3.1.1 Goods Subject to Sanitary and Phytosanitary Controls

Key definitions for traders
These controls will introduce a number of new processes and procedures which will apply to the import of Animal Products, Fish, Shellfish and their Products, Live Animals and Plants and Plant Products.

These controls include the requirements for:
• Import pre-notifications
• Health certification (such as an Export Health Certificate or Phytosanitary Certificate)
• Documentary, identity and physical checks at the border or inland (temporarily)
• Entry via a Border Control Post (BCP)

An import pre-notification refers to the means by which importers provide advance notice to relevant regulatory bodies of a consignment’s arrival into GB. This is typically a standardised import notification form that requires the importer to provide details regarding the consignment, such as the consignment’s country of origin, place of destination, the specific species/product and general details for the importer, exporter and transporter. This is submitted by the importer in advance of the consignment’s arrival to the relevant regulatory body for that commodity.

A health certificate refers to an official document that confirms the product meets the health requirements of the destination country. This is required to accompany the consignment during its passage. It is the responsibility of the exporter to secure this from the country of origin’s relevant competent authority. Different products will require different details from the exporter regarding the consignment, though this will generally include details of the country of origin, place of destination, and nature of transport, as well as a health attestation of the consignment. For products of animal origin and live animals, for instance, this will require the consignment to be inspected by an Official Veterinarian in order to verify that the consignment’s contents meet the health requirements of the destination country. An individual health certificate is required for each species/type of product.

Therefore, a single import may consist of multiple consignments that each require multiple health certificates.
A documentary check is an examination of official certifications, attestations and other commercial documents that are required to accompany a consignment.

An identity check entails the visual inspection of a consignment in order to verify its content and labelling corresponds to the information provided in accompanying documentation.

A physical check entails a check on the goods to verify that they are compliant with the sanitary and phytosanitary import requirements for GB. This includes, as appropriate, checks on the consignment’s packaging, means of transport and labelling. Temperature sampling for analysis, laboratory testing or diagnosis may also be required.

Entry via a Border Control Post (BCP) refers to the requirement for certain goods to enter GB via specific points of entry that are equipped to perform checks on specified goods. A BCP is an inspection post designated and approved in line with that country’s relevant legislation for carrying out checks on animals, plants and their products arriving from the EU. These checks are carried out to protect animal, plant and public health. The commodities that BCPs are equipped to process will differ between BCPs. Therefore, it is the responsibility of the importing/exporting parties to ensure that their goods are routed via an appropriate BCP; importers are typically required to notify the relevant BCP of the goods arrival as part of the pre-notification process as such.

Animal Products (Products of Animal Origin and Animal By Products)

Requirements
From July 2021, there will be a requirement for:
• goods to be accompanied by an Export Health Certificate in order to undergo documentary checks
• import pre-notifications submitted by the importer in advance of arrival
• Entry via a Point of Entry (PoE) with an appropriate BCP in order for goods to be made available for documentary, identity and physical checks

Guidance on products classed as POAO and ABP can be found online. Importers should check if the CN code for their product is listed in Regulation 2019/2007 to find out if their POAO or ABP must meet the above requirements.

EU POAO and ABP will be required to be accompanied by an Export Health Certificate (EHC). An EHC is an official document that confirms the export meets the health requirements of the destination country; this will need to be secured by the exporter from the EU country of origin’s competent authority.

Where there are no standardised requirements and no model Export Health Certificate currently exists, the GB importer will need to contact CEFAS/CITC for England/Wales. In Scotland, individual importers do not require authorisation but relevant authorities may need to confirm that the consignment is destined for an authorised facility.
Contact details for relevant authorities can be found here:
• Centre for International Trade Carlisle (CITC)
• Centre for Environment, Fisheries and Aquaculture Science
• Fish Health Inspectorate

There will also be new requirements for importers to submit pre-notifications for POAO and ABP via IPAFFS. The importer will need to use IPAFFS to pre-notify the goods’ arrival in advance.
Imports of fully processed animal feed, including pet food, will be subject to the requirements set out above for EU POAO and ABP.

Additional Requirements for Marine-Caught Fish and CITES-listed goods
Imports of marine-caught fish, fishery products and some types of shellfish will also need to meet catch certificate requirements as detailed for fish, shellfish and their products.

