Brexit - What We Know So Far on the Animal Health Regulation and Composite Products Update

Brexit - Animal Health Regulation and Composite Products Update

Changes to the EU's border controls on animals and germinal products came into place in April 2021. The EU has said that the changes are to streamline a number of legal acts. Essentially, there are new export health certificates (EHCs) that businesses will need to use when importing into the EU and Northern Ireland. To continue to trade within these regions, traders will have to learn and follow the new rules. 

In this article, we summarise the changes and how to determine which documentation you'll need when exporting into the EU.

Composite products and customs

A composite product is a food that contains both animal and plant products. Composite products are considered to come with a level of risk for an importing country. Animal and dairy products can contain pathogens that the country of destination is not used to, which is a cause for concern.

The new regulations are in place to better mitigate this risk. Animal and composite products are a broad group of foods. Some have a more significant risk than others. The new EHC's group these products into relevant subgroups and contain different levels of custom approvals.

Meat products, for example, require an EHC and are subject to Border Control Post (BCP) checks. In comparison, shelf-stable composite products containing processed dairy will only require a private attestation and BCP. If the product is in the lowest risk category, it won't need a BCP but still requires a private attestation document.

What has changed?

Previously, traders have had to acquire EHCs before exporting composite products into the EU. This is still the case; however, the range of composite products that require an EHC has changed.

Some products will now be exempt from requiring an EHC, and others that didn't require one before, now will. If a product is now exempt from an EHC, they may now need an attestation document, or they may not.

When do I need to make the changes?

The Department of Environment, Food and Rural Affairs (DEFRA) made the new composite EHC's available from 21st April 2021. There is a phasing period, though. If you export a composite product that currently requires an EHC, you can continue to use the same EHC until August 2021. If your product doesn't currently require an EHC but now does, you'll have to use the new composite EHC from April 2021.

The remaining composite products that don't require an EHC will need their private attestation documentation from the 21st of April 2021.

What are the new certificates?

All animal or composite products will fall into one of the five new EHC's or one private attestation documentation. There are three new products of animal origin EHC's which include wild game meat, farmed meat and mechanically separated pork.

The two new composite EHC's relate to either composite products entering the EU or transiting through the EU. Finally, a private assertion document is required for composites that are exempt from EHC's.

How will I know what certificates I need?

As a trader, you may have to distinguish which certifications you need for your products. DEFRA has created a decision tree to make this a bit more straightforward for you. You can access it by following this link, which also explains how to use the decision tree. Or, you can follow this link if you would like further guidance from DEFRA.

Final notes

With new regulations of exporting composite products into the EU as well as post-Brexit changes, trading currently can be confusing. WTA are export experts and can help simplify the process for you. Contact us if you would like any help.