Preparation for EU exporters

There are new processes coming in on both sides of the Channel as a result of these new rules. The moment the EU supplier’s goods move over the EU border – whether it’s heading to Northern Ireland or Britain – they will be required to provide additional certificates and documents, as set out in the Border Target Operating Model. If the goods are landing in Northern Ireland there will also be a mandatory full inspection.

From a UK importer perspective, you will need to ensure your EU supplier has an established point of contact with the animal or plant health department in their own country. For UK exporters this would be DEFRA or APHA, for example; EU countries will have their own equivalents which the EU suppliers will need to contact.

For products of animal origin, the EU supplier will also need to establish links with an official veterinarian (OV). The export health certificate must be obtained and approved by the OV. The OV will need to physically visit your premises to check and approve each pallet or item that’s being shipped, providing a physical certificate for each. There is a cost associated with that, and the GB importer and EU supplier would need to decide who that’s allocated to.

The physical certificate must physically accompany the goods as it will be stamped and signed. The electronic copies must be sent to the importer or their appointed representative.

There are similar problems and processes involved in getting phytosanitary or catch certificates for plants, fish and non-farmed fish.

The other thing the EU supplier will need to ensure is that they have the required certificates a minimum of 24 hours in advance of the goods crossing the border. They will need to lodge a pre-notification of the goods movement, with the accompanying certification, using a system called TRACES.

There is an issue at the moment because of the limited number of available OVs. The EU supplier will therefore need to ensure they’ve contacted an OV well in advance of the export.

If they leave it too late before the goods are due to move, they may not be able to book an appointment in time and their goods won’t be able to cross the border because they won’t have the required certification.


Planning the logistics of the export

You need to have a clear timeline and logistical plan in place for obtaining the documentation, and you also need to book your transportation and method of crossing – whether it’s by train or ferry, and what route the goods will travel by.

The key thing is to ensure you’ve got the necessary certification well in advance – whether that’s an export health certificate for animal-origin products, phytosanitary certificate for plants or catch certificate for fish.

The EU supplier will need to ensure they have obtained all the relevant documentation and uploaded these onto TRACES at least 24 hours before the crossing time – and they’re going to be very strict on these deadlines from 31 January.


Preparation for GB importers

The EU supplier will need to provide a digital copy of the export health, phytosanitary or catch certificate to the GB importer so that the GB business, or their customs broker, can lodge it with the IPAFFS system in the UK, 24 hours in advance of the goods movement.

The GB business or their broker will also need to lodge this in the Customs Declaration Service (CDS) as well, and they will be given a pre-authorisation number for the movement. This will be needed for the haulier when they’re creating a Goods Movement Reference (GMR) number in the Goods Vehicle Movement System  (GVMS).

As with the export requirements outside of the EU, this cannot be done last minute and you need to ensure you have a clear timescale and logistical plan for obtaining the documentation.

Within IPAFFS, a common health entry document (CHED) will be created and there are different types of CHED for different products – CHED P is the one predominantly used within most SPS movements, but there are other CHEDs for goods regulated by the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) and other high-risk or unusual goods. If your goods are chosen for inspection at the border, the agent will complete the CHED with the written result of the inspection.

This document will need to accompany the goods to the final destination and the importer will then need to close off the movement on the system by confirming that the goods have been delivered. This is done so that if an inspector from APHA or DEFRA wants to look at the goods after their arrival, they know where they’re going to be.

From this point, if they haven’t closed their CHED, or if they haven’t had their notification submitted in a timely manner, the importer won’t be able to continue to move the goods. HMRC and Border Force could then penalise the importer or even prohibit them from continuing to import SPS goods.


Which goods are categorised as needing inspection and will this affect where they can enter the UK?

Risk-based identity and physical checks will be introduced on medium-risk animal and plant goods from the EU, except from Ireland, from 30th April 2024. The inspections that need to be conducted will be determined by the risk assessments completed on the back of the documentation that’s uploaded, which is why there’s the 24-hour notice period via TRACES in the EU and IPAFFS in the UK, as this will give border force agencies the time to select which goods need to be inspected.

It’s vital, however, for importers to select the correct border control post (BCP) for the goods to enter the UK through, as not all BCPs will have the facilities to process the different types of SPS goods.

The government has provided an interactive map setting out which BCPs can process the different types of goods.


Who can help me comply with these new requirements?

A lot of suppliers and importers will have customs brokers who they can nominate to manage the customs processes for them, although they now charge additional costs for submitting pre-lodgements for the goods movements.

The EU supplier will nonetheless need to manage the process of obtaining the SPS certification (e.g. export health or phytosanitary certificates) themselves and then provide these to their broker so that they can pre-lodge the movement through TRACES (unless you’re collecting EXW).

Your customs intermediary in the UK will also support customs processes around the goods movements, but they will need to be provided with the SPS documentation in a timely manner to ensure they can lodge the pre-notifications with IPAFFS and get the pre-authorisation number to generate the GMR for the haulier.



The Procedure for Electronic Application for Certificates (PEACHES) will no longer be operational by the end of the month. IPAFFS is essentially replacing it, so it’s vital that importers and their brokers register to it as soon as possible.


What are the cost implications of the new regulations for EU suppliers and GB importers?

On average, the cost in Europe is generally around £38 for obtaining the certifying documentation – e.g. the export health certificate – and a certificate will be needed for each item or a pallet of items. There’s also additional administration costs if you’re using a broker to upload this onto TRACES in the EU and a broker for putting it onto IPAFFS in the UK.

The average overall additional cost for the new processes around medium-risk plant-based or animal-origin products is believed to be an additional £140 per shipment.