Food Imports

Importing
Steps to take
Getting ready 

Importing

From 1 January 2021, food and food contact materials coming from Great Britain will be an import from a third country (a non-EU country). To continue to trade with Great Britain from this date, you will need to comply with import requirements. Knowing these requirements will help reduce the impact of Brexit on your food business.

Checks on imports

Checks (controls) are carried out on food and food contact materials entering the EU market to ensure they meet the requirements of EU food law.  These controls  include:

  • documentary checks
  • identity checks
  • physical checks

Higher risk imports

Some foods and food contact materials are considered to pose a higher risk to public health, animal health, or the environment in terms of diseases, pests, or contaminants. Additional requirements are in place to control such risks and include:

  • additional documentation
  • prior notification before arrival of the food into Ireland

These products must enter Ireland through a specific entry point called a Border Control Post (BCP).

Steps to take to import food from Great Britain

  1. Register for an EORI (Economic Operator Registration and Identification) number
    • You cannot trade with Great Britain without this number
  2. Know the classification code (CN) of your product
    • You will need this code when completing import documentation for your product
  3. Identify the type of product you will be importing because each food type has different requirements
  4. Register with TRACES NT (EU online System) if you are importing
    • Food of animal origin
    • Composite products that require veterinary checks
    • Certain foods of non-animal origin
    • Fruit and vegetables
    • Organic food
  5. Be familiar with the documentation and notification periods for food imports, and identify who is responsible for submitting the documents
  6. Consider how to simplify consignments so that products needing identity/physical checks are easily accessible to inspectors

Getting ready

It’s important to be aware of how the end of the transition period (31 December 2020) will affect your business. For further information on the changes:

 

Last reviewed: 9/10/2020

oods of animal origin

Food of animal origin imported into Ireland from a third country is subject to veterinary controls at one of Ireland’s Border Control Posts (BCPs). It is also subject to specific requirements such as registration of the importer, pre-notification of its arrival, submission of mandatory documentation and identity and physical checks on arrival at the border control post.

Register with the Department of Agriculture, Food and the Marine (DAFM)

Importers of food of animal origin must register with DAFM. The person responsible for the consignment must register on TRACES NT. This is an EU online platform used for the importation of animal products, certain food of non-animal origin and plants into the EU, as well as certain intra-EU trade and exports of animals and certain animal products.

Get details on how to register with DAFM

Documents and pre-notification

The person responsible for the load (the importer, or an agent working on their behalf) must complete and submit a Common Health Entry Document (CHED-P) for animal products through TRACES, a minimum of 24 hours in advance of the consignment’s arrival into Ireland.

Check the information on DAFM’s website to make sure you have the correct documents for your product of animal origin.
A CHED is required for each animal product so a mixed load could have a number of CHEDs for one consignment 

Check your supply chain

Make sure your suppliers of food of animal origin can provide you with the appropriate documents and certificates to allow the foods to be imported.

Foods of animal origin

Food of animal origin imported into Ireland from a third country is subject to veterinary controls at one of Ireland’s Border Control Posts (BCPs). It is also subject to specific requirements such as registration of the importer, pre-notification of its arrival, submission of mandatory documentation and identity and physical checks on arrival at the border control post.

Register with the Department of Agriculture, Food and the Marine (DAFM)

Importers of food of animal origin must register with DAFM. The person responsible for the consignment must register on TRACES NT. This is an EU online platform used for the importation of animal products, certain food of non-animal origin and plants into the EU, as well as certain intra-EU trade and exports of animals and certain animal products.

Get details on how to register with DAFM

Documents and pre-notification

The person responsible for the load (the importer, or an agent working on their behalf) must complete and submit a Common Health Entry Document (CHED-P) for animal products through TRACES, a minimum of 24 hours in advance of the consignment’s arrival into Ireland.

Check the information on DAFM’s website to make sure you have the correct documents for your product of animal origin.
A CHED is required for each animal product so a mixed load could have a number of CHEDs for one consignment 

Check your supply chain

Make sure your suppliers of food of animal origin can provide you with the appropriate documents and certificates to allow the foods to be imported.

Food of non-animal origin

Register
Temporary Increased Controls
Emergency Measures

Food imports of non-animal origin from third countries are subject to import requirements which include registering as an importer and submitting import documentation. Consignments are risk assessed and inspected by Environmental Health Officers (EHOs) at Dublin port and Dublin airport. Some consignments may be randomly chosen for identity/physical checks.

All imports of food of non-animal origin need a customs declaration and commercial documents relevant to the consignment. Foods with temporary increased controls or emergency measures have additional requirements.

