Sanitary and Phytosanitary (SPS) Import Controls
Animals and animal products post Brexit
This article gives an overview of measures surrounding the Importation of live animals or animal derived products, including fisheries products into the EU (Ireland) from third countries.
The measures apply to UK (Excluding NI) imports from 1st January 2021.
The Importation of animal and animal products is subject to EU regulations.
After the transition period, Imports of UK animal products and products containing animal derivatives will be subject to Veterinary/Sanitary checks in accordance with the relevant EU legislation. This does not apply to Northern Irish goods of Northern Irish Origin as a result of the revised Protocol on Northern Ireland***
These types of products will need to be presented at Border Control Posts
They will undergo an Import Controls Process which will have started once the Operator responsible for the consignment (RFC) has pre-notified the BCP of entry 24 hours in advance of the load arriving at the BCP. The RFC will also have submitted the documents to a DAFM Online portal (24 hrs in advance and in most cases an accompanying health certificate will be required –
The Department responsible for these checks is the DAFM – Department of Agriculture Food & the Marine.
NOTE: The Department for Agriculture Food and the Marine Recently issued the following update notice:
Information note on health certificates required for fresh or chilled meat preparations
Regulatory background
European Regulations identify meat preparations as “fresh meat, including meat that has been reduced to fragments, which has had foodstuffs, seasonings, or additives added to it which has undergone processes insufficient to modify the internal muscle fibre structure of the meat and thus to eliminate the characteristics of fresh meat”.
All products of animal origin must be accompanied by an EU health certificate. These EU health certificates are laid down in various EU legal Acts. Commission Decision 2000/572 specifically sets down the model health certificate which must accompany all meat preparations imported into the EU.
The certificate states that the meat preparation must be frozen, as set out in Article 3(3) of Commission Decision 2000/572 – “[meat preparations] have been frozen at an internal temperature of not more than -18 degrees Celsius at the production plant or plants of origin.”
EU Regulations do not provide for a certificate which would allow for the import of fresh or chilled meat preparations into the EU. There are no flexibilities in EU import rules on this issue, and there are no easements or flexibilities contained in the recent EU-UK Trade and Cooperation Agreement in relation to the import of these products.
Implications
Imports from Great Britain
In summary, meat preparations can only be imported into the EU with a valid certificate, which can only be issued if the product is frozen. Therefore, fresh or chilled meat preparations cannot be imported into the EU from Great Britain after 1 January 2021. These include products like uncooked turkey burgers, uncooked pork sausages, and uncooked seasoned T-bone steak that has more than 1% salt. Retailers should engage with their suppliers to establish whether the products being supplied to them are affected by these Regulations.
There is significant domestic production of these meat products, and engagement between retailers, processors and producers is encouraged in order to address any reduction in supplies of these products from Great Britain.
Exports to Great Britain
Import controls carried out in Great Britain on products of animal origin imported from the EU do not require a health certificate until 1 April 2021. The UK has not yet published its health certificates for 1 April, but has indicated that it intends to apply EU import controls on a reciprocal basis. If the UK does this then fresh or chilled meat preparations cannot be exported to Great Britain from the EU, including Ireland, after 1 April 2021.
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The establishment in the third country must be approved for exporting that category of animal product into the European Union.
This is important to ensure the product intended for export meets the standards required.
Importers should contact their UK suppliers to ensure:
- the supplier can meet EU requirements that their establishment, and any other establishments involved in production of the final product are EU approved.
- That the suppliers have access to a competent authority official Veterinarian or officer to complete the required certification at point of dispatch.
- that they have their products certified within the timeframes required
The list of approved exporters in the third country will be updated and available from TRACES – Trade Control and Expert System
The person who needs to register on DAFM is the person who is to be the Operator Responsible For the Consignment (RFC) This is the title given on TRACES to the person who will pre-notify the Border Control Post BCP, Submit the documents to DAFM, and be the first point of contact for staff at the BCP should there be issues with the documentation related to the consignment for which they are responsible.
