1. Can you help export my cat/dog/horse?
We get a lot of phone enquiries on this. Unfortunately, in general terms, we are unable to assist with live animal exports of the above species. DEFRA/APHA require official veterinarians to be registered on alternative panels in order to certify these species of live animal.
Some of our OVs however, do hold additional panels, to product export, meaning we can help with some niche exports, such as avian exports (poultry and hatching eggs etc), as well as a laboratory and zoo animals, including captive birds.
2. Brexit – What happened on 31/12/20?
The Brexit transition period ended, the UK is a third country and GB will not be in the single market or customs union (although NI effectively is, for now). Many products of animal origin now therefore need export health certificates to travel to EU and NI.
3. What needs an EHC to export?
There are over 100 new EHCs for export to the EU. As a rule of thumb – all meat goods and most other goods containing POAO that are either not heat treated and/or are not shelf stable will need an EHC. So, for example a supermarket shipping raw milk goods, pasteurised milk goods, eggs, poultry, fish, honey, beef, lamb, pork and composite products on one lorry may need 15 or even more EHCs just for that one lorry. If they ship 10 lorries a day, that could be 150 EHCs!
Fresh meat, ‘meat products’, ‘meat preparations’, fish, egg, honey, gelatin, collagen, ‘composite product’, pet food, animal by-products – and many more.
There is also an EHC (8461) that permits the re-export to EU/NI of EU/NI origin goods that are only stored (i.e., no further processing occurs) in GB.
4. What about triangular trade, and what is it?
DEFRA have issued new guidance on 10/3/22 which limits “triangular trade”. Effectively this means that EU or ROW origin goods must be further processed (heating, smoking, curing, maturing, dying, marinating, extraction, extrusion or a combination of these processes) to be eligible to export. Product simply sliced and/or rewrapped cannot be exported.
EU origin goods not changed at all, may be eligible to go on storage EHC 8461, but ROW goods cannot.
5. What is a composite product?
It is defined as “a foodstuff intended for human consumption that contains both PROCESSED products of animal origin and products of plant origin and includes those where the processing of primary product is an integral part of the production of the final product” eg BLT sandwich, lasagne, pork pie, chicken burrito.
However, it is a very complex area and we have experts on hand who have advanced knowledge in this area. There are also ‘compound products’ e.g. fresh beef steak with a butter pat that require 2 or more EHCs.
6. What is a private attestation?
Certain composite goods (eg shelf stable and contain no meat) may not require an EHC but can instead travel with a ‘private attestation’, signed by the importer.
7. What about labelling?
The health mark will need to be ‘GB’ or ‘United Kingdom’, not ‘UK’. FSA guidance can be found here. There are also other labelling requirements.
8. Who can sign my EHC?
Most EHCs must be signed by an official vet – who are appointed by APHA to carry out this work on behalf of DEFRA. A few products, mainly fish, can be certified by a food competent certifying officer (FCCO) – usually an environmental health officer.
OVs can utilise Certification Support Officers to carry out some identity and documentary checks under their direction but CSOs cannot sign EHCs in their own right.
9. What evidence does the OV need to sign the EHC?
This will vary from EHC to EHC, but may include evidence of country of origin/any movement during rearing, veterinary statements/support health attestations, oval health mark, processing details, batch specific temperature records, disease freedom, non-contamination etc. If non-UK origin, we will need the documents that accompanied the goods into the UK, plus similar veterinary assurance from the country of origin.
There is a lot of paperwork and traceability involved – there is much more to it than just turning up, looking at the goods and signing. We CANNOT sign an EHC once the goods have left GB, so supporting documentation and traceability need to be in good order, in plenty of time.
10. How long will it take?
It can vary hugely, depending on the type and number of products, the layout of the depot, the availability of supporting documentation, plus the OV’s familiarity with the goods and the EHC.
It will also depend on the BCP, as the EHC also needs to be completed in this language too.
11. Does the OV need to examine all the goods?
Where reasonably practicable, the OV or CSO will check as much product as possible. However, if you are shipping 10,000 cans of custard every day, and we are familiar with your goods and processing, we are not going to examine every can.
12. What about the UK’s health status?
We have generally been awarded a high health status, with no special guarantees needed for meat. Controlled housing may be used instead of testing for Trichinella in some situations. UK is clear of diseases such as foot and mouth, swine fever, lumpy skin disease. ‘Bird flu’ (HPAI) has caused us to be split into various regions which has causes complications with fresh poultry and poultry product exports.
13. What happens at the BCP?
EU law specifies that the inspecting veterinarian at the border control post will scrutinise every EHC and carry out 100% identity checks on the vehicle and seal and then a risk based physical check on the goods inside (which may include temperature checks and sampling for microbiological analysis) – of between 5 and 30% of consignments.
