EXPORT OF FORESTRY PLANTS, WOOD AND WOOD PRODUCTS FROM IRELAND INTO THE UK IN THE CASE OF A NO-DEAL BREXIT.
Context – Plant Health Legislation Exports of commodities from Ireland into other parts of the EU – including into the UK are currently regulated under Council Directive 2000/29/EC, commonly called the Plant Health Directive. This describes phytosanitary (“plant health”) legislation and requirements for the movement of regulated commodities, in order to prevent the introduction and spread of organisms harmful to plant and forest health.
Context – Brexit The UK has voted to leave the EU and it will become a Third Country (non-EU Member State) from the date of withdrawal. As of the date the United Kingdom exits the European Union the regulation of export of forestry plants, wood and wood products from Ireland to the UK under the above Directive will no longer apply and will then be regulated by UK phytosanitary legislation.
If you are an exporter of wood or wood products from Ireland to the UK you should familiarize yourself with post-Brexit UK phytosanitary (plant health) import requirements which will come into force on the date of withdrawal (see link below).
In the event of a No-Deal Brexit, this comes into effect when the UK leaves the EU.
What you should do now
A. Establish whether the commodity you are exporting to the UK is a regulated commodity
Generally, the phytosanitary entry requirements that apply to certain forestry plants, wood and wood products depend on the species, the country of origin and the form/nature of the wood or commodity.
Regulated export commodities and requirements are defined by the country of import (UK authorities in this case) and exporters are advised to clarify UK import requirements by commodity with the UK authorities directly or through their UK customer. Further information on UK requirements is available at https://www.gov.uk/guidance/importing-and-exporting-plants-and-plant-products-if-theres-nowithdrawal-deal
A. Register with DAFM for Plant Health Prior to exporting regulated wood and wood products from Ireland, exporters are required to register with the Department. To receive a timber importers/exporters registration form, contact: forestprotection@agriculture.gov.ie Department of Agriculture, Food and the Marine Forest Health Section 3 West Agriculture House Kildare Street DUBLIN 2 DO2 WK12
See “Plant Health Registration” link and Application Form.
What you need to do prior to export of regulated commodities to the UK
Obtain Official Certification of the regulated commodity in Ireland from DAFM prior to export to the UK
If the commodity for export is a regulated commodity under post-Brexit UK phytosanitary (plant health) import requirements the consignment will need to be officially certified by the National Plant Protection Organisation (NPPO) which is DAFM in Ireland and which will involve an inspection and the provision of a Phytosanitary Certificate for UK Authorities.
A. Provide the following to DAFM. i. Exporters should establish the import requirements for the commodity they wish to move into the UK. (This is the exporter’s responsibility). ii. Exporters should provide a statement from the UK authorities as to whether a phytosanitary certificate is required to accompany these consignments, and if so indicate any additional declaration that needs to be included on the phytosanitary certificate (see B(iii)below). B. Apply for a Phytosanitary Certificate
If the commodity is regulated and a Phytosanitary Certificate is required the exporter should apply to DAFM for a Phytosanitary Certificate. A phytosanitary certificate application form may be requested from forestprotection.gov.ie
i. The importer is required to complete and submit a phytosanitary certificate application form for each consignment. ii. The application form should be submitted at least two weeks prior to a date / time suitable for inspection, and detail the location and time an inspection can be facilitated. iii. The application should include any additional declaration as required by the NPPO of the importing country in the appropriate field on the application (see A.ii above). iv. A forestry inspector will inspect the consignment at an arranged time and place for conformity to the details submitted on the application form. v. If the inspection is passed, the phytosanitary certificate will be issued.
The country of import may require advance notification from the importer of the intention to import which may include provision of the Phytosanitary Certificate. Current indications are that three days notice of intention to import is required by UK authorities. UK Customs procedures may also apply.
Fees Council Directive 2000/29/EC, Annex VIIIa sets out the schedule of fees for documentary, identity and plant health checks.
Queries Department of Agriculture, Food and the Marine Forest Health Section 3 West Agriculture House Kildare Street DUBLIN 2 DO2 WK12 forestprotection@agriculture.gov.ie
IMPORTATION OF FORESTRY PLANTS, WOOD AND WOOD PRODUCTS INTO IRELAND FROM THE UK IN THE CASE OF A NO-DEAL BREXIT.
Context – Plant Health Legislation The importation into and the movement within the EU of inter alia certain wood and wood products from non-EU (“Third Countries”) is regulated under Council Directive 2000/29/EC, commonly called the Plant Health Directive, which sets-out phytosanitary (“plant health”) legislation and requirements in order to prevent the introduction and spread of organisms harmful to plant and forest health.
Context – Brexit The UK has voted to leave the EU and it will become a Third Country (non-EU Member State) from the date of withdrawal. As of the date the United Kingdom exits the European Union the introduction of forestry plants, wood and wood products from the UK into the EU will be regulated by the above Directive in the same manner as for other Third Countries.
If you are an importer of forestry plants, wood or wood products from the UK which are regulated under Council Directive 2000/29/EC, you are required to complete and observe a number of new DAFM phytosanitary (plant health) requirements which were not required when the UK was an EU member state. (Importers are also encouraged to familiarise themselves with relevant Revenue requirements).
In the event of a No-Deal Brexit, this comes into effect on when the UK leaves the EU.
