Exporting or moving high risk food and feed of non-animal origin to the EU or Northern Ireland

Last updated 8 September 2021

Some non-animal food and feed products from certain non-EU countries present risks to human health because of aflatoxins, pesticides, salmonella or dioxins. These high-risk food and feed of non-animal origin (HRFNAO) must meet more requirements to be imported to EU member states or moved into Northern Ireland (NI) than low risk food and feed products.

See the full list of HRFNAO with restrictions.

There is no HRFNAO listed in legislation 2019/1793 originating in the UK.

The rules apply to HRFNAO that you have imported from non-EU countries to GB (England, Scotland and Wales) and then re-export to the EU or move into NI.

Exporting HRFNAO from GB to the EU or moving it to NI

The EU does not recognise UK import controls as satisfying EU import requirements.

To export to the EU or move to NI HRFNAO in Annex 1 of regulation 2019/1793:

• you must include commercial shipping documents, such as the invoice, shipping document and bill of lading with the HRFNAO
• your EU or NI-based import agent must pre-notify the arrival of the consignment on TRACES NT

You must meet more requirements to export to the EU, or move to NI, HRFNAO listed in:

• Annex 2 of regulation 2019/1793
• Annex 1 of regulation 2020/1158 - HRFNAO following the Chernobyl power station accident
• Annex 2 of regulation 2019/1793 that are processed and repackaged into a new compound food - a final product that contains more than 20% high risk ingredients listed in Table 1 (for example, a cake that is made of more than 20% hazelnuts from Turkey)

For these HRFNAO you must:

• get an official certificate
• contact your local authority to arrange the sampling of the HRFNAO to be analysed at an approved laboratory - the lab will give the certifying officer the sampling results or an analytical report

These rules apply to the HRFNAO in Annex 1 of regulation 2020/1158 following the Chernobyl power station accident that either:

• originate from GB
• are imported to GB before being re-exported or moved to the EU or NI

If you’re moving the following categories of HRFNAO products from Great Britain to Northern Ireland you do not need to pay for official certification costs (including lab sampling costs):

• Annex 2 of regulation 2019/1793
• products originating from countries listed in Annex 1 of regulation 2020/1158

These costs are covered by the Movement Assistance Scheme.

Follow these steps to meet EU requirements to export these HRFNAO from Great Britain to the EU or move them to Northern Ireland.

Get an official certificate and laboratory analysis report

1. You complete part 1 of the:

   • official certificate for annex 2 HRFNAO and compound food - see annex 4 of 2019/1793
   • official certificate for a product subject to Chernobyl requirements - see annex 3 2020/1158

   You must complete the official certificate in English and the languages of the member state border control post and the final destination.

   Email the official certificate(s) to your local authority.

2. You contact your local authority to:

   • find a certifying officer who can sign your certificate
   • request a site visit

3. The certifier:

   • visits your site and samples the HRFNAO
   • sends samples to an official laboratory with a unique reference number (URN) that they give your consignment

4. The laboratory:

   • gets the samples and does the testing
   • gives results of the analytical report to the certifier

5. The certifier:

   • completes part 2 of the official certificate(s)
   • returns laboratory results, the report and the completed official certificate(s) to you

6. You send copies of the official certificate(s) and sampling results or analysis report to the EU import agent. The original official certificate(s) and sampling results or analysis report must travel with the goods.

7. The EU import agent uploads the copies onto the TRACES notification required for entry to the EU.

Send your HRFNAO to an EU border control post or NI point of entry

You must send your export to:

• an EU border control post (BCP) approved to accept your HRFNAO
• a designated point of entry in NI

Your EU or NI import agent must:

• pre-notify the BCP or point of entry of your goods on TRACES at least 24 hours before arrival
• fill in Part I of the Common Health Entry Document (CHED-D)

Your EU or NI import agent will upload to TRACES:

• the official certificate
• analysis report
• any commercial documents

Your consignment must arrive in the EU at the BCP or the point of entry in NI that used in the pre-notification.

At the BCP or point of entry, the consignment must have the:

• original official certificate
• laboratory analytical report

Points of entry in Northern Ireland can accept the original official certificate within 10 working days of the arrival of your consignment, so long as you have supplied the documents on TRACES. This is a temporary measure because of COVID-19 so you should check with the BCP or point of entry for their specific arrangements.

The BCP or point of entry will carry out checks, which may include:

• documentary checks
• ID checks
• physical checks (including sampling and analysis)

If the BCP or point of entry selects your consignment for sampling they will detain it until sample results are available.

Release of the consignment

The BCP or point of entry will record the checks on Part II of the CHED-D on TRACES.

If the checks are successful, the BCP or point of entry will release your consignment.

If your goods fail inspection at a BCP

If your HRFNAO fail inspection because of risks to animal or public health, they will be destroyed immediately.

If the goods fail for other reasons, the BCP will:

• notify your importer or NI-based agent
• ask your importer or NI-based agent to decide whether your goods should be destroyed or returned to GB

The BCP will not usually contact you directly.

Banned exports or movements of HRFNAO from GB to EU or NI

You will not be able to export to EU or or move NI products listed in regulations:

• 2016/6 (Fukushima)
• 2011/884/EU (Chinese Rice GMOs)

Arrangements for authorised traders moving food from GB to NI

An arrangement is in place which allows authorised traders such as supermarkets and their trusted suppliers to move some goods without the need for official certification.

If you’re an authorised trader moving HRFNAO from GB to NI, you do not need official certification, such as export health certificates, phytosanitary certificates or marketing standards certification.

You can no longer register for the authorised trader scheme.

The following conditions are attached to these arrangements:

• the goods are packaged for end consumers and they bear a label reading “These products from the United Kingdom may not be marketed outside NI”
• they are destined solely for sale to end consumers in supermarkets located in NI, and they cannot be sold to other operators of the food chain
• they are accompanied by a simplified official certificate globally stating the products meet all the import requirements of EU legislation
• they enter NI through a designated point of entry, where they are submitted to a systematic documentary check and to a risk-based identity check on a selection of items in the means of transport
• they are monitored through a channelling procedure applicable from the designated point of entry to the destination supermarket in NI

Exporting HRFNAO from Northern Ireland to the EU

HRFNAO moving between NI and the EU will not have to meet any notification, certification or sampling requirements. The EU will treat this as an intra-EU movement from an sanitary and phytosanitary perspective.