Port Health Frequently Asked Questions
If we supply a customer (who later wants to export from their own cold store with other goods) or deliver to a groupage transport depot somewhere, we ask North East Lincolnshire Council (NELC) to sign one of these attestations to confirm the product details that will later go on the Export Health Certificate (EHC) issued by the customers local Official Veterinarian (OV)/Environmental Health Officer (EHO) when goods are exported? Presumably, this would still have a charge of £108 from NELC the same way a EHC would?
If a company is using an Export Logistics Hub or Certifying a certificate outside of the area that the product was originally manufactured, then there will be a requirement for the local authority in which the products are manufactured or packaged to provide an attestation to support the EHO/OV in the signing of an EHC. Depending on the nature of the product and the frequency of export, these attestations can be provided on a risk-based approach so it may not be that you require one to accompany each load.
The charge for a Supporting Attestation is £50 and the length of their validity is dependent on the Scheme they are using (30 days for the Groupage Export Facilitation Scheme (GEFS)) or up to 6 months for the Risk Based Certification Scheme for Fishery Products.
For products previously imported to the UK from non-EU countries and that have not been further processed prior to export, copies of the import documents (CHEDPs) showing clearance at a UK BCP will provide equivalent assurance to a Local Authority Support Attestation.
If we are asking NELC to sign an EHC for a full truck load of various products leaving our store, where we supply for example, photos of labels confirming the information on the EHC, do we still have to have signed up to (Groupage Export Facilitation Scheme (GEFS) because we are sending out various products on one truck or as it’s a direct export from our store would we not be required to be signed up for GEFS and NELC could still sign an EHC as normal?
If you are sending out a full load of fishery products directly from your site here to the point of destination, then you would not have to sign up to GEFS and NELC can provide fishery product EHCs that would cover the whole consignment.
Please confirm whether NELC would charge £108 for the signed attestation and then the exporting customer has to pay his EHO/OV their charge for the EHC on export? So, 10 different lots on a truck could have had a charge of a few thousand £’s in health attestations/certs by the time it loads in theory?
The charge for a Supporting Attestation is £50 and they are valid for a specified time period, therefore it is highly unlikely that you will require a new one for each consignment you export, unless you only export throughout the duration of the attestation.
Can the exporter still just ask for an EHC for goods to load from his store and just provide the usual proof of product details as we would do? Surely, this is all that would be necessary without the exporting customer having to get all these attestations?
You can have a certificate issued from your site for the goods, however if your consignment is to be consolidated at another location and form part of a groupage load, you have to take into consideration that some elements of the information on that certificate may differ to the information on the overall load, i.e., transport details. A Certifying Officer at the place of dispatch may use the EHC in place of a Supporting Attestation however this is probably a more expensive route to take than providing an attestation.
I would like to understand more about the plans and resources to complete the EHC online certificate checks also the physical checks. Would a Certified Officer have to come to site to inspect every outload?
The mechanism for applying for Export Health Certificates to the EU and Export Health Certificates for some non-EU countries is through Export Health Certificate Online (EHCO), which is an online process set up by the Animal and Plant Health Agency (APHA). Exporters would have to register on this site, make their application for a certificate, which is then sent through to their nominated Certifying Officer or organisation in the case of NELC. We would then ask you to notify us of the date and time of loading – email@example.com and our officers will make arrangements to visit and inspect the consignment.
There is no obligation to inspect every consignment and we are permitted to apply a risk-based approach to certifying loads that we have not inspected, however given that we are still in the initial stages of certifying goods to the EU and we are still finding issues on inspection routinely, we are currently inspecting each one. We very much anticipate that there will be a point in the not-so-distant future where we are not inspecting each consignment and will rely on the information provided to us.
How long will it take to produce the EHC?
The time it takes to certify a certificate very much depends on the accuracy of information provided to us in Export Health Certificate Online (EHCO) and the complexity of the load. On submission of an application, officers will check the information within it to ensure that the information is correct. This will be cross referenced with any supporting information that has been uploaded, i.e. packing lists and / or photographs.
We will make as many necessary changes as possible prior to the date and time of loading in the hope that all information remains correct and the certificate can be handed over at this time. Any discrepancies between the information provided to us and the physical load will result in a delay to this process. Due to limitations with the certificates generated by the EHCO system, we are currently having to apply several required amendments by hand that can be time consuming. We anticipate that DEFRA will make improvements to EHCO that will minimise this issue in the future.
Will NELC take the EHC to you or do you have to collect it from NELC? (If the driver needs to take it with them)
If we are already in possession of all the information required for the certificate, including transport details and seal numbers, if applicable, the certificate can be completed in advance and the officer will bring it with them. If there are any discrepancies that result in amendments to the certificate, then it may be that you are required to collect the amended certificate from our office.
If we are not planning to visit the consignment, you will be notified and expected to make arrangement to collect the certificate from our office at Europarc Innovation Centre, Europarc, Grimsby, DN37 9TT.
Guidance on what exporters should put on the EHC
We have issued multiple guidance documents on how to register on EHCO, a step-by-step process on how to complete the information required and a guide on the certificates to use. The relevant guidance documents can be made available on request.
Imports – Border Control Post (BCP)
Will we be pre-informed which containers are selected for exam?
Ideally, yes but it all depends on how we receive the information. We are aware that there are much shorter journey times and if we solely rely on manifest information to select units, then we could be receiving the manifests on the same day that the units are arriving. We still have some work to do in this area, but we are working closely with the Port Operators and hopefully our stakeholders, who we would very much appreciate an input from.
If importers are in a position to be able to present information in advance, then we may have a better mechanism for selecting units without the need to rely on the manifest information.
Will the BCP be manned 24 hours?
In the first instance we are not looking at a 24/7 operation but are looking to extend the BCP operating hours and discuss the inclusion of weekends if required. The reason why we are not looking at a 24/7 operation is because the proposed check identity percentage rates for EU/EEA origin goods from the 1st July is 1%. Given the nominal rate, we do not anticipate that the BCP will need to be staffed on a 24/7 basis. If we do however receive information to the contrary, then it is something that we will have to explore.
Will there be any priority for fresh or chilled which will adversely affect the frozen cargo?
We are in the process of looking at vessel schedules, liaising with stakeholders and others that will influence the way in which we operate. We are anticipating having a much wider range of goods to deal with, that presents its own challenge in relation to cross contamination, the different presentations and goods that will require a greater degree of clean up than others. Prioritising various product categories is something that we will of course consider if the vessel schedules and movements allow us to do so. Live, chilled and/or perishable would be the obvious priorities.
What are the expected number of exams per day?
We are planning our service based on 100% identity checks for non-EU cargo and 1% for EU goods for the various product categories. Our current capacity at a BCP with 1 bay is 20 examinations a day between the hours of 8:30 – 12:00 / 13:00 – 16:00. We are currently interrogating manifest information to assess how many more examinations a day will be required based on the 1%. We will then staff the facility and amend the operating hours based on this information, instead of focusing on the number of examinations we can do a day.
How many new officers will there be?
We have just completed our second phase of recruitment with the third phase in process now. Our recruitment exercise looked at increasing the various roles within the team. Additional qualified officers who can carry out the examinations, Official Veterinary Provision to inspect products of animal origin (other than fish) and support officers. We have had a positive response to the recruitment and have increased the size of the team from 20 officers (including Trading Standards) to 50+. This increase has accounted for the need for extended working hours and potential weekend provision.
We have already been significant progress with training for the first of these phases and officers have been involved in both import and export work, the qualified officers will join us in March as will the additional Support Officers, who will all go through an intense training programme.
We understand that the selection for exam will be 1% for EEA/EU cargo – when will this be confirmed?
This has now been confirmed by Central Government and there is nothing to suggest that there will be a move away from this from Day 1. We have however been made aware that it may be reviewed the following year, so we are taking this into account when planning our service.
Will the rate for examination be different for EU/EEA and other third countries i.e., not standardised for all cargo?
In terms of charging, we are still using the harmonised EU rates until we get a steer from Central Government on what the UK’s charging regime is going to be. Similarly, charging is something that is discussed on the various forums, meetings etc for EU goods but yet, we have still not received any update on this.
In terms of rate for documentary, identity, and physical checks, we are progressing on the basis that non-EU rates will continue as normal, 100% Documentary, 100% identity and a reduced percentage for physical checks based on the commodity and country of origin. We are aware however that these are currently under DEFRA/APHA review.
EU/EEA will initially be set at 100% documentary checks, 1% identity checks and 1% physical checks.
Will the % be applied to other countries i.e., China / Vietnam etc?
We have been advised that this is currently being reviewed.
When will the new costings be released as we will require sufficient time to inform our customers?
We will release information in relation to charges as soon as we have received the information from DEFRA. We anticipate that they will continue down the route of a harmonised charge so that has to come from central government.
Are there any plans or discussions in place to accept scanned copies of all documents including the health certificate for short sea shipments?
There will be an expectation from the 1st April 2021 to pre-notify the BCP prior to arrival through