What importers need to do to prepare for the rules and processes if the UK leaves the EU with no deal.
Rules from 29 March 2019 (may also apply to new exit date on 31 December 2020): imports and control requirements
After the UK leaves the EU, you’ll still be able to import animals, animal products, food and feed whether from the EU or elsewhere. However, the process for notifying the UK authorities of these imports will change. Some import requirements from the EU to the UK may also change.
Use this guidance to understand what will and will not change if you’re importing to the UK:
- directly from third countries (non-EU member states or European Free Trade Agreement countries)
- from third countries and travelling through EU member states
- directly from EU member states
To import animals, animal products, high-risk food and feed to the UK, you’ll need to:
- make sure you know the import notification process for importing from non-EU and EU countries
- speak to your exporters from non-EU and EU countries to make sure they’re aware of the changes
- for live animals and germplasm, notify the Animal and Plant Health Agency (APHA) – or the Department of Agriculture, Environment and Rural Affairs (DAERA) in Northern Ireland – for EU trade or the UK border inspection post (BIP) for non-EU trade that your consignment is arriving at least 24 hours in advance
- for germplasm, products of animal origin (POAO) and animal by-products (ABP) subject to vet checks, notify the UK BIP (for non-EU trade) that your consignment is arriving in advance
- for POAO and ABP from the EU that travel on official documentation (an Intra Trade Animal Health Certificate (ITAHC) or commercial documents (DOCOMs)), notify APHA at least 24 hours before arrival
- import non-EU high-risk food or feed of non-animal origin into the UK through a designated point of entry (DPE)
- comply with wider HMRC customs guidance on customs requirements for importing and consider whether you’ll need an import agent
New notification process for imports from non-EU countries and EU countries
If the UK leaves the EU without a deal on 29 March, you’ll no longer have access to the EU’s import system TRACES (Trade Control and Expert System) for importing into the UK.
To ensure imports of live animals, products of animal origin, animal by-products, germplasm and high-risk food and feed not of animal origin can continue after exit, the UK is launching a new system called the ‘Import of products, animals, food and feed system’ (IPAFFS).
The Department for Environment, Food and Rural Affairs (Defra) is releasing IPAFFS in phases.
From 29 March, you can use IPAFFS if you’re importing live animals, animal products and high-risk food and feed not of animal origin from non-EU countries.
You can register for IPAFFS from early March 2019, and create notifications for consignments arriving after 29 March.
Find out more about how to use it in the IPAFFS user guidance.
You’ll be able to use IPAFFS to notify us of high-risk food and feed, live animals, germplasm from the EU from summer 2019.
Direct imports from outside the EU to the UK
If you import directly from outside the EU on 29 March changes will apply to requirements for notifications of the following:
- live animals
- POAOs subject to veterinary checks
- high-risk food and feed not of non-animal origin
- ABPs subject to veterinary checks
You’ll need to:
- use IPAFFS instead of the EU’s TRACES to notify imports
- import high-risk food or feed of non-animal origin into the UK through a DPE as you do currently – find out which DPE you need from the Food Standard Agency’s list of DPEs
- import live animals, germplasm, POAOs and ABPs into the UK through a UK BIP (there is currently no BIP in Dover)
Health certificates and other documentation currently used for imports into the EU will be accepted for 6 months after the UK leaves the EU. After that, you’ll need to use a new UK health certificate.
Imports from outside the EU travelling via EU member states
If you’re importing POAOs, germplasm and ABPs not for human consumption from non-EU countries that are subject to vet checks from non-EU countries but transiting through the EU to the UK, they’ll need to arrive in the UK through a BIP.
If you’re importing high risk food and feed from non-EU countries that will transits through the EU, they’ll need to arrive in the UK through a DPE.
Further guidance on transit goods for other commodities, such as live animals, will follow.
Direct imports from EU countries to the UK
You will not be able to use IPAFFS from 29 March if you’re planning to import live animals and animal products from the EU. Until IPAFFS is made available in summer 2019, you’ll need to send information electronically to the competent authorities though a different process.
