FAQ
Frequently Asked Questions
• DAFM - Dept of Agriculture, Food and the Marine (IE)
• DEFRA - Dept of Environment, Food and Rural Affairs (UK)
• CHED - Common Health Entry Document
• TRACES - Trade Control and Expert System (EU)
• IPAFFS - Import of products, animals, food and feed system (UK)
• EHCs - Export Health Certificates (EU)
• EHCO - Export Health Certificate Online (UK)
• POAO - Product of Animal Origin
• FBO - Food Business Operator
• EORI - Economic Operators Registration and Identification (EU and UK)
• SAD - Single Administrative Document
• ROS - Revenue Online System (IE)
• CHIEF - Customs Handling of Import and Export Freight (UK)
• AIS - Automated Import System (EU)
• NCTS - New Computerised Transit System
• GVMS - Goods Vehicle Movement System
• MRN - Movement Reference Numbers
• TAD - Transit Accompanying Document
1. Completed appropriate registrations to allow company to trade with the UK?
- Register as an Economic Operator - EORI - with Revenue
- Register with DAFM - Corporate Customer System (CCS) - person responsible for declarations
- Register with Traces - EU Trade Control and Expert System (TRACES) - platform for electronic completion of documentation required for imports from third countries
- Register for IPAFFS (UK) - system for the import of live animals, animal products and high risk food and feed not of animal origin into Great Britain (Deferred)
2. Establish customs commodity (HTS) codes for all products?
- Required for customs documentation on goods shipping to, from or through GB
- Available for look-up on EU Taric database
3. Confirm with customers responsibility for Export and Import customs processes?
- Usually governed by three letter codes in contracts, known as Incoterms. Examples would include EXW (Ex-works) or DDP (Delivery Duty Paid)
- Export clearance responsibility is usually with the seller with exception of EXW terms where the seller is still responsible to provide documentation to facilitate Export
- Import clearance responsibility is usually with buyer unless DDP terms. If DDP terms to GB, may require GB EORI number and Importer of Record in UK.
4. Confirm ability to generate commercial invoices for all shipments to, from or through GB?
- 16 fields of information required on the invoice
- Can use combination of commercial invoice, pro-forma invoice and packing list
5. Nominate a knowledgeable 3PL / Customs agent to manage physical product flows and customs process?
- Can manage customs flows internally but would need training and experience
- Have 3PL confirm their readiness - registration of UK EORI, access to customs apps and documentation and sufficient resources
- Confirm pricing for customs agent and clearance services
- Put in place direct representation to allow them act as customs agent.
- Agree on the information required and timing relative to shipments
6. Manage compliance on broker declarations
- Broker is responsible for making declarations as part of customs process
- Company remains accountable for declarations made on their behalf
- Suggest regular audit of declarations ahead of inspection from Revenue or HMRC
There are additional requirements, particularly for larger producers and those with complex supply chain flows – clarifying product origin, customs warehousing, the application of special customs procedures, known consignor and known consignee programs and the ability to register with customs as known traders under an Authorised Economic Operator (AEO) certification.
Support is available for Bord Bia client companies if you are unsure about the customs and trade requirements of doing business with the UK.
As part of the UK establishing its own regulations around products placed on the UK market, changes are required to food product labels from 31st December 2023.
Importer Address
From 1st Jan 2024 any pre-packaged food or caseins imported or sold on the UK market will need to have on the label:
• the address in the UK of the business whose name the food is marketed under, or
• the address in the UK of the business that has imported the food
This is to provide UK market surveillance authorities a local contact within the UK for any food products placed on the market.
• A PO Box, email address or phone number is not sufficient for this purpose.
Business to Business shipments may need to include the UK address on boxes or commercial documents if the products are not being sold pre packed.
For imported products, the name/address of the business on the food label is the entity who takes legal responsibility for the information on the product label in the UK market.
You may include additional information on labels (means you can meet both EU and UK requirements on a single label)
This role comes with responsibilities including (but not limited to):
• Holding the technical file for the product, and being able to produce the file immediately if it is requested by a market surveillance authority
• Being the first point of contact for authorities if there is any query or issue with a product
• Co-ordinating any product recall if required.
Options for Irish Food Producers
There are several options available to Irish food producers. The best option for any food producer will depend on individual circumstances. The available options are:
1. Use your own business entity in the UK
• May be a viable option if you already have a physical office or presence in the UK
• Consider costs and potential tax implications of setting up and maintaining entity
2. Use your distributor / importer’s address
• Need to confirm that they are happy to take on this responsibility
• Need to provide them with access to technical files to support each product
• Need clarity on legal responsibilities and costs
3. Use the services of a Third Party Authorised representative
• Professional companies provide this as a service for a fee
• Typical fees include set up (by product / product group) and ongoing service fees
• Need to have food and drink experience
• Register as an FBO on behalf of the manufacturer
For more information on the labelling address requirements please see the below link.
Country of Origin Labelling
There are specific food origin labelling requirements for:
• Beef, veal, lamb, mutton, pork, goat and poultry including minced meat)
• Fish and shellfish
• Honeys
• Olive oil
• Wine
• Fruit and vegetables
• Eggs
Need to have country of origin on other prepacked products only if the consumer could be misled by the packaging / description – for example ‘Danish Butter Cookies’ if the product was not from Denmark, picture of Eiffel Tower but product is not from France.
If the product says “Made/Produced in one place, but the primary ingredient is from a different place – this must be state clearly. (i.e. Made in Ireland using UK and Non-UK pork)
Specific country of origin labelling requirements by product are also updated from 31st December 2023 set out in the guidance in the link below.
• https://www.gov.uk/guidance/food-labelling-country-of-origin
• https://www.gov.uk/food-labelling-and-packaging/food-labelling-what-you-must-show
A simplified view of this guidance is a requirement to ensure updates to origin references to reflect that UK is no longer part of EU. E.g., ‘EU / Non-EU’ to references may need to change to ‘UK / Non-UK’.
- ● High risk: live animals, live aquatic animals and germinal products (with published exceptions for animals with additional safeguards or assurances or which present a lower risk) and commodities covered under safeguard measures.
- ● Medium risk: raw, chilled, frozen meat, meat products, dairy, animal by-products for use in animal feed, fishery products and aquatic animals imported as products of animal origin.
- ● Low risk: processed, shelf-stable products such as composites and certain canned meat products, processed animal by-products and certain fishery products and aquatic animal products from lower risk countries.
There are three parts to the CHED form:
- ● The Economic Operator Responsible for the Consignment (Registered) in the EU notifies the arrival of the consignment by completing Part 1 of the common health entry document (CHED) to be submitted to the BCP on entry to EU
- ● The Border Control Post (BCP)of entry into the Eu processes Part 2of the CHED. If required a RASFF of Interception notification is submitted (RASFF –the Rapid Alert System for Food and Feed)
- ● The Competent Authority of the final destination records in part 3 of CHED the checks performed at destination, confirming arrival of consignment or the measures taken on the basis of the Authorities decision.
- Different CHEDs apply based on Consignment type:
-
- CHED-A for live animals
- CHED-P for POAO, animal by products, germinal products, composite products, hay & straw
- CHED-PP –plants, plant products & other objects
- CHED–D consignments of food & feed of non-animal origin
Critical Points in Completion Of CHED
- ● Complete Transport Operator & Approval Number details
- ● Most consignments of Food/Feed of animal origin will only require input in the ‘Conforms to EU Requirements’ and ‘For Internal Market’ areas.
- ● Select “Conforms or Non-Conforming” results in channelling prior to release
- When the Purpose tab has been completed, all the Consignment details (References, Traders, Commodity, Purpose) should now be entered.
- ● The last step in the process, is to Submit for Certification, Sign
- ● The user will then be presented with the CHED number for this consignment.
- ● Print off copies and ensure one printed copy accompanies consignment
NB: If you are bringing in similar products you can save the Completed CHED as a Template use Copy as New Function then TRACES will issue a new CHED number.
- Enter Attached Document/Authorisation unique numbers carefully.
- ● Delivery address: place to where the product is to be taken for final unloading.
- ● Means of transport: this is the means of transport upon arrival at the BCP.
- ● Document: The airway bill number, the vessel and bill of lading number or registration number and trailer number of the road vehicle.
- ● Seal Number: The number of the seal applied on leaving the place of loading in the Third Country.
- ● Country of Origin: this refers to where the final product was produced, manufactured, or packaged
- ● Country from where consigned: This refers to the country from where the consignment was placed aboard the means of final transport for the journey to the EU.
What Do I Need to Include on The CHED
- 1) Contact details of Operator Responsible for the consignment (RFC)
- 2) Date and time of arrival of consignment
- 3) Country of dispatch & Entry Point on arrival
- 4) CHED-PP (Common Health Entry Document for Plants, Plant Products and Plant propagating material) number
- 5) Plant Health Registration (PHR) number of the Importer
- 6) Copy of the Original Phytosanitary Certificate (colour scan of original) with appropriate additional declarations
- 7) Copy of the Invoice & Copy of the Airway bill
- 8) Copy of Customs SAD (Single Administrative Document) & SAD Number
The Accredited Trusted Trader scheme being piloted would allow frequent importers of products of animal origin and animal by-products to potentially reduce the need for routine physical checks at the Border Control Posts by taking responsibility for carrying out routine checks and sampling to ensure the protection of biosecurity, animal and public health whilst being closely regulated by government. Pilots will be used to establish the final membership criteria but as a minimum.
Accredited Trusted Trader Scheme members will:
- ● Be a registered business in the UK for custom purposes.
- ● Have a good compliance history (where available).
- ● Have a named responsible person/s for the identification, management, and monitoring of risks.
- ● Implement government-produced standard operating procedures to ensure equivalent assurance of public health and biosecurity safeguards.
- ● Have bio-secure premises and infrastructure.
- ● Provide end to end supply chain assurance; and
- ● Have suitably trained staff who can act independently.
Sending Goods from the Republic of Ireland to Northern Ireland
Under the terms of the Windsor Framework, trade between the Republic of Ireland and Northern Ireland remains uniquely aligned with EU customs and regulatory processes for goods. This special provision ensures the free flow of goods and maintains the integrity of the island of Ireland's supply chain.
Customs Formalities: No customs declarations are required. Goods movements between these two jurisdictions are not considered exports or imports in a customs context.
Sanitary and Phytosanitary (SPS) Requirements: Consignments are not subject to new SPS requirements, negating the need for Export Health Certificates (EHCs) for Products of Animal Origin (POAO) or Phytosanitary Certificates for plants and plant products.
Border Controls: There are no routine documentary, identity, or physical checks at the land border. The movement of goods is unrestricted, preventing any disruption to logistics.
Labelling: “Not for EU” labelling is not required for goods moving directly from Ireland to Northern Ireland.
Sending Goods from the Republic of Ireland to Great Britain
Exports from the Republic of Ireland to Great Britain are now subject to the full set of post-Brexit customs procedures as the UK operates as a third country. This process is governed by the UK’s Border Target Operating Model (BTOM).
Customs Declarations: For every consignment, the Irish exporter must submit a full electronic export declaration to Irish Revenue via the Automated Export System (AES). This declaration requires granular data elements, including the commodity code, a detailed description of the goods, their value, and the consignor/consignee details.
SPS Certification: Consignments must be accompanied by the appropriate official certification. Products of Animal Origin (e.g., meat, dairy, fish) require a government-issued Export Health Certificate, signed and stamped by an official certifier (e.g., a vet). Plants and plant products require a Phytosanitary Certificate from a plant health authority.
Border Controls: Upon arrival in Great Britain, your consignment is subject to the BTOM's risk-based control regime. It must be pre-notified by the importer on the UK's IPAFFS system and may be selected for documentary, identity, and physical inspections at a designated Border Control Post (BCP). These checks incur government fees and can cause logistical delays.
Delegation of Authority: Due to the complexity of these procedures and the required software integration, most companies engage the services of a customs agent or freight forwarder to manage these declarations and navigate the required regulatory systems on their behalf.
Labelling:
“Not for EU” labelling is not mandatory for goods placed on the GB market. However, if you are exporting Irish meat or dairy to GB, “Not for EU” labelling is required. Also, if products are intended for the Northern Ireland market or could move onward to NI, “Not for EU” labelling may become relevant.