The Operator RFC can be the importer themselves or an agent acting in their behalf, but they must be registered on TRACES for this activity type. DAFM initiate this registration which is one of the reasons the Operator RFC must come through DAFM first
Register at the email address below
brexitregistration@agriculture.gov.ie
Once the Operator RFC is registered they will be able to proceed and generate a Common Health Entry Document CHED for each consignment they are importing
This same person (RFC) will upload a copy of the CHED and supporting documents to DAFM online Portal 24 HOURS IN ADVANCE
Each RFC will receive Log in details once the portal is launched- to follow
There should be a set of documents for each consignment ( Health cert, CHED-P) and then supporting documents for the entire load including packing list and invoices. The BCP will also require the SAD number to be entered on the Portal for each consignment once it becomes available.
Under the Northern Ireland Protocol Annex to the Brexit Withdrawal agreement, there is to be NO Sanitary or Phytosanitary checks between Northern Ireland and the Republic of Ireland.
High food safety standards are one of the cornerstones of protecting the EU single market and it’s from potentially harmful and unsafe foods being imported.
Watch the European Commission video on EU food safety below
Notification
Pre-notification of imports of live animals and animal products must be submitted at least 24 hours before the consignment arrives in Ireland at the point of entry
Pre-notification is done by filling the relevant document in TRACES
The person importing the consignment must also submit the relevant health certificates and any other documents required under EU legislation to an electronic mailbox at the same time as the TRACES document is completed
It is important that all health certificates and other documents are submitted prior to the minimum notice period to prevent delays. Failure to submit the documents in time will result in the consignment being delayed until other imports have been cleared.
DAFM Guide to completing a new Common Health Entry Document.
Please note newer versions of this guide may become available from DAFM
Animal or Animal Products Check List 
- Register with DAFM if not already done so.
- Register on TRACES
- Check your UK supplier is approved on TRACES for exporting that particular product to the EU*
- Make sure your haulier is in possession of relevant authorisations
- Make sure your packaging is compliant
Composite Products- Contains both processed Products of Animal Origin and Plant Origin
Examples of Composite Products include
Chicken Salad Wraps, Pepperoni Pizza, Beef Lasagne, Chicken Curry with Vegetables.
Examples of Products not considered Composite Products include:
Tuna in Vegetable oil ( fisheries product)
Yogurt With Fruit ( Dairy Product of Animal Origin)
Chicken Nuggets with Breadcrumbs ( Product of Animal Origin – Meat)
A product is also not considered a composite product if it is A product is not a composite product if it contains any raw material of animal origin or if it is not intended for human consumption for example pet food.
For the full Guidance on importing Composite Products see the link to DAFM Web page here:
Non Animal Food Products
EU legislation provides for the routine control of feed and food of non-animal origin being imported into the EU. In addition, due to the increased risk associated with certain food and feed of non-animal origin from certain third countries.
Consignments of these products must undergo controls before their entry into free circulation is permitted.
In Ireland, the competent authorities for carrying out these controls are:
Department of Agriculture, Food and the Marine (DAFM)
& The Health Service Executive (HSE)
In order to obtain HSE Clearance of all third country consignments upon entry into the port, agents must submit all required documentation via email to importcontroldublin@hse.ie
These documents must be submitted before your arrival into the port. These documents are in addition to the ones submitted to Revenue, so submit them separately.
Documents for HSE checks include:
- SAD (Revenue Documentation)
- Commercial Invoice
- Bill of Lading
- Packing List
- Delivery Address
- Country of Origin of the products
It is essential that these documents are submitted via email. If we need more information we will be in contact. The HSE, Environmental Health Service is operating 24/7 and is completing document checks continuously.
Failure to submit the required documentation via email will result in the delay of vehicles and your consignments, until all appropriate documentation has been received by importcontroldublin@hse.ie
The HSE, Environmental Health Service check for food safety on foods of non-animal origin or food contact materials. If you require any help or assistance, please email importcontroldublin@hse.ie or telephone 01 9212851.
Further information on www.hse.ie/eng/services/list/1/environ/prepare-for-brexit/
Revenue’s Customs Service assists in the implementation of these controls by referring consignments of interest to DAFM or HSE, as appropriate.
