Businesses now need to use the Animal Health Regulation (AHR) Export Health Certificates (EHCs) for goods exported from Great Britain (GB) to the EU or moved to Northern Ireland (NI) if an EHC is required.
EHCs used by Authorised Traders to move prohibited and restricted (P&R) goods to Northern Ireland are unaffected by these changes.
If you export certain animals, germinal products, products of animal origin, fishery products, live bivalve molluscs and composite products you will need to use the AHR EHCs.
The old EHCs were withdrawn from EHC Online on 14 January 2022, apart from some specific cases outlined below.
The old EHCs that have now been withdrawn are no longer available via the Certifier Dashboard in EHC Online. Any in-progress exports using the old EHCs will be valid for entry into the EU so long as the EHC was signed before 23:59 on 14 January, and the consignment arrives at the point of entry in the EU by 15 March 2022.
Businesses should consider timings and factor in how long it normally takes to get an EHC when exporting goods. Also, products exported on the AHR EHCs from 15 January 2022 may require changes to be made to Support Health Attestations (SHA) earlier than 15 January 2022, so they reflect conditions of the AHR EHCs.
Can I still use old EHCs?
The majority of the old EHCs were switched off on 14 January 2022. The EU has requested flexibility from Member States in accepting old EHCs until the end of April 2022.
The EU has not delayed the implementation of the AHR EHCs in law. New EHCs should be used wherever possible and it will be for individual Member States to decide whether they will continue to accept old certificates.
You should check with your BCP of entry before using an old EHC after 15 January 2022.
In what circumstances can I use old EHCs?
AHR dairy EHCs 8353, 8354, 8287 and 8356 for raw milk, raw milk products and dairy products are being updated and we expect them to be made available this week. EHC 8358 and 8280, for colostrum based products will also be made available.
The EHCs will be amended so there is no longer a requirement for animals providing the milk (or milk within the product) to have been resident in GB for three months prior to milking in the following circumstances:
- The animal has been imported into GB from an EU Member State;
- The animal has been imported into GB from another third country listed by the EU for the export of raw milk, colostrum or colostrum-based products and spent a combined total of three months in that third country and GB prior to milking.
However, the EHCs require the Official Veterinarian (OV) to select whether the animal providing the milk has been resident either in GB or imported into GB from an EU Member State or a relevant third country. OVs may therefore require supporting information from processors to confirm which attestation the product complies with. UKG are continuing discussions with the EU on this and will be engaging further with the sector directly.
In the meantime, you should consider using the old EHCs if you are unable to provide the relevant supporting information to your OV. You should confirm that the BCP of entry will accept the old EHCs before using them.
Poultry hatching eggs
The hatching eggs of poultry AHR EHC 8436 is being updated and will available soon. The EU is revising the EHC so there is no longer a requirement for an OV to inspect the flocks of origin 24 hours before loading for dispatch.
The revised certificate will allow for either a clinical inspection of the flock(s) of origin of the hatching eggs 72 hours prior to the time of loading, or monthly clinical inspections of the flock(s) of origin supported by an evaluation of the current health status based upon operator records by the certifying OV, 72 hours prior to loading.
As this EHCs will only be available for a short time prior to 15 January, the old hatching eggs EHC will remain available for now. Exporters should confirm that the BCP of entry will accept this old EHC before using it.
UKG are still in discussions with the EU on amendments to the residency requirements for germinal products therefore a small number old EHCs for bovine and ovine germinal products will be still be available to use until 30 April 2022. These include EHCs 8201, 8202, 8203, 8208, 8209, 8210, 8211 and 8212.
Exporters should confirm that the BCP of entry will accept the old EHCs before using them.
Poultry meat and meat preparations
The AHR EHCs for poultry meat and meat preparations require that birds do not pass within 10km of an Avian Influenza outbreak on route to slaughter. Due to the ongoing Avian Influenza (AI) outbreak, significant transport routes are within 10km of outbreaks. UKG are in discussions with the EU about this condition.
In the meantime, the old EHC, 8296, for poultry meat and the old EHCs for meat preparations, 8256 and 8257 will be available for use. Exporters should confirm that the BCP of entry will accept the old EHCs before using them.
Re-export of meat products
Traders will be unable to re-export certain EU origin products of animal origin (POAO) using the AHR EHCs. A new EHC for the re-export of POAO that is being imported from the EU and stored in GB without tampering or further processing has been created by the EU.
This new certificate does not cater for all types of re-export of EU POAO currently undertaken by GB traders and for certain meat products, the UKG is awaiting technical clarification from the EU as to whether the AHR EHCs can be used. For these products, the old EHCs will still be available to use until April 2022. This includes EHCs 8254 and 8255. Exporters should confirm that the BCP of entry will accept the old EHCs before using them.
Further AHR updates
Live animal EHCs
The EU has confirmed its intention to recognise GB as free of bluetongue in legislation. The live animal EHCs 8446, 8447, 8448, 8449 and 8452 for live cattle, sheep and goats, which were removed from EHC online, until this was resolved, will be made available again this week.
Private attestation – shelf-stable composite products
The EU has updated the private attestation for shelf-stable composite products containing no meat. The revised attestation now allows for products containing pasteurised dairy content originating in GB, the EU or another similarly listed third country to be exported. This replaces the interim arrangement that has facilitated this trade since April 2021. The updated private attestation has been published, so please ensure your EU importer is using the correct version.
First published 18 January 2021