Imports of food products made from species listed in the CITES, EUWTR or UKWTR annexes, such as caviar from the Sturgeon family, will also need to meet CITES-related requirements as detailed for CITES goods in SECTION 1.2.2. These include the requirement for relevant EUWTR export permits from the country of departure and a UKWTR import permit issued by APHA.
Location of checks

POAO and ABP will need to enter GB via a suitable Border Control Post (BCP) in order for the goods to be available for inspection. A list of current BCPs and the commodities they accept is available here.

The UK Government is currently exploring options to build more BCPs and to provide targeted support to ports to do so. Therefore, this list will likely change to include further sites. These changes will be made public in order for traders to prepare accordingly.

EU animal products will be subject to documentary, identity and physical checks. Goods may also be sampled for laboratory testing. Documentary checks entail examination of the official certifications, attestations and other commercial documents that are required to accompany the consignment. An identity check entails a visual inspection to verify the content and labelling of a consignment correspond to the information provided in the accompanying documentation.

Physical checks entail a check on the goods and, as appropriate, checks on packaging, the means of transport, labelling and temperature, the sampling for analysis, testing or diagnosis and any other check necessary to verify compliance with the import sanitary and phytosanitary rules. The level of checks will take into account the level of checks imposed by the EU on GB goods of similar risk status.

Systems
The importer will need to register for IPAFFS.

Process Map: Products of Animal Origin and Animal By-Products

Fish, shellfish and their products

Requirements for all fish

All fish, shellfish and their products originating from the EU will be subject to sanitary and phytosanitary import controls, similar to those applying to animal products and live animals. This includes the requirement for Export Health Certificates, import pre-notifications and entry via a Border Control Post (BCP).
In addition, most imports of marine-caught fish and some shellfish will need to be accompanied by a catch certificate.

Catch certificates are official documents that prove any marine-caught fish has been caught legally. These are issued by the competent authority of the country the fishing vessel is registered to; this will need to be secured by the EU exporter.

Imports of non-marine-caught fish (e.g. farmed fish and shellfish, freshwater fish) and certain exempt marine species (e.g. mussels, cockles, oysters, scallops, fish fry or larvae) are not subject to catch certificate requirements.

Requirements for fish as animal products (e.g. containerised fish or via vivier transport) and live animals (e.g. ornamental fish)
In line with rules for animal products, new import requirements will apply to EU fishery products as from July 2021 – see 3.2.3. Guidance on products within this category can be found online.

In line with rules for live animals, imports of fish as live aquatic animals will be subject to new import controls for live animals from July 2021 – see 3.2.3.
Live aquatic animals where intended for direct consumption by the final consumer – such as live oysters and mussels (if from Class A waters or depurated), crabs and lobster – are classed as animal products and not as live animals; therefore, these will be subject to controls applying to animal products rather than live animal controls. LBMs are subject to circumstantial rules.
For all imports of fish as animal products and live animals, there will be the requirement for:
• goods to be accompanied by an Export Health Certificate
• import pre-notifications submitted by the importer in advance of arrival.
• Entry via a Point of Entry (PoE) with an appropriate BCP in order for goods to be made available for documentary, identity and physical checks

Imports of fish as animal products and live animals will be required to be accompanied by an Export Health Certificate (EHC). An EHC is an official document that confirms the export meets the health requirements of the destination country; this will need to be secured by the exporter from the EU country of origin’s competent authority.
Where there are no standardised requirements and no model EHC currently exists, the GB importer will need to contact the Centre for International Trade (CITC) for fishery products or CEFAS/MS for live aquatic animals, for import requirements, if permitted, including any licencing or documentation where applicable.
Contact details for relevant authorities can be found here:
• Centre for International Trade Carlisle (CITC)
• Centre for Environment, Fisheries and Aquaculture Science
• Fish Health Inspectorate

There will also be new requirements for importers to submit pre-notifications for animal products and live animals via IPAFFS. The importer will need to use IPAFFS to pre-notify the goods’ arrival in advance.

Requirements for direct landings of marine-caught fish by EU registered fishing vessels

If an EU registered fishing vessel wishes to land its catch directly into the UK it must give 4 hours’ notice to UK authorities, submit a prior notification document, a pre-landing document and a catch certificate for the fish that is being landed.