14. Groupage/GEFS scheme
For mixed consignments of retail goods eg a typical supermarket lorry, the UK has the GEFS scheme. For processed POAO with a stable supply chain, we may be able to carry out an inspection of the manufacturing premises every 30 days which will reduce the need for additional evidence for every batch during that time. However, EHCs are still required for groupage consignments – but the EHC may be easier and quicker for us to sign.
15. Less than load (LTL) freight/consolidation
A lot of freight goes LTL. An OV could certify one pallet that is loaded onto a vehicle, however, they cannot enter a vehicle seal number as it will not be known at that time. EU law does not insist on a seal number (unless the specific EHC requires it), however it may lead to delays and more checks at the other end – and some BCPs do insist on it, along with details of transport. There is the option of using ‘pallet seals’ in such cases.
An OV at the final loading may be able to certify, based on supporting documents from the other OVs or CSOs who have checked the goods and paperwork (linear or hub+spoke groupage models).
The exporter must also be aware that if other products are loaded afterwards and these fail a BCP check, it is possible the entire vehicle contents may be refused and need to be destroyed or reexported – even if your EHC is correct.
If a forwarder is consolidating a load from say 5 different exporters in one lorry, then either the forwarder or the 5 individual companies should apply for the EHCs. There could be one final EHC using the forwarder as the consignor, but the certifying OV will need veterinary documentation from the suppliers to be able to sign.
16. Does the vehicle need a seal?
For the majority of EHCs, this is not a legal requirement, however the BCPs very much prefer a lorry and seal number as this can be used in place of an identity check on the goods and speed things up. This ‘official seal’ must be applied under veterinary supervision.
Some BCPs seem to be more lenient than others and will accept EHCs without lorry/seal details but again we are seeing inconsistency.
Some people are using ‘pallet seals’ in groupage loads to overcome this issue. Again, BCPs vary in how acceptable these are.
17. How many EHCs might one vehicle need?
Worst case – a supermarket shipping raw milk goods, pasteurised milk goods, eggs, egg products, poultry, fish, honey, beef, lamb, pork, venison, game, gelatin, composite products, meat products, tinned pet food, canned pet food on one lorry may need 17 or even more EHCs just for that one lorry. If they have more than two consignees, this could be 34. Am EHC must be signed in English and also in the language of entry). That means 68 EHC versions for 1 vehicle!
18. Consignee details
An EHCs is normally for a shipment of one type of commodity to a single consignee in the destination country. If, say, a supermarket wants to ship to 10 individual stores in the destination country, do they require 10 EHCs or can they set up and ship to a company set up in that country? Does that company need to have a physical presence there? It depends on the legal status of the companies and specialist advice should be sought.
19. Can the EHCs be done electronically?
Technically – yes. However, this is not fully available yet for us in the UK. There is a system which is currently being trialled by one of our clients for certain EHC types to Northern Ireland.
20. TRACES
A scanned EHC copy will be made and sent to the exporter. The BCP must be notified electronically, and the CHED part 1 completed on TRACES, potentially up to 24 hours in advance of arrival of the shipment. EU law gives the BCP some discretion to reduce this to 4 hours.
21. What if the driver loses the original EHC?
EU law insists the original copy must be presented at the BCP, so a ‘cancel and replace’ would be needed. APHA have made this an instant process for most EU EHCs so the OV can action and sign straight away. The physical hard copy of the C+R must then go to the BCP.
22. What happens if the EHC is rejected?
If it is rejected due to a ‘typo’ or admin error, then EU law allows a ‘cancel and replace’ as above. However major errors, or the wrong EHC being sent, will require the goods to be destroyed or returned to the UK.
23. What about the volume of goods?
It will certainly be a challenge – we have extra OVs and CSOs on standby to cope with the extra volume and are aware that it may be a 24/7 operation in some cases.
24. What about importing goods into GB?
We do not specifically advise on imports, however in many (but not all) cases it mirrors the export process. GB is introducing pre-notification on IPAFFS 1/1/22 and further physical checks and a phased introduction of EHCs from 1/7/22.
1/7/22 – meat, meat products and animal by-products.
1/9/22 – dairy
1/11/22 – fish, composite and other regulated products
25. How can I make it easy?
No simple answer on this one without completely reworking your distribution systems. There will inevitably be delays and teething problems.
- Arrange loads so all the dairy is on one lorry, the meat on another etc, where possible
- Arrange your shipments in as short a window as possible to minimise vet time on site
- Ship from the same depot on the same day(s) each week to help with resourcing OVs
- Consider direct EU to EU shipping of goods where possible
- Work with your suppliers to ensure paperwork is correct and prompt.
26. Is there technology which can help?
There is commercial software available that can track and capture much of the information required. We have assisted in its development and can put you in touch with the developer if you wish to explore in more detail what it can offer. There is also the digital assistance scheme (DAS) in testing by DEFRA, designed to allow electronic certification, though this is still being trialled.