Several FBO’s have been querying with Trade Associations the process to follow when sending samples to the EU.
From conversations with Defra, we had understood that the EU were amending legislation to simplify the process and hopefully remove the need for Export Health Certificates (EHC’s).
However, having now reviewed the EU amending Regulation, although it recognises that such products pose a low risk to public health and the Member State should therefore be able to grant exemptions from official controls, Article 4, then goes onto refer to an additional ‘official document’ travelling with the consignment, as well as an EHC!
In light of this, clarification has been sought from Defra and we have received the following response:
In terms of interpreting the new rules our initial reading is that it will be down to the EU Member State of destination to confirm the specific documentary requirements for trade samples once these rules come in. As I read it, the legislation gives them a route by which they can exempt trade samples from BCP checks. Presumably they may also stick with the current system if they wish. If they wish to exempt these consignments from BCP checks, they need to have issued a specific authorisation and have assurance that the product meets the conditions of the relevant EHC. I think it is likely going to be down to each MS to determine how they actually go about operationalising this new flexibility, but the EU’s purpose does seem to make this trade easier (presumably because they accept the argument that full BCP checks on small consignments of product never placed on the market are unnecessary).
The BFFF would be interested to hear if any members have spoken to EU Member States about the new rules and how they intend to implement them? Any insight you can share would be most welcomed. Please email email@example.com
Should you wish to make a formal comment on the Draft Regulation, you can do so here . It is open for feedback until 23 November 2021 (midnight Brussels time).