or Marine Scotland in compliance with the Aquatic Animal Health (England and Wales) or (Scotland) Regulations 2009.
  • When animals are transported in water, that water cannot be changed in a 3rd country not listed for entry to the EU, for the particular species and category of aquatic animal as set out in point II.2.6.1.
  • Once certified and signed the EHC is now valid for 10 days. In case of transport by waterway/sea this period of 10 days may be extended by the length of the journey on water (point II.2.8).
  • Businesses must list the name of species and number of animals in each container. Further details are in point II.2.7.1 – 2.7.2. (a – d).



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