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Export Health Certificates (EHC) for exporting foods to Great Britain

Food Business Operator (FBO) Obligations when requesting Export Health Certificates (EHC) for exporting foods to Great Britain (GB)

Since the UK introduced specific import requirements from Jan 31st 2024, it is possible that the foods you export to Great Britain (GB) will require an export health certificate (EHC). This is a new UK import requirement under the UK Border Target Operating Model (BTOM), and it is the obligation of all food business operators (FBOs) to familiarise themselves with all of the requirements before exporting food to GB.  To help your food business meet its obligations when exporting foods to GB you may need the officer from the supervising agency that performs food inspections in your food business to provide you with an export health certificate (EHC). In some cases, depending on the EHC requirements it may be necessary for your food business to transfer to the supervision of a different supervising agency, therefore it is advised that you contact your current food inspector to discuss the possible impact of the UK import requirements as soon as possible.

The FSAI has published helpful information for all FBOs on the GB import requirements on its website but in summary, all FBOs need to familiarise themselves with the need for:

Some other key specific advice and obligations for FBOs to be aware of when exporting food to GB are highlighted below.

 

Export of High-Risk Foods of Non Animal Origin (HRFNAO) from IE to GB:

Some foods of non-animal origin are classified as a high-risk food of non-animal origin (HRFNAO) because they pose health risks associated with the country of origin. A HRFNAO is a food which contains for example contaminants such as mycotoxins (aflatoxins), pesticides, salmonella, pentachlorophenol, or dioxins.

Regulation (EU) 2019/1793 as amended covers the temporary increase of official controls and emergency measures governing the entry into the European Union of certain goods from certain third countries. There are 2 Annexes to this legislation that cover the list of specific foods as follows:

Annex I: lists food and feed of non-animal origin from certain third countries subject to a temporary increase of official controls at border control posts (BCPs) and control points.

Annex II: lists food and feed from certain third countries subject to special conditions (e.g. the requirement to provide an official certificate and results of laboratory analysis, prior to their entry into the European Union.

With the UK leaving the EU, a divergence in legislation has occurred with the UK Retained EU Regulation 2019/1793 which means that there is difference between the GB list of products and the EU list of products that are subject to temporary increased controls and emergency measures.  This in turn means that some of the specific goods listed will be subject to controls at BCPs in IE/EU but they may not be subject to these controls in GB and vice versa.

An EHC may need to be issued by your supervising agency here in IE prior to export HRFNAO to GB.

Where HRFNAO is transiting through the EU/IE destined for GB, Third country certificates presented on import into EU/IE may only be used by an FBO for export to GB and must be in date (i.e. no longer than four months from the date of issue, and no longer than six months from the date of the results of the laboratory analyses conducted). 

FBOs wishing to export these commodities should familiarise themselves with the requirements for certification to the UK and contact and discuss this with their supervising agency without delay.

 

Hauliers and Transport/Distribution FBOs:

The transportation model for foods being exported to GB is complex and can change within a short timeframe.

It is vital that all FBOs involved in food distribution to the GB consider their current model, and should any changes be made to this distribution model, the obligation rests with you as FBO to familiarise themselves with the requirements for certification to the UK and to contact your supervising agency as soon as possible, where export certification may be required going forward.

 

Composite Products:

A ‘composite product’ means food containing both products of plant origin and processed products of animal origin.

Currently composite products have been categorised in the BTOM as low risk, therefore only requiring pre-notification on IPAFFs.

However, it is essential that FBOs who currently export any composite products, keeps a check for any changes to the current categorisation which could affect the need for EHCs.

 

All Food Business Operators are obliged to check for changes with requirements to export to GB and should any trade models or commodities being exported change, you need to discuss with your supervising agency without delay.