EU vessels will need to submit a NEAFC Port State Control form (PSC1 or PSC2). EU vessels will also need to complete a prior notification form and pre-landing declaration.
Further details are available online.
Additional requirements for endangered species listed under CITES
Imports of food products or live animals listed in the CITES, EUWTR or UKWTR annexes, such as caviar from the Sturgeon family, will also need to meet CITES-related requirements as detailed for CITES goods in 1.2.2a. These include the requirement for relevant EUWTR export permits form the country of departure and UKWTR import permit issued by APHA.

Locations of checks
Imports of fish as animal products and live animals will need to enter GB via a Point of Entry (PoE) with a suitable Border Control Post (BCP) in order for the goods to be available for inspection.
There is an exemption from this for fresh fish that are direct landings into a UK IUU designated port. A list of current BCPs and the commodities they accept is available online.

The UK government is currently exploring options to build more BCPs and to provide targeted support to ports to do so. Therefore, this list will likely change to include further sites. These changes will be made public in order for traders to prepare accordingly.

Following arrival at the BCP, goods will be subject to documentary, and additional identity and physical checks, if selected. Goods may also be sampled for laboratory testing.

Documentary checks entail examination of the official certification, attestations and other commercial documents that are required to accompany the consignment. An identity check entails a visual inspection to verify that the content and labelling of a consignment correspond to the information provided in the accompanying documentation.

Physical checks entail a check on the goods and, as appropriate, checks on packaging, the means of transport, labelling and temperature, sampling for analysis, testing or diagnosis and any other check necessary to verify compliance with the import sanitary and phytosanitary rules. The level of checks will take into account the level of checks imposed by the EU on GB goods of similar risk status.

Direct landings of marine-caught fish, which are subject to the North East Atlantic Fisheries Commission (NEAFC), will need to be landed at a designated GB port as listed by the North East Atlantic Fisheries Commission. Further details of ports in this category are available online.

Direct landings exempt from BCP inspection, must additionally land at an IUU designated port.
The vessel must also give 4hrs notice to UK authorities, submit a prior notification document, a pre-landing document and a catch certificate for the fish that is being landed.
All catch certificates will need to be checked and authorised prior to landing. These checks are carried out away from the border. For fishery products (includes fish), direct landings by EU registered fishing vessels will also become subject to landing in IUU designated ports.
5% is the IUU regulation benchmark for port inspection of 3rd country vessels (which would include EU vessels). This is determined by species of fish caught, previous catch behaviour and/or country flag.

Systems
The importer will need to register for IPAFFS here.

Process Map: Fish Direct Landing

Process Map: Fish as Animal Products

Process Map: Fish as Live Animals

High-Risk Food and Feed Not of Animal origin (HRFNAO)

Requirements

From July 2021, HRFNAO from a third country that has been previously imported into the EU will be subject to new import requirements when imported to the UK.
This includes the requirement for:
• import pre-notifications to be submitted in advance of the goods’ arrival.
• Entry via a Point of Entry (PoE) with an appropriate BCP in order for goods to be made available for documentary, identity and physical checks
Guidance on products classed as HRFNAO can be found online.

Importers will need to submit pre-notifications to an appropriate Border Control Post (BCP) via the Import of Products, Animals, Food and Feed System (IPAFFS). The importer will need to notify the relevant BCP of the goods’ arrival in advance, though some BCPs may require additional notice and a separate notification submitted in addition to IPAFFS.

RoW-originating HRFNAO that transits the EU will continue to need to be pre-notified on the Import of Products, Animals, Food and Feed System (IPAFFS) and enter the UK at a BCP approved for HRFNAO in the same way as similar consignments imported directly from a third country. (see 1.2.3 for further information)

Additional requirements for high-risk plants and products
HRFNAO also includes some controlled plants and plant products – such as apples, lettuce, and all solanaceous fruits (e.g. tomatoes, aubergines). Imports of HRFNAO within this category will also need to meet phytosanitary controls as detailed in 3.2.3, such as the requirement for a Phytosanitary Certificate.

Location of checks

HRFNAO will need to enter GB via a suitable BCP in order for the goods to be checked. Upon arrival at the BCP, goods will be subject to documentary checks. This entails examination of the official certifications, attestations and other commercial documents that are required to accompany the consignment.

Depending on the commodity, hazard and country of origin, goods may also be subject to identity and physical checks. An identity check entails a visual inspection to verify the content and labelling of a consignment correspond to the information provided in the accompanying documentation.

