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Bulletin 17

Are you Brexit ready?

POAO – No, not “pow wow” but Product of Animal origins are today’s bulletin subject headlines.

Defra is in control of these matters and we would like to bring these subjects to your attention by starting with the overview of the items involved.

In particular, we shall concentrate on the exportation and importation of the blue highlighted headings above.

The group of products is collectively also known as Products of Animal Origins or POAO.

You’ll need to get a license or certificate to export some types of these goods from the UK and we would ask you to check your requirements well in advance especially if your products are required to be issued with an Export Health Certificates or Catch certificates.

The section of the topic of live animals and animal products is split into 

  • Live animals and genetic material
  • Animal products for human consumption
  • Animal by-products/products not for human consumption
  • Miscellaneous

Another major product group which is falling under the category of special requirements is

Fish for human consumption.

Please find the government website for further information
https://www.gov.uk/guidance/exporting-and-importing-fish-if-theres-no-brexit-deal

To export these products, you will need either Health certificates or Catch certificates as these products will be inspected by the EU at their Border Inspection Posts (BIP) when entering the EU.

Fish inspections will take place at the BIP in Boulogne.

All other POAO will be inspected at the BIP at Calais or any other point of entry (PoE) in the EU.

Please double check your routing on your FTL routes as some PoE have not yet established a BIP which means vehicles will be not allowed to proceed out of the port area and therefore must return to the UK to find a different route into the EU. The Nagel -Group will use the Dover/Calais route as default.

All EU BIP’s request pre-advice/booking in procedures for the POAO - 24 hours before arrival in the EU.

To make matters worse UK companies without an EU base will no longer be able to use the EU TRACES (Trade Control and Expert System) yet you are required to comply with EU laws to register your goods on TRACES on arrival in the EU. The Nagel-Group will offer the service to register your goods on TRACES through our EU offices involved for a fee.

Government Information on the importation of Products of Animal Origin are currently very loose and not 100% specified. For the first 3 months after the 01.01.2021, it seems that the UK Government is applying an open-door policy without any checks or, if checks are to take place, it will be at the place of delivery.

From January 2021: Controls from 1 January 2021 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) from July 2021

From April 2021: All products of animal origin (POAO) – for example meat, honey, milk or egg products – and all regulated plants and plant products will also require pre-notification and the relevant health documentation. Any physical checks will continue to be conducted at the point/place of destination until July 2021.

From July 2021 at the latest - all POAO products will be subject to full physical check procedures at the UK Border Control Post (BCP) which are the equivalent of EU BIP’s.

As previously reported the EU Traces system will be no longer be available in the UK and the UK Government has introduced the replacement system ‘Import of Products, Animals, Food and Feed System’ (IPAFFS) to certify UK imports and which should be used instead of Traces.

Please visit the APHA Vet Gateway for further information. http://apha.defra.gov.uk/

If you are one of the Nagel-Group customers who are exporting and importing POAO goods please advise us of your Export Border readiness (Export Health Certificates / Catch Certificates etc.) no later than 30 November 2020 as we need to discuss with you the flow of documents in order to keep the transit times for your goods from the UK collection point to the EU delivery point to the absolute minimum.

The last, but not least, point of our todays bulletin is regarding:

Packaging issues which will come into effect as of 01.01.2021

Movement of wood packaging material

Wood packaging material (WPM) moving between the UK and the rest of the EU can currently move freely without checks or controls.

WPM includes:

• pallets

• crates

• boxes

• cable drums

• spools

• dunnage

From 1 January 2021 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 from 1 January 2021.

Important!

Please note in this respect that if your goods are rejected either by your customers or, more than likely, by EU official bodies such as Customs, Police, Health officials due to noncompliance with ISPM 15 rules the Nagel Group will have no alternative but to charge you with all associated costs of such an event/incident - e.g. demurrage charges, inspection charges, return of goods costs etc.

Please make sure your company is ISPM 15 compliant. Speak to your packaging supplier and order early as we anticipate shortages of these ISPM15 pallets in the early days of 2021.

We have started to compile useful links which we will carry forward to the next bulletins:

https://www.gov.uk/transition

https://www.gov.uk/prepare-to-export-from-great-britain-from-january-2021

https://www.gov.uk/prepare-to-import-to-great-britain-from-january-2021

https://www.gov.uk/government/organisations/animal-and-plant-health-agency

https://www.ippc.int/en/publications/640/ (ISPM15)

http://ehmipeach.defra.gov.uk/

https://www.gov.uk/guidance/importing-animals-animal-products-and-high-risk-food-and-feed-not-of-animal-origin-from-1-january-2021

Our next bulletin shall concentrate on Nagel-Group European abilities to help our customers and your customers and/or suppliers and we shall start sketching out the Export and Import processes and the procedures which will be applicable.

All information provided by Dover International Department (DVI) of Nagel Langdons Ltd. If you are a UK based company and you seek support or help to prepare for Brexit please contact UK customs. If you are a Continental based company please contact Continental customs.