Reviewed in November 2020. Content will be updated as negotiations develop.

What Happens Now?

Ireland

From 1 January 2021, Great Britain (GB) is to be outside of the EU Single Market and Customs Union. Businesses in Ireland who move goods from, to or through Great Britain will be subject to new Customs formalities and regulatory requirements, regardless of the outcome of the EU-UK Free Trade Agreement (FTA) negotiations.  There are to be no Customs or SPS controls on the island of Ireland, with or without a FTA. 

Sanitary and Phytosanitary (SPS) Controls For Post-Transition Trade Between Ireland and GB

The export and import of live animals, products of animal origin (including fish), germinal products, animal by-products (i.e. not for human consumption) and some plants will be subject to additional SPS border checks. This is to reduce the risks of diseases, pests, or contaminants entering from third countries.

Prior to the goods being imported, they must be pre-notified by the importer to national authorities. I.e. for imports into the EU using the  Trade Control and Export System (TRACES), or for imports into GB using the  Import of Product, Animals, Food and Feed Systems (IPAFFS). 

Goods must then move through a Border Control Post (BCP) capable of handling those particular goods. For a list of BCP’s in the UK click  here and for Ireland click  here.

Checks can then be carried out, including:

  • Documentary checks e.g. an Export Health Certificate for animals/animal products, a phytosanitary certificate for some plants/plant products or a catch certificate for some fish.
  • Identity checks to verify that the goods match those on the documentation.
  • Physical checks, the frequency of which depends on the risk associated with a commodity – click here for more information.

It is the responsibility of the “operator responsible for the consignment” to ensure that the appropriate paperwork is in place. The operator responsible for the consignment can be the importer, but is often a Customs agent acting on the importer’s behalf.

GB Goods Entering Ireland

From 1 January 2021, full SPS checks will be imposed, with checks at BCPs and requirements for certificates, pre-notification through TRACES (24 hours before arriving at the BCP) and submitting the necessary documents via the Department of Agriculture, Food and the Marine (DAFM), or other import portal. 

For more information, see Irish Revenue’s October 2020 Presentation on  Trading in Agricultural Goods – SPS Checks and Requirements

Goods From Ireland Entering GB

On 8 October the UK published its updated  Border Operating model, introducing border controls in three stages for EU goods arriving in GB, with full SPS controls by July 2021. 

  • Stage 1 – From January 2021: Imports of high-risk live animals, plants and animal/plant products must be pre-notified to the UK authorities via IPAFFS, have correct health documentation and may be subject to checks. Physical checks will be carried out at the point of destination/other approved premises.
  • Stage 2 -From April 2021: Pre-notification (via IPAFFS) and health documentation will be required for all products of animal origin, regulated plants and plant products. Physical checks will continue to be conducted at the point of destination/other approved premises.
  • Stage 3 – From July 2021: Goods requiring SPS checks will need to move through designated Border Control Posts equipped to handle the particular type of goods.
Wood Packaging Material

From 1 January 2021 all wood packaging associated with goods (e.g. boxes, crates, dunnage, pallets) moving between GB and the EU must meet  ISPM15 International Standards by undergoing heat treatment and marking. The UK has advised that it will carry out checks on a “ risk targeted basis only“. 

Landbridge

Irish Revenues  advises that, from 1 January 2021, animals and goods moving between Ireland and another EU Member State via GB (the UK Landbridge) must be placed under the Customs Transit procedure, to maintain their Union status. EU regulations require certain SPS controls on animals and goods re-entering the Union. Discussions are ongoing to determine how this will work. 

Northern Ireland

There are to be no tariffs or Customs controls on the island of Ireland, regardless of the outcome of the EU-UK Free Trade Agreement (FTA) negotiations. Goods moving between Northern Ireland and the rest of the EU will also continue to move freely. From 1 January 2021, Great Britain (GB) is to be outside of the EU Single Market and Customs Union. Northern Ireland will belong to a different sanitary and phytosanitary (SPS) zone to the rest of the UK, with new SPS requirements for goods moving from GB to Northern Ireland. 

Sanitary and Phytosanitary (SPS) Controls

To reduce the risks of diseases, pests, or contaminants entering from third countries, the export and import of live animals, products of animal origin (including fish), germinal products, animal by-products (i.e. not for human consumption) and some plants are subject to SPS border controls and checks. 

GB to Northern Ireland

With the island of Ireland as a single epidemiological unit, live animals being moved from GB to Northern Ireland already undergo checks upon arrival.

From January 2021 agri-food products entering Northern Ireland from GB will need to:

·Enter via a designated point of entry (the list is still being  finalised).

·Pre-notify movements on the UK’s Import Of Products, Animals, Food and Feed System,  IPAFFS (the UK Government has promised to provide  further guidance).

·Hold Export Health Certificates for movements of live animals and animal products, Phytosanitary Certificates for movements of plants and plant products and Catch Certificates for some fish. The UK Government has introduced a new digital online application service,  EHC Online (EHCO) to streamline the process. The Export Health Certificate will need to be completed and signed by an appropriately qualified officer e.g. Official Veterinarian for products of animal origin.

There are additional requirements for aquatic animals and endangered species.

Goods will be subject to documentary and ID checks and perhaps physical checks at the point of entry depending on the perceived risk of the commodity.

An import licence from the Northern Ireland Department for Agriculture, Environment and Rural Affairs (DAERA) may be required, as is the case today.  Access further information on import licences.

For more information relating to specific products and their SPS requirements, please click  here.

Northern Ireland to GB

The UK Government has promised “unfettered access” for goods moving from Northern Ireland to the rest of the UK – without the need for additional approvals, Customs or regulatory checks.  The precise arrangements are yet to be determined.

 More information is available  here.

Between Northern Ireland and EU Member States

For goods in free circulation in Northern Ireland moving to the EU (including Ireland), there are to be no substantive changes for how goods currently move. 

More information is available  here

Helpful Links

*Trade negotiations between the EU and UK are ongoing, as are discussions of the EU-UK Joint Committee (under the Withdrawal Agreement). Decisions made in these processes may affect some of this guidance.

Key Actions

The below will help advise you as to what you need to do next to get your business prepared ahead of 1 January 2021.

Ireland & Northern Ireland – Verify what certificates are required to export/import the products.

Ireland – Ask suppliers if they will be able to provide the health/phytosanitary/catch certificates and the time this will take.

Northern Ireland – Identify the responsible person for your organisation.

Ireland – Identify the responsible person for your organisation.

Northern Ireland –  Register for IPAFFS.

Ireland – Register with national authorities,  TRACES and/or  IPAFFS.

Northern Ireland – Ask suppliers if they will be able to provide the health certificate/phytosanitary certificate/catch certificate, and the time this will take.

Ireland – For DAFM, see this  link and contact  BrexitRegistration@agriculture.gov.ie

Northern Ireland – Identify a designated point of entry (when the list is available) for goods moving from GB to Northern Ireland.

Ireland – Decide how the consignment(s) will be presented at the Border Control Post – the simpler the load the quicker the import control process. 

Northern Ireland – Notify the Department of Agriculture, Environment and Rural Affairs (DAERA) if importing live animals and germinal products from the EU to Northern Ireland.

Ireland – Complete pre-notification and submit the correct documentation 24 hours in advance. 

Northern Ireland – Decide how the consignment(s) will be presented at the Border Control Post – the simpler the load the more efficient it is to process through all stages of the import control process.

Northern Ireland – Submit notification in IPAFFS at least 24 hours before the consignment is due to arrive at the border control point. This can be done up to 30 days in advance. 

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