Physical checks entail a check on the goods and, as appropriate, checks on packaging, the means of transport, labelling and temperature, the sampling for analysis, testing or diagnosis and any other check necessary to verify compliance with the import sanitary and phytosanitary rules. The level of identity and physical checks from July 2021 will reflect the specified frequency of controls as per the legislative requirements.

A list of current BCPs and the commodities they accept is available here.

The UK Government is currently exploring options to build more BCPs and to provide targeted support to ports to do so. Therefore, this list will likely change to include further sites. These changes will be made public in order for traders to prepare accordingly.

Systems

The importer will need to register for IPAFFS.

Process Map: HRFNAO

Live Animals and Germinal Products

Requirements

From July 2021, new import requirements will apply to live animals and germinal products from the EU.
This includes the requirement for:
• goods to be accompanied by an Export Health Certificate (EHC).
• import pre-notifications submitted by the importer in advance of arrival.
• Entry via a Point of Entry (PoE) with an appropriate BCP in order for goods to be made available for documentary, identity and physical checks
All live animals and germinal products will need to be accompanied by an Export Health Certificate (EHC); this will need to be secured by the exporter from the EU country of origin’s competent authority.

Where there are no standardised requirements and no model EHC currently exists, the GB importer will need to contact CEFAS/CITC for England/Wales; an importer of live fish/shellfish must be authorised before importing. In Scotland, individual importers do not require authorisation but relevant authorities may need to confirm that the consignment is destined for an authorised facility.

Contact details for relevant authorities can be found here:
• Centre for International Trade Carlisle (CITC)
• Centre for Environment, Fisheries and Aquaculture Science
• Fish Health Inspectorate

All consignments must enter GB via a BCP. The original EHC must be available on arrival at the BCP for documentary inspection.

The UK Government is currently exploring options to build more BCPs and to provide targeted support to ports to do so. Therefore, this list will likely change to include further sites. These changes will be made public in order for traders to prepare accordingly.

The GB importer will also need to submit a pre-notification to the relevant BCP via the Import of Products, Animals, Food and Feed System (IPAFFS) in advance of the goods’ arrival.
Depending on the type of animal, specific welfare requirements may apply including the need for specifically approved transportation vehicles, and certificates of competence or authorisations for the drivers and handlers of the animals. Depending on the length of the journey, a journey log would also need to be submitted to APHA and accompany the consignment.

Details on these are available online.

Additional requirements for endangered species and marine-caught fish
Imports of live animal species listed in the CITES, EUWTR or UKWTR annexes will also need to meet CITES-related requirements as detailed for CITES goods in 3.2.2. These include the requirement for relevant EUWTR export permits from the country of departure and a UKWTR import permit issued by APHA.
Import of live, marine-caught fish will also need to meet catch certificate requirements as detailed in 3.2.4.
Location of checks
All live animals and germinal products will need to enter GB via a suitable BCP.

Upon arrival at the BCP, goods will be subject to documentary, identity, and physical checks. This entails an examination of the official documents which are required to accompany the consignment and a visual inspection to verify the content of the consignment, including the marks on animals, correspond to the official documents.

A physical check may mean a check on, as appropriate, the means of transport, the condition of the animal, and may include sampling for analysis. The level of checks will take into account the level of checks imposed by the EU on GB goods of similar risk status.

Systems
The importer will need to register for IPAFFS.

Process Map: Live Animals

Equines

Requirements
From July 2021, new import requirements will apply to equines from the EU. This includes the requirement for
• goods to be accompanied by an Export Health Certificate (EHC).
• import pre-notifications submitted by the importer in advance of arrival.
• entry via a Border Control Post (BCP), where goods will undergo identity and physical checks.
All equines will need to be accompanied by an Export Health Certificate (EHC); this will need to be secured by the exporter from the EU country of origin’s competent authority.

All goods will need to enter GB via an appropriate BCP, where the goods will be subject to identity and physical checks.
The UK Government is currently exploring options to build more BCPs and to provide targeted support to ports to do so. Therefore, this list will likely change to include further sites. These changes will be made public in order for traders to prepare accordingly.

The GB importer will also need to submit a pre-notification to the BCP via the Import of Products, Animals, Food and Feed System (IPAFFS) in advance of the goods’ arrival.
The driver of the equine transportation would also require a Certificate of Competence, a valid Vehicle Approval Certificate, from Defra, and Transporter Authorisation, from APHA. A journey log would also need to be submitted to APHA and accompany the equine in certain cases.
Details on these are available online.
Location of checks
Equines will need to enter GB via a suitable Border Control Post (BCP) in order for the animals to be checked. A list of current BCPs and the commodities they accept is available here.