Food imports of non-animal origin from third countries are risk assessed and inspected by Environmental Health Officers (EHOs) at Dublin port and Dublin airport, which are designated Border Inspection Posts.
See Revenues June 2020 manual here for further details.
imports-of-feed-and-food-of-non-animal-origin
Pallets and Wood Packaging Materials
Importers must ensure that Pallets, crates and other wood packaging are International Standard for Phytosanitary measure no.15 ISPM15 compliant.
ISPM 15 is an international Phytosanitary measure by the international plant protection convention (IPPC)
The measure sets down standards for treatment and marking of Wood Packaging Material (WPM) and effects all WPM in international trade including Pallets, Crates, and Dunnage .
The aim of ISPM15 is to prevent the spread of diseases and insects that could negatively impact countries plant health and ecosystems.
ISPM15 requires WPM to be:
- Either heat treated (HT) , Fumigated (MB) or heat treated using dialectic heating (DH)
- Officially marked with the ISPM 15 stamp consisting of 3 codes (Country, Producer & measure applied and the IPPC logo as above.
These requirements do not apply to
- Wood of 6mm thickness or less.
- WPM made entirely from processed wood using glue, heat and pressure for example plywood, oriented strand board and veneer.
- The vast majority of intra-EU trade
SPS Controls- Plant & Plant Products
The competent authority in Ireland for control of plant and plant products is DAFM.
Watch the latest Webinar on Importing Plants and Plant Products from the UK post Brexit from DAFM here:
The Department of Agriculture, Food & the Marine regulates the movement of plants and plant products into and within the European Community for the island of Ireland. This involves checks at the border of plants and plant products being imported into Ireland and export certification of Irish grown produce.
for operators in this trade, a helpful page from Department of Agriculture food and the marine can be found here:
Plant health and Brexit
A new EU Plant Health Regulation(Regulation(EU)2016/2031) came into operation on 14th of December 2019. The objectives of the new Regulation are:
- Better protection of EU Plant Health,
- More focus on proactive action,
- Compliance with international plant health standards (International Plant Protection Convention (IPPC).
The new Regulation focuses on reducing the risk of introducing quarantine pests to the EU as follows:
- focusing attention on high risk plants,
- developing a list of EU priority pests,
- expanding the range of plant operators to be registered with the competent authority,
- applying stricter Protected Zone requirements, and
- requiring all plants for planting to be accompanied with a Plant Passport.
Under the New Regulation plant health will, for the first time, be subject to the Officail Controls Regualation (Regulation(EU)2017/625) .
This introduces the possibility for co-funding of the annual surveys for priority pests and also the possibility to contribute to the destruction costs for eradication control measures of a Quarantine Pest.
Importers of plant and plant products must register with the DAFM horticulture and plant health division
plantandpests@agriculture.gov.ie;
These products will be subject to Phytosanitary checks.
Pre-notification of arrival must be made 24 hours prior to arrival.
Relevant plant health certificates must also accompany the consignment.
Application for Plant Health Importation Licence:
Only Registered Importers may apply to bring plant and plant produce into Ireland from a Third Country. Applications must
be made on a completed Plant Import Request Form.
Completed application forms must be submitted a minimum of 72 hours prior to the arrival of the consignment into Ireland by:
Email: plantimports@agriculture.gov.ie
By post:
Plant Health Section, Department of Agriculture, Food and the Marine,
2nd Floor Administration Building,
Backweston Campus,
Celbridge,
Co. Kildare.
Failure to complete and return the form to the above address may result in a delay in the granting of an Importation Licence.
Since December 2019 all plants for planting require a plant passport when moving from professional operator to professional operator.
Plant Passports are not required for plants or plant products which are supplied direct to end users.
SEE the Full document here: 1PlantPassport021219
Xylella fastidiosa Restrictions-
Watch the European Commission Video below
For further information on animals and animal products please consult the Department of Agriculture Food and the Marine
And the Food Safety Authority of Ireland
Please note this article and it’s content has been created as an aid to preparing for Brexit and/or international trade. It is not intended to be construed as official, legal or advice of any kind. Operators should always check with their local customs Authority for legal or any other obligations under international Trade.