You’ll need to use this process to notify import of:
- live animals, germplasm or equines requiring a health certificate or travelling under official documentation (DOCOMs)
- animal products from EU countries with disease outbreak safeguards measures
- live animals that do not require a health certificate or official documentation (but are required under the Trade in Animals and Related Products regulations (TARP) to be notified)
You’ll also need to:
- Notify authorities using a form on GOV.UK, and submit this to APHA with details of the consignment including origin, destination, purpose and export details.
- Quote the unique notification number issued by APHA within 24 hours of receipt of the form on applicable documentation.
- Send this number to the EU official vet for them to complete the ITAHC or UK health certificate. You can do this through the EU exporter. The UK government is working with the EU Commission to ensure all member states, competent authorities and official vets will have access to the new health certificates. For consignments previously travelling on commercial documents (DOCOMs), add the unique reference number to the DOCOM and send to APHA.
- Notify animals and germplasm imports at least 24 hours before arrival.
- If you’re importing to Northern Ireland, email scanned copies of the health certificates to DAERA on firstname.lastname@example.org as soon as they’re available.
This notification is already a legal requirement. A new UK health certificate will be required for live animals and germplasm however a current ITAHC if one was issued by the EU will be also be accepted for 6 months post-exit.
This route will also be used to notify of imports from Northern Ireland and the crown dependencies to the UK.
More guidance will be available shortly.
Importing food and feed from EU countries to the UK
You can continue your normal trade activities for importing feed and food from the EU from 29 March. There will be no additional controls or checks. You will not need to notify these on IPAFFS.
You’ll need to notify UK authorities about high-risk food and feed products from the EU from summer 2019. Further details on this will be provided in advance.
Products may be considered high risk if they contain, for example:
- contaminants – mycotoxins and aflatoxins
- excessive pesticide residues
- heavy metals, for example mercury
If you’re importing high-risk products from countries outside the EU you will need to notify authorities using IPAFFS.
You’ll need to make sure your consignment travels through a DPE. Find out which you need from the list of DPEs on the Food Standard Agency (FSA) website.
Find out more information on high-risk products, including the current list of products defined as high risk.
Importing animal by-products not for human consumption (ABP) from EU countries to the UK
If you’re importing category 3 ABPs from the EU, you can continue normal trade activities from 29 March. There will be no additional controls or checks. It’s likely that from 29 March you will not be permitted to import category 1 and 2 ABPs from the EU.
Documents for transporters
From 29 March 2019 (may also apply to new exit date on 31 December 2020), documents issued by the UK will only be valid in the UK and not in EU countries.
Read the Department for Transport’s guidance on preparing to drive in the EU after Brexit for more information.
If you’re a UK transporter who transports live animals in the EU you’ll need to appoint a representative within an EU country. You’ll need to apply to the relevant government department to get a:
- transporter authorisation
- certificate of competence
- vehicle approval certificate
- journey log (where necessary)
Checks at the UK border
An increased number of checks is expected as consignments will need to be checked at UK DPEs and BIPs. This includes high-risk food and feed not of animal origin which travel through the EU and do not go through EU import checks.
Those carrying out the UK import control checks will be fully trained to minimise disruption. IPAFFs will be used to plan and record controls at BIPsand DPEs with notifications enabling the necessary checks to take place.
How the UK government is working with interested parties
The government will continue to work with businesses to help them prepare for these changes. We have published guidance for users of IPAFFS. Guidance for imports from the EU will follow.
Other import requirements
You will have to apply customs, excise and VAT procedures to goods traded with the EU. You should:
- get an Economic Operator Register and Identification (EORI) number to be able to trade
- check for potential EU trade tariff changes
- find out the commodity code for your goods
- determine the value of your goods
- check if your goods are prohibited or restricted
- choose the correct customs procedure code (CPC) for your goods
- declare your import to customs – find out how in the guidance on importing from outside the EU
Find out more about HMRC customs requirements for imports to the UK in Preparing for a no deal EU Exit: step-by-step guide to importing.
If the UK leaves the EU without a deal, there will be no implementation period. In this scenario, the government will seek to bring into force UK-third country agreements from exit day, or as soon as possible afterwards.
These new agreements will replicate existing EU agreements as far as possible. Where replacement trade agreements are not agreed, trade would take place on World Trade Organisation (WTO) terms with that country. Details of each agreement will be shared with parliament and the public when they have been agreed.
Read the guidance on existing free trade agreements if there’s no Brexit deal.