Dear subscriber,

Welcome to our latest FSAI Brexit Ezine.

Brexit makes the movement of goods to and from the UK (excluding Northern Ireland) more complex.

Imports of food are subject to controls to protect the safety and health of citizens, the health and welfare of animals, and the environment.

The type of import controls carried out depend on the food and include documentary checks, identity checks, and physical checks. Recent editions of our Brexit Ezine have focused on documentary checks and the requirement to notify the Border Control Post (BCP) in advance of the consignments arrival into Ireland.

This Ezine will focus on identity and physical checks and outline what is involved with both.

The Protocol on Ireland / Northern Ireland, means that no new procedures will apply to goods moving between Northern Ireland and Ireland (or the other Member States of the European Union) in either direction.

Some foods pose a higher risk to public health, animal health, or the environment in terms of diseases, pests, or contaminants. Specific requirements are in place to control these risks which include identity and physical checks.

The percentage of consignments requiring identity and physical checks depends on the type of product. These checks are carried out at the BCP by:

The Department of Agriculture, Food and the Marine (DAFM)
The Environment Health Service of the Health Service Executive (HSE)

Identity and physical checks

What is an identity check?

An identity check is a visual inspection to verify that the content and the labelling of a consignment, including the marks on animals, seals and means of transport, correspond to the information provided in the official certificates, official attestations and other documents accompanying it.

What is an physical check?

A physical check is a check on animals or goods and, as appropriate, checks on packaging, the means of transport, labelling and temperature, the sampling for analysis, testing or diagnosis and any other check necessary to verify compliance with food legislation.

How many consignments require identity and physical checks?

Foods of animal origin

100% of consignments are required to have an identity check
Physical check rate for most foods of animal origin is 15% or 30% (see below)

Composite products

100% of consignments subject to veterinary checks (see DAFM website for more details) are required to have an identity check
15% of consignments are required to have a physical check

Plants and plant products

100% of consignments of regulated plants and plant products are required to have an identity check and a physical check

Foods of non-animal origin

Certain foods of non-animal origin are required to have identity/physical checks. The frequency of checks is set out in Regulation 2019/1793

Food contact materials

10% of consignments of polyamide and melamine kitchenware from China and Hong Kong are given an identity/physical check

For all other foods and food contact materials, random identity and physical checks may be carried out on your consignments. You will be notified that your consignment has been chosen for a check. Consignments may also receive an identity or physical check on grounds of suspicion.

Rates of physical checks for foods of animal origin

Seal Check

If an official seal is applied to a container or other means of transport, a seal check alone may suffice for the identify check.

For seals to be used in an identity check, they must meet all of the following:

Consignment has been loaded in transport units which are closed and locked by a seal
Seals are intact and not tampered with
Seals were fixed by, or under the supervision of the competent authority issuing the official certificate e.g. veterinary inspector overseeing the place of dispatch
Information on the seal must correspond to that given in the accompanying official certificate

Mixed loads and groupage

Mixed loads and groupage are often used when transporting consignments from Great Britain.

Groupage refers to a load containing different types of products, which may be sourced from more than one supplier, destined to one or more importer, and which may require different import checks e.g. veterinary, plant health.

Mixed loads usually refers to a load containing a mix of products e.g. retail trucks with supplies for stores containing food, plants, stationery, clothes etc.

Mixed loads and groupage requiring more than one type of food control will take longer to process at import than loads requiring a single control.

Simplifying loads will minimise the number of food controls needed. The packing and location of products within a mixed load can add to the time it takes to carry our controls.

The FSAI eLearning module Brexit - Food Import Requirements outlines the types of checks that will be carried out on your food imports.

To move goods as efficiently as possible, it is important to:

Be familiar with the documentary requirements for your food imports
Notify HSE/DAFM within the required timeline
Talk to the key players in your supply chain as you rely on them for some of the import documentation e.g. health certificates for foods of animal origin
Consider the use of an official seal on your container/transport
Simplify loads to minimise the number of food controls needed. Groupage and mixed loads by their nature and complexity will be slower to process
Provide an email address which is constantly monitored, should further information on your goods be needed
Delays will occur if documents are missing, have incorrect information, or are not completed properly

FSAI Brexit Resources

Visit the FSAI's Brexit Resources page to find all our food business resources in one place.

Upcoming Brexit events

The UK's Department for the Environment, Food & Rural Affairs (DEFRA) are holding a series of webinars ‘Importing Products of Animal Origin (POAO) from the European Union into Great Britain' throughout February and March. These webinars are in advance of the changes coming about from 1 April 2021 if exporting foods of animal origin to Great Britain, as outlined in the Border operating Model.

Register for the DEFRA webinars at the links below:

10/02/2021 10:30-11:30 - Register here
15/02/2021 14:00-15:00 - Register here
22/02/2021 14:00-15:00 - Register here
01/03/2021 14:00-15:00 - Register here - focus on composites
08/03/2021 14:00-15:00 - Register here
15/03/2021 14:00-15:00 - Register here - focus on composites
22/03/2021 14:00-15:00 - Register here - focus on fish & fish products
29/03/2021 14:00-15:00 - Register here

Six Steps to Brexit Readiness

Now that the transition period has ended, all companies, big and small, moving goods to, from, or through the UK, excluding Northern Ireland will be affected. Further details are available in the government’s Brexit Readiness Action Plan.

Is your food business ready for post-Brexit trading?

Check the six steps at www.gov.ie/brexit to ensure you have made the necessary changes. If you have not, you need to take action today.

For up-to-date information on Brexit, visit our website at www.fsai.ie/Brexit or email Brexit@fsai.ie if you have any specific questions.

Look out for future FSAI Brexit Ezines.

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