What you should do now A. Establish whether the commodity you are importing from the UK into Ireland is a regulated commodity
Generally, the phytosanitary entry requirements that apply to forestry plants, wood and wood products depend on the species, the country of origin and the form/nature of the commodity. For example in the case of imports from the UK, coniferous sawnwood and roundwood with bark are regulated commodities. If an importer is unsure whether the commodity they wish to import into Ireland is regulated, or for information on the entry requirements of regulated wood, queries can be submitted to forestprotection@agriculture.gov.ie.
B. Register with DAFM for Plant Health Prior to importing regulated wood and wood products into Ireland, importers are required to register with the Department. To receive a timber importers/exporters registration form, contact: forestprotection@agriculture.gov.ie Department of Agriculture, Food and the Marine Forest Health Section 3 West Agriculture House Kildare Street DUBLIN 2 DO2 WK12
See “Plant Health Registration” link and Application Form.
What you need to do prior to import of regulated commodities
A. Obtain Official Certification of the regulated commodity in the UK prior to export. If the commodity is a regulated commodity under Council Directive 2000/29/EC the consignment will need to be officially certified by the National Plant Protection Organisation (NPPO) of the UK which will involve an inspection and the provision of a Phytosanitary Certificate by UK Authorities to the importer. B. Provide advance notification of import to DAFM
Advance notification to DAFM is required of regulated wood imports. A minimum of 24 hours notice is required but in the case of some products, depending on the means and duration of transport (shipping), this notice period may be 72 hours.
The importer / shipping agent then submits to the Forest Health section, via the email address forestprotection@agriculture.gov.ie, the following documents associated with the consignment:
o The red routed SAD o The packing list and Bill of Lading o The phytosanitary certificate, and/or other plant health documentation required for the regulated commodity as set out under Directive 2000/29 EC as amended.
Landing, Inspection and clearance of the consignment.
A. Ports of Import Regulated commodities from Third Countries can only be imported through approved Border Inspection Points (BIPs) or Designated Points of Entry (DPEs).
B. DAFM Inspection & release of the commodity. DAFM Phytosanitary inspection involves three aspects – a documentary, identity and plant health check of the imported commodity The identity and plant health checks require the physical inspection of the commodity. If all is found to be compliant, the Inspector confirms to Customs that the phytosanitary inspection has been satisfactory and Customs may green route the consignment for onward movement. Note: The consignment remains under Customs control for the duration of the inspection.
Fees Council Directive 2000/29/EC, Annex VIIIa sets out the schedule of fees for documentary, identity and plant health checks.
Queries Queries in relation to this or any other aspect of the importation of wood and timber can be sent to: Department of Agriculture, Food and the Marine Forest Health Section 3 West Agriculture House Kildare Street DUBLIN 2 DO2 WK12 forestprotection@agriculture.gov.ie
ISPM No.15 and Wood Packaging Material (WPM) requirements in the event of a ‘No-deal’ Brexit
What is ISPM No.15? ISPM No. 15 is an international phytosanitary (plant health) measure developed by the International Plant Protection Convention (IPPC) that sets down standards for the phytosanitary treatment and marking of Wood Packaging Material (WPM). WPM is a term used to describe pallets, crates, dunnage etc. used in international trade for the transport of goods of all kinds. The aim of ISPM No.15 is to prevent the international movement and spread of disease and insects harmful to the health of plants, trees forests or ecosystems.
ISPM No. 15 does not currently apply Ireland-UK trade. The following is a summary of the stated positions of the UK and the EU in relation to ISPM No.15 as of the withdrawal date. In the event of a No-Deal Brexit, the UK will leave the EU and become a third country (i.e. a non-EU Member State) when the UK leaves the EU. ISPM No.15 and the export of goods using WPM from Ireland to the UK Wood Packaging Material (WPM) including pallets, crates and dunnage, used in the transport of goods moving from Ireland to the UK does not currently need to meet ISPM No.15 requirements. In the event of a ‘no deal’ Brexit the position of the UK Government, as indicated in its guidance document updated 21st February 2019 (and which can be accessed by following the link below), is “In the event of no deal, all WPM moving between the UK and the EU must meet ISPM15 international standards by undergoing heat treatment and marking. All WPM may be subject to official checks either upon or after entry to the EU. Checks on WPM will continue to be carried out in the UK on a risk-targeted basis only. The plant health risk from WPM imported from the EU is not expected to change as a result of an EU exit. https://www.gov.uk/guidance/importing-and-exporting-plants-and-plant-products-if-theres-no-withdrawal-deal
ISPM No.15 and the import of goods using WPM from UK to Ireland The EU has indicated the following regarding imports into the EU. “As of the withdrawal date, the introduction of plants, plant products and other objects from the United Kingdom into the EU-27 will be governed by this Directive (Council Directive 2000/29/EC). This is in particular relevant for the introduction into the EU of wood packaging material: such wood packaging, whether or not actually in use for the transport of objects of all kinds, has to be compliant with a treatment and mark as specified in the FAO International Standard for Phytosanitary measures No 15 (‘ISPM 15’)”. https://ec.europa.eu/info/sites/info/files/file_import/plant_health_en.pdf
Keeping up to date In the context of Brexit preparedness and in order to monitor developments on the UK Government’s position and the EU Commission’s position in the event of a ‘no-deal’ Brexit, it is recommended that you refer to the above links in order to remain fully informed of the official positions. You are strongly urged to keep this evolving situation under review.
Contacts and further information DAFM & EU Brexit information is available at https://www.agriculture.gov.ie/brexit/ and https://ec.europa.eu/food/plant/plant_health_biosecurity_en Further information on ISPM No.15 is available at https://www.agriculture.gov.ie/forestservice/foresthealthandseeds/exportsofwoodpackagi
