Food of non-animal origin

Food imports of non-animal origin from third countries are subject to import requirements which include registering as an importer and submitting import documentation. Consignments are risk assessed and inspected by Environmental Health Officers (EHOs). Some consignments may be randomly chosen for identity/physical checks.

All imports of food of non-animal origin need a customs declaration and commercial documents relevant to the consignment. Foods with temporary increased controls or emergency measures have additional requirements.

A summary of the legislative framework for official controls on Products of Non-Animal Origin is outlined below:

•  Official controls on products of non-animal origin summary
•  Collated list of Border Control Posts for products of non-animal origin

Importing Food of non-animal origin

What are the requirements for importing food of non-animal origin?

• Notify the Environmental Health Service of the Health Service Executive

  To import food of non-animal origin, you need to notify your food business to the Environmental Health Service of the Health Service Executive. You can do this online on the HSE website. You can also use this online system to make changes to your notification.

  Some foods of non-animal origin have specific import requirements. These foods must enter Ireland through a Border Control Post and

  • most are subject to registration on TRACES NT (an EU online platform used when importing or exporting certain products including food of animal origin and certain food of non-animal origin),
  • must pre-notify their arrival, and
  • require additional import documentation.

• Temporary increased controls

  There are temporary increased controls for some foods of non-animal origin from certain third countries. This is due to a known or emerging risk, or because of widespread non-compliance with food law. 

  Annex I of Regulation 2019/1793 lists the food of non-animal origin subject to a temporary increase of controls at border control posts. This list is reviewed by the Commission at least twice a year.

  For more information on this issue, see the European Commission's Notice on information related to risks and non-compliance in the context of the periodic reviews of Commission Implementing Regulation (EU) 2019/1793. This Notice provides increased transparency on the relevant criteria and considerations.

  For food that has specific import requirements, the person responsible for the load must complete a Common Health Entry Document (CHED-D) through TRACES NT in advance of the arrival into Ireland of the consignment. A model for CHED-D is in Annex II to Commission Implementing Regulation (EU) 2019/1715.

• Additional requirements

  • Prior notification of 24 hours is required for foods subject to increased controls
  • Foods must be presented at a Border Control Post (BCP). 

  The increased control mechanism means that competent authorities will:

  • carry out checks on all the documents accompanying the consignments
  • conduct identity and physical checks, including laboratory analysis, at a frequency set down in the legislation for the specific commodity being imported

• Emergency measures

  Emergency measures are in place for a range of food commodities coming into the EU where a food is likely to pose a serious risk to human health, animal health or the environment.

  Annex II of Regulation 2019/1793 lists the foods from certain countries subject to special conditions for entry into the EU due to contamination risk by, for example mycotoxins including aflatoxins, pesticide residues, chemical, microbiological and other contamination, e.g. unauthorised dyes, additives. This list is reviewed by the Commission at least twice a year.
  
  In addition, there are a number of emergency measures under other legislation with import conditions that are specific to each measure:

  • GM rice from China
  • Food from certain countries post Chernobyl
  • Sprouts and seeds for sprouting from 3rd countries

• For foods with emergency measures you must have:

  • Common Health Entry Document (CHED-D). A model for CHED-D is in Annex II to Commission Implementing Regulation (EU) 2019/1715
  • Health certificate
  • Certificate of analysis (CoA)

  Get more information on temporary increased controls and emergency measures

• Checks

  Document check

  Document checks can be carried out, and the products cleared before the food products arrive at the point of import into Ireland. To avoid delays it is essential that all necessary import documents are complete, accurate and submitted within the notification timelines.

  Identity check

  This a visual inspection to ensure that certificates or other documents accompanying the food consignment match the labelling and the content of the consignment.

  Physical check

  A physical check is a check on food which may include checks on:

  • the means of transport
  • packaging
  • labelling
  • temperature

  Sampling for analysis and laboratory testing may be done and any other check necessary to verify compliance with food law.