Notify the Environmental Health Service of the Health Service Executive

To import food of non-animal origin, you need to notify your food business to the Environmental Health Service of the Health Service Executive. You can do this online on the HSE website. You can also use this online system to make changes to your notification.

Some foods of non-animal origin have specific import requirements. These foods must enter Ireland through a Border Control Post and

  • most are subject to registration on TRACES NT ( an EU online platform used when importing or exporting certain products including food of animal origin and certain food of non-animal origin),
  • must pre-notify their arrival and
  • require additional import documentation

Temporary increased controls

There are temporary increased controls for some foods of non-animal origin from certain third countries. This is due to a known or emerging risk, or because of widespread non-compliance with food law.

Annex I of Regulation 2019/1793 lists the food of non-animal origin subject to a temporary increase of controls at border control posts. This list is reviewed by the Commission at least twice a year.

For food that has specific import requirements, the person responsible for the load must complete a Common Health Entry Document (CHED-D) through TRACES NT in advance of the arrival into Ireland of the consignment. A model for CHED-D is in Annex II to Commission Implementing Regulation (EU) 2019/1715.

Additional requirements

  • Prior notification of 24 hours is required for foods subject to increased controls
  • Foods must be presented at a Border Control Post (BCP).

The increased control mechanism means that competent authorities will:

  • carry out checks on all the documents accompanying the consignments
  • conduct identity and physical checks, including laboratory analysis, at a frequency set down in the legislation for the specific commodity being imported

Emergency measures

Emergency measures are in place for a range of food commodities coming into the EU where a food is likely to pose a serious risk to human health, animal health or the environment.

Annex II of Regulation 2019/1793 lists the foods from certain countries subject to special conditions for the entry into the EU due to contamination risk by, for example mycotoxins including aflatoxins, pesticide residues, chemical, microbiological and other contamination e.g. unauthorised dyes, additives. This list is reviewed by the Commission at least twice a year.

In addition, there are a number of emergency measures under other legislation with import conditions that are specific to each measure:

  • GM rice from China
  • Food from Japan post Fukushima
  • Food from certain countries post Chernobyl
  • Sprouts and seeds for sprouting from 3rd countries

Annex IIa of Regulation 2019/1793 lists the foods from certain third countries that are prohibited from being imported into the EU.

For foods with emergency measures you must have:

Get more information on temporary increased controls and emergency measures

Document checks

Document checks can be carried out, and the products cleared before the food products arrive at the point of import into Ireland. To avoid delays it is essential that all necessary import documents are complete, accurate and submitted within the notification timelines.

Identity and physical checks

Identity check

This a visual inspection to ensure that certificates or other documents accompanying the food consignment match the labelling and the content of the consignment.

Physical check

A physical check is a check on food which may include checks on:

  • the means of transport
  • packaging
  • labelling
  • temperature

Sampling for analysis and laboratory testing may be done and any other check necessary to verify compliance with food law.

Importing composite products

Commission Decision 2007/275/EC defines a composite product as a foodstuff intended for human consumption that contains both processed products of animal origin and products of plant origin, examples of composite products include cheese and pepperoni pizza, salmon and broccoli quiche, mayonnaise (made with pasteurised egg).

A composite product will be subject to veterinary checks at a Border Control Post if:

  • it contains a processed meat ingredient
  • its total food of animal origin content is greater than or equal to 50%
  • it contains less than 50% of any other (i.e. not meat)  processed food of animal origin and does not meet the criteria for the derogations or exemptions in  Article 6 of Commission Decision 2007/275/EC

Composite products subject to veterinary checks  must give at least 24 hours notice prior to the arrival of the consignment at the Border Control Post. They must be accompanied by a composite product health certificate.  Further details are available on the DAFM website.

Exemptions

Commission Decision 2007/275/EC grants an exemption from veterinary checks on import to composite products that meet certain criteria:

or

they contain less than 50% of any processed food of animal origin other than meat and they meet all the conditions laid down in Article 6 of Commission Decision 2007/275/EC i.e.

  1. shelf-stable at ambient temperature or has undergone in its manufacture a complete cooking or heat treatment process throughout their substance, so that any raw product is denatured
  2. clearly identified as intended for human consumption
  3. securely packaged or sealed in clean containers
  4. accompanied by a commercial document and labelled in an official language of a Member State, so that that document and labelling together give information on the nature, quantity and number of packages of the composite products, the country of origin, the manufacturer and the ingredients;

Any milk product included in a composite product must only be derived from (and treated as provided for in Regulation 605/2010) countries approved by the EU for imports into the EU.

Last reviewed: 3/9/2020

Share this article

Contact McMahon Legal