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If the UK leaves the EU without a deal on 29 March 2019, you will need to adapt your business to comply with new systems, processes and controls, but the government will take steps to smooth the transition.
Importing direct from the EU
Currently, live animals and some very specific animal products brought into the UK direct from the EU (such as germplasm) require the exporter to provide either an Export Health Certificate (EHC) or, more generally, an EU-specific version of an EHC, known as an Intra-Trade Animal Health Certificate (ITAHC).
For all other animal products imported direct from the EU, no certification is required and no specific processes need to be followed. This is also the case for high-risk food and feed not of animal origin (FNAO).
There are additional requirements when transporting live vertebrate animals for commercial or economic activity. For all journeys, the transporter must hold a valid Transporter Authorisation and drivers and attendants must hold a Certificate of Competence.
For journeys over 8 hours within the EU, vehicles must also have a valid vehicle approval certificate.
Transporter Authorisations, Certificates of Competence and Vehicle Approval Certificates must be issued by an EU country. For journeys over 8 hours, where farm livestock and unregistered horses will be transported, the transporter must also hold a Journey Log.
How processes will change if you import direct from the EU
If the UK leaves the EU without a deal, the government will ensure a smooth transition by making no changes on day one to current import controls or notification requirements for live animals, products of animal origin (POAO) and high-risk food and feed not of animal origin imported direct from the EU.
The EU system for import notifications of live animals and high-risk food and feed (both POAO and FNAO) – Trade Control and Expert System (TRACES) – will be replaced by a new UK system. This system will be available for early testing in January 2019 and will be fully operational for all users from the day the UK leaves the EU.
It has been developed to replicate TRACES functionality and representatives from key user groups are involved in the design, testing and preparation of the system. Guidance and training material will be available ahead of March 2019.
To maintain high levels of food safety, the UK will require importers to pre-notify the Food Standards Agency (FSA) of imports of high-risk food and feed from the EU (in practice this will only be POAO as the EU determines what is high-risk FNAO, and this is non-EU in origin).
The Department for Environment, Food and Rural Affairs (Defra) and the FSA are working to establish when such a requirement could be satisfactorily introduced. More information will be released later.
This pre-notification requirement will have no direct impact at the border. If you’re introducing high-risk foods into the UK, you will make pre-notifications electronically in advance – and this would be managed by the FSA. No additional controls will be introduced at the border.
For an interim period, for importing live animals, the UK will continue to recognise Transporter Authorisations, Certificates of Competence, Vehicle Approval Certificates and Journey Logs issued by EU countries. UK-issued documents would only be valid for use in the UK and not in any EU country.
If you’re a UK transporter wishing to transport live animals in the EU, you will need to appoint a representative within an EU country and apply to their relevant government department to obtain a valid Transporter Authorisation, Certificate of Competence, Vehicle Approval Certificate and, where necessary, a Journey Log.
Importing from outside the EU
Currently, imports of live animals and high-risk food and feed (both POAO and FNAO) are notified to the UK using the EU’s Trade Control and Expert System (TRACES). Health certificates are required for live animals, POAO and specific FNAO products.
Veterinary and public health checks are carried out at specific approved facilities at air and sea ports on entry to the UK. For live animals and POAO these will be at a Border Inspection Post (BIP), and for high-risk FNAO checks will be undertaken at a Designated Point of Entry (DPE).
Goods originating in countries outside the EU, destined for the UK, which enter the EU to transit onwards to the UK, are normally checked at the first point of entry into the EU. Once they have been checked in the EU they are free to be placed on the market anywhere within the EU, and are not subject to additional controls when entering the UK.
How processes will change if you import from outside the EU
If the UK leaves the EU without a deal, there will be no change to current import controls and requirements for notifications of live animals, products of animal origin, and high-risk food and feed not of animal origin imported directly from outside the EU.
The only difference is that importers would need to use a new UK import notification system, rather than TRACES. This system will be available for early testing in January 2019 and will be fully operational for all users from the day the UK leaves the EU.
This system has been developed to replicate TRACES functionality and representatives from key user groups are involved in the design, testing and preparation of the system. Guidance and training material will be available ahead of March 2019.
Changes will apply to control requirements for imports of third country live animals and animal products which move through the EU before arrival in the UK:
The requirement for live animal imports from a third country, which move through the EU before arrival in the UK, to enter via a UK BIP is being reviewed, as all live animals would have been subject to checks at the point of entry to the EU. You will still be required as an importer to notify the UK authorities using the new import notification system.
Animal products (POAO) and high-risk food and feed not of animal origin
You will need to notify UK authorities using the new import notification system. Additionally, POAO, which will have transited the EU under seal, and which would have been subject to EU imports controls, will be directed to an existing UK BIP, where the relevant checks would take place. These requirements will ensure the current levels of biosecurity and public health are maintained.
The need to undertake checks at UK BIPs for consignments of POAO that have transited the EU where they have not been subject to checks, will lead to an increase in the number of UK checks undertaken at BIPS. Those carrying out the checks at the BIP will receive notifications on the new import notification system to support checks and controls, and they will be fully trained to minimise the impact at the border and reduce the chance of delays.
Actions you can take now
- Read the government’s existing guidance for importing outside of the EU, to familiarise yourself with the key processes. On GOV.UK, search for ‘Starting to import’ and then select ‘Importing from non-EU countries’.
- Take account of the volume of your trade with the EU and any potential supply chain impacts.
- Consider the impact on your role in supply chains with EU partners. In a ‘no deal’ scenario, trade with the EU will be on non-preferential, World Trade Organization terms. This means that Most Favoured Nation tariffs and non-preferential rules of origin will apply to consignments between the UK and EU.
- If necessary, put steps in place to renegotiate commercial terms to reflect any changes in customs and excise procedures, any additional requirements for checks (for example, for imports of agrifood) and any new tariffs that may apply to UK-EU trade.
- Consider how you will submit customs declarations for EU trade, if required, including whether to engage a customs broker, freight forwarder or logistics provider or whether to get the right software and authorisations to do it yourself.
- Consider how you will meet other requirements for imports (for example, of agrifood), such as pre-notifications to the relevant government agency in advance of arrival at the border. This may include the requirement to register on an IT system. You may also wish to consider whether to engage an agent or whether to do it yourself. You can find out more information in the government’s EU Exit technical notices or by contacting the relevant agency or department.
- The passport rules for travel to most countries in Europe will change if the UK leaves the EU on 29 March 2019 without a deal. Read the government’s guidance on Travelling to the EU with a UK passport if there’s no Brexit deal and, if relevant, ensure your employees and customers are aware of the potential changes.
- Stay up-to-date with these changes by registering for email alerts. Follow the link, add your email address, select ‘submit’, select ‘Add subscription’ and choose ‘EU Exit’ then select ‘Submit’.