What does the notice say?
The notice sets out how businesses or individuals that export animals or animal products (meat, dairy products, eggs, etc) to EU countries would be affected if the UK leaves the EU in March 2019 with no deal in place.
Export Health Certificates
In a no deal situation Export Health Certificates (EHCs) would be required for every export of live animals or animal products from the UK to the EU, this is to prove the consignment complies with the quality and health standards of the destination country – in this case the EU. EHCs would need to be signed by an Official Veterinarian following inspection of the consignment and they are commodity and destination specific.
The government has now released further guidance on this and it is suggested you follow the below five steps:
- Find the EHC and other forms you need on the export health certificate form finder. If you’re exporting from Northern Ireland, contact your local DAERA office. Most EHCs also have guidance documents telling you how to fill out the certificate.
- Nominate an official vet (OV) or local authority inspector (usually an environmental health officer) to inspect your product. There are various ways you can find one:
- Fill in the EHC and supporting forms and email them to the APHA address provided on the forms.
- APHA will send your EHC to your official vet or inspector within 7 working days. Or within 1 working day if you plan to export in the next 7 working days.
- The vet or inspector will check the animal or animal product meets the health requirements of the destination country, and complete and sign the EHC. The completed EHC will go with the animal or animal product, and the vet or inspector will send a copy to APHA.
There is no fee for the certificate itself but you will be charged for your vet or inspector’s time.
Border and Customs offices
Alongside an EHC in order to export animals or animal based products to the EU you must:
- Ensure the trade route for your goods allows for your consignment to be checked at a border inspection post (BIP) at the first EU country you enter for export
- Make sure your EU-based import agent has notified the BIP that your consignment is arriving at least 24 hours in advance
- Comply with wider HMRC guidance on customs requirements for exporting to the EU
Third country listing
The EU would require the UK to be listed as an approved third country. In the event of a ‘no deal’ scenario, the UK has applied for this status but cannot be certain of the EU response or its timing. Without this listed status no exports of live animals or animal products could enter the EU.
In the event of no deal UK issued transport documentation would cease to be recognised by the EU and would only be valid for transport within the UK.
If you are transporting live animals using a UK transporter from the UK into the EU you will need to appoint a representative within an EU country. You will then need to work with this representative to apply to the relevant government department to obtain the following documents:
- transporter authorisation
- certificate of competence
- vehicle approval certificate
- journey log – this is necessary for journeys over eight hours long
You will need to apply for a journey log from the first EU country you enter for export and show this at a BIP.
You can find further information about haulage in the event of no deal in the Department for Transport guidance .
What does this mean for me and my business?
Without the EU giving the UK approved third country status there could not be any exports of animals and animal products. This is of great concern to the NFU as farmers rely on the meat supply chain, namely processors and cutting plants to export carcases, meat and meat products to the most appropriate market.
As a priority Defra must update all existing EHCs and ensure that official veterinarians and the exporting processing premises have the necessary authorisation on day one of exit. It is not acceptable to prioritise specific sectors, products or processing plant with highest volumes. Defra need to ensure that a systems based audit approach is adopted rather than approval through individual plant inspection. A concern for many exporting businesses will be to ensure they are approved to export to the EU and how this approval process will be managed.
To ensure compliance with EHC’s primary producers will need to continue to comply as they do now with traceability, safety and animal health and welfare regulation.
What is the NFU doing?
We continue to stress to government the need for the export certification and approval process to established in readiness for the end of March 2019. The aim must be to simplify approvals for processing/cutting/manufacturing plants, ensure new EHC’s are available and that there are enough trained and approved veterinarians or authorised signatories to approve the additional certificates required to export to the EU. Government must ensure that the infrastructure at UK and EU Border Inspection Posts is available to cope with the increase in documentary and physical checks. Current trade flows particularly through Dover – Calais route are not through existing BIP’s, therefore we continue to highlight to government our concern that there will be significant disruption and increased costs incurred by exporting businesses. Current locations of BIP’s in the UK and Europe could not cope with current trade flows.
We remain concerned that government has indicated that they would take steps to control the export of live farm animals for slaughter once we leave the EU. We believe that the live export of animals for slaughter, under strict control needs to remain part of the trading mix. Whilst the trade with Europe has moved towards carcases and cuts of meat the trade in live animals enables producers to maintain prices when domestic supplies are high.
Where can I find out more?
You can read the full technical notice here.
Read the NFU's comment on the publication of this notice.
More information on the NFU’s work on Brexit is available on the Brexit pages of NFUonline.
We understand that further guidance, training materials and updates will be issued to industry to support exporters in preparing to leave the EU.