The UK Government is currently exploring options to build more BCPs and to provide targeted support to ports to do so. Therefore, this list will likely change to include further sites. These changes will be made public in order for traders to prepare accordingly.

Upon arrival at the BCP, the animals will be subject to identity and physical checks. This entails a visual inspection to verify that the content of the consignment corresponds to the official documents. A physical check means a check on, as appropriate, the means of transport, the condition of the animal, and may include sampling for analysis. The level of checks will take into account the level of checks imposed by the EU on GB goods of similar risk status.

Systems

The importer will need to register for IPAFFS.

Process Map: Equines

Plants and Plant Products

Requirements

From July 2021, all regulated plants and plant products will be subject to import requirements as introduced for April 2021 – see SECTION 2.2.3. However, goods will be subject to an increased number of identity and physical checks.

This includes the requirement for:
• goods to be accompanied by a phytosanitary certificate
• import pre-notification submitted by the GB importer
• documentary and identity checks and physical inspection (frequency dependent on risk)

This will apply to all regulated plants and plant products, which includes high-risk plants and plant products as detailed in 1.2.3. An exhaustive list of the regulated plants and plant products that will require a phytosanitary certificate and pre-notification of import from 1 April 2021 will be published in due course and will include:
• all plants for planting;
• root and tubercle vegetables;
• some common fruits other than fruit preserves by deep freezing;
• some cut flowers;
• some seeds and grains;
• leafy vegetables other than vegetables preserved by deep freezing;
• potatoes from some countries;
• machinery or vehicles which have been operated for agricultural or forestry purposes. These will be subject to checks at a frequency determined according to the risk they pose. Guidance on these will be available in due course.

All regulated plants and plant products imported from the EU will need to be accompanied by a phytosanitary certificate and may be checked upon entry into GB. A phytosanitary certificate is an official document that certifies that the material has been inspected, is considered free from quarantine and other pests, and that it conforms to the plant health regulations of the importing country.

The exporter will need to apply for a phytosanitary certificate from the relevant competent authority of the EU country of origin; this will need to be secured prior to the goods’ departure so that it can be sent to the importer for pre-notification purposes.

Importers will need to submit import notifications at least four hours prior to arrival if travelling by air, or at least one working day prior to arrival by all other modes of transport – along with the original PC.

Checks will be carried out by Plant Health and Seed Inspectors (PHSI) from the Animal and Plant Health Agency (APHA) and the Forestry Commission (FC) in England and Wales, and the Scottish Government in Scotland. Physical inspections will take place at BCPs.
Further information is available here.

Additional requirements for High-Risk Food and Feed Not of Animal Origin and CITES-listed goods

Imports of products categorised as High-Risk Food not of Animal Origin (HRFNAO) will also be subject to these controls as detailed elsewhere in this document.
Plants and plant products that fall under endangered species regulations (CITES/UKWTR) have further requirements as detailed elsewhere in this document.
Locations of checks
EU regulated plants and plant products will be subject to documentary, identity and physical checks. Goods may also be sampled for laboratory testing.
Documentary checks entail examination of official certifications, attestations and other commercial documents that are required to accompany the consignment. This will require all goods to be accompanied by a PC and movements to be pre-notified at least one working day in advance of arrival.
An identity check entails a visual inspection to verify that the contents of a consignment corresponds to the information provided in the accompanying documentation.
Physical checks entail a check on the goods and, as appropriate, sampling for analysis or diagnosis and any other check necessary to verify compliance with phytosanitary import requirements. These checks will take place at BCPs.
Systems

For all regulated plants and plant products, the importer will need to have registered via the relevant IT system. For England and Wales this will be IPAFFS; further information will be available shortly for Scotland.
Importers in England and Wales can register for IPAFFS online.

Wood Packaging Material

Wood packaging material (WPM), including pallets and crates, must meet the ISPM15 international standards for treatment and compliant marking. The WPM holding a consignment may be subject to inspections upon entry to GB to verify compliance with the ISPM15 requirements.
Further details on ISPM15 requirements can be found here.

Process Map: Plants and Plant Products

Share this article