What importers need to do to prepare for the rules and processes if the UK leaves the EU with no deal.
Rules from 12 April 2019: imports and control requirements
After the UK leaves the EU, you’ll still be able to import animals, animal products, food and feed whether from the EU or elsewhere. However, the process for notifying the UK authorities of these imports will change. Some import requirements from the EU to the UK may also change.
Use this guidance to understand what will and will not change if you’re importing to the UK:
- directly from third countries (non-EU member states or European Free Trade Agreement countries)
- from third countries and travelling through EU member states
- directly from EU member states
To import animals, animal products, high-risk food and feed to the UK, you’ll need to:
- make sure you know the import notification process for importing from non-EU and EU countries
- speak to your exporters from non-EU and EU countries to make sure they’re aware of the changes
- for live animals and germplasm coming from the EU, notify the Animal and Plant Health Agency (APHA) or the Department of Agriculture, Environment and Rural Affairs (DAERA) in Northern Ireland at least 24 hours in advance
- for live animals and germplasm coming from outside the EU, notify the UK border inspection post (BIP) that your consignment is arriving at least 24 hours in advance
- for products of animal origin (POAO) and animal byproducts (ABP) from the EU that travel on official documentation (an Intra Trade Animal Health Certificate (ITAHC) or commercial documents like DOCOMs), notify APHA at least 24 hours before arrival
- for germplasm, POAO and ABP subject to vet checks, notify the UK BIP (for non-EU trade) that your consignment is arriving in advance
- import non-EU high-risk food or feed of non-animal origin into the UK through a designated point of entry (DPE)
- comply with wider HMRC customs guidance on customs requirements for importing and consider whether you’ll need an import agent
New notification process for imports from non-EU countries and EU countries
If the UK leaves the EU without a deal on 12 April, you’ll no longer have access to the EU’s import system TRACES (Trade Control and Expert System) for importing into the UK.
To ensure imports of live animals, products of animal origin, animal byproducts, germplasm and high-risk food and feed not of animal origin can continue after exit, the UK is launching a new system called the Import of products, animals, food and feed system (IPAFFS).
The Department for Environment, Food and Rural Affairs (Defra) is releasing IPAFFS in phases.
From 12 April, you can use IPAFFS if you’re importing live animals, animal products and high-risk food and feed not of animal origin from non-EU countries.
You can register for IPAFFS now, and create notifications for consignments arriving after 12 April.
Find out more about how to use it in the IPAFFS user guidance.
From summer 2019 you’ll be able to use IPAFFS to notify authorities of high-risk food and feed, live animals, germplasm from the EU. Until then you’ll need to notify APHA using a different process.
Direct imports from outside the EU to the UK
If you import directly from outside the EU on 12 April changes will apply to requirements for notifications of the following:
- live animals
- POAO subject to veterinary checks
- high-risk food and feed not of non-animal origin
- ABP subject to veterinary checks
You’ll need to:
- use IPAFFS instead of the EU’s TRACES to notify imports
- import high-risk food or feed of non-animal origin into the UK through a DPE as you do currently - find out which DPE you need from the list of DPEs on the Food Standards Agency (FSA) website
- import live animals, germplasm, POAOs and ABP into the UK through a UK BIP (there is currently no BIP in Dover)
Health certificates and other documentation currently used for imports into the EU will be accepted for 6 months after the UK leaves the EU. After that, you’ll need to use a new UK health certificate.
Imports from outside the EU travelling via EU member states
If you’re importing POAO, germplasm and ABP not for human consumption that are subject to vet checks from non-EU countries but transiting through the EU to the UK, they’ll need to arrive in the UK through a BIP.
If you’re importing high risk food and feed from non-EU countries that will transit through the EU, they’ll need to arrive in the UK through a DPE.
Further guidance on transit goods for other commodities, such as live animals, will follow.
Direct imports from EU countries to the UK
Until IPAFFS is available in summer 2019, you’ll need to download a form from GOV.UK to notify authorities if you’re planning to import:
- live animals, germplasm or equines that need a health certificate (for example an ITAHC) or are travelling under official documentation (for example a DOCOM)
- animal byproducts travelling under official documentation
- animal products from EU countries with disease outbreak safeguards measures that need a health certificate
- equines travelling with a health attestation
- live animals that do not need a health certificate or official documentation but do have to be notified under Trade in Animals and Related Products regulations (TARP), for example insects, reptiles and amphibians
If you’re not sure what documents you need, check the import information notes on the APHA vet gateway.
You’ll also need to follow this process if you’re importing from Northern Ireland or the crown dependencies (Jersey, Guernsey and the Isle of Man) to the UK.
You’ll need to notify APHA at least 24 hours before your consignment is due to arrive in the UK. Notify APHA as early as you can, up to 30 days before. APHA will send you back a unique notification number.
If your consignment needs a health certificate, tell your official vet to put the number on the health certificate. Your exporter or official vet can download a health certificate.
If your consignment is travelling on official or commercial documentation, or a health attestation, you’ll need to add the number to the paperwork and email it to APHA.
If you’re importing to Northern Ireland, email scanned copies of the health certificates to DAERA on email@example.com as soon as they’re available.
APHA will check your health certificate or other documents against the notification form you sent. If there are any problems, they’ll get in touch with you to correct them.
ITAHCs will still be accepted for 6 months after the UK leaves the EU.
Importing food and feed from EU countries to the UK
You can continue your normal trade activities for importing feed and food from the EU from 12 April. There will be no additional controls or checks. You will not need to notify these on IPAFFS.
You’ll need to notify UK authorities about high-risk food and feed products from the EU from summer 2019. Further details on this will be provided in advance.
Products may be considered high risk if they contain, for example:
- contaminants - mycotoxins and aflatoxins
- excessive pesticide residues
- heavy metals, for example mercury
If you’re importing high-risk products from countries outside the EU you will need to notify authorities using IPAFFS.
You’ll need to make sure your consignment travels through a DPE. Find out which you need from the list of DPEs on the FSA website.
Find out more information on high-risk products, including the current list of products defined as high risk.
Importing animal byproducts not for human consumption (ABP) from EU countries to the UK
If you’re importing category 3 ABP from the EU, you can continue normal trade activities from 12 April. There will be no additional controls or checks. It’s likely that from 12 April you will not be permitted to import category 1 and 2 ABP from the EU.
Documents for transporters
From 12 April 2019, documents issued by the UK will only be valid in the UK and not in EU countries.
Read the Department for Transport’s guidance on preparing to drive in the EU after Brexit for more information.
If you’re a UK transporter who transports live animals in the EU you’ll need to appoint a representative within an EU country. You’ll need to apply to the relevant government department to get a:
- transporter authorisation
- certificate of competence
- vehicle approval certificate
- journey log (where necessary)
Checks at the UK border
An increased number of checks is expected as consignments will need to be checked at UK DPEs and BIPs. This includes high-risk food and feed not of animal origin which travel through the EU and do not go through EU import checks.
Those carrying out the UK import control checks will be fully trained to minimise disruption. IPAFFS will be used to plan and record controls at BIPs and DPEs with notifications enabling the necessary checks to take place.
How the UK government is working with interested parties
The government will continue to work with businesses to help them prepare for these changes. We have published guidance for users of IPAFFS. Guidance for imports from the EU will follow.
Other import requirements
You will have to apply customs, excise and VAT procedures to goods traded with the EU. You should:
- get an Economic Operator Register and Identification (EORI) number to be able to trade
- check for potential EU trade tariff changes
- find out the commodity code for your goods
- determine the value of your goods
- check if your goods are prohibited or restricted
- choose the correct customs procedure code (CPC) for your goods
- declare your import to customs - find out how in the guidance on importing from outside the EU
Find out more about HMRC customs requirements for imports to the UK in Preparing for a no deal EU Exit: step-by-step guide to importing.
If the UK leaves the EU without a deal, there will be no implementation period. In this scenario, the government will seek to bring into force UK-third country agreements from exit day, or as soon as possible afterwards.
These new agreements will replicate existing EU agreements as far as possible. Where replacement trade agreements are not agreed, trade would take place on World Trade Organization (WTO) terms with that country. Details of each agreement will be shared with parliament and the public when they have been agreed.
Read the guidance on existing free trade agreements if there’s no Brexit deal.