We are now in the final countdown to UK border controls. From July food imports will require full paperwork and lorries will be stopped to check consignments. To avoid congestion and disruption to your supply chains it is important your EU suppliers are as prepared as possible. Here is a summary of what we know about border changes and some of the issues yet to be resolved to help those conversations and don’t forget the best way to get the latest insight is to join our Brexit Working Group, contact Hannah.firstname.lastname@example.org to make sure your company is connected.
What we know
- Beginning on 1/7/22 Export Health Certificates (EHCs) will be required for all products of animal origin (POAO) signed by a vet in the exporting country. These will be introduced over the Autumn beginning with EHCs for fresh meat in July, from September for all dairy products and November for all remaining POAO including composite products.
- From 1/7/22 all regulated plants, including most fresh fruit and vegetables will require a phytosanitary certificate issued by the relevant plant health authority in the exporting country
- All food imports will need to be pre-notified to the UK through the import IT system IPAFFS. This has been the case since January but IPAFFS will be more complicated and require more information.
- From 1/7/22 food consignments will need to arrive through a border control post (BCP) able to check it eg fish, meat, fruit and vegetables
- From 1/7/22 BCPs will begin stopping vehicles to make physical checks. Importers will be advised in advance and it will be rolled out in line with EHCs ie meat from 1/7, composites from 1/11.
- UK is adopting similar risk assessment to stop lorries for physical checks as the EU. This basically means approximately 1% of basic fruit and vegetable loads and for POAO between 1 and 15% depending on product.
What we don’t know
- How well prepared EU Member States are to support export certification on a 24/7 basis. We understand key countries including Holland, Belgium and Germany have sufficient vets and processes in place to do this but there is uncertainty across other EU countries
- Which BCPs will handle different food imports, we expect designation in March
- What the pre-notification period will be. We expect it to be 4 hours as it has been since January but it is yet to be confirmed
- What happens to imports from the Republic of Ireland. These are not currently subject to the basic controls introduced in January due to a lack of readiness at the Welsh ports. We expect them to be the same as other EU countries but yet to be confirmed.
- How well the new processes including inland lorry parks to administer physical checks will work. We are told the infrastructure is ready but we will only know how these and the IT systems cope once full import volumes occur.
- How pragmatic the UK port authorities will be to manage disruption. We expect the UK to take a less bureaucratic approach than the EU to genuine small mistakes in certification but unsure if that would extend to a reduction in stopping lorries for physical checks if there is disruption
- How well prepared importers in general are. Your suppliers may be prepared and ready to go but still suffer delays from disruption regardless due to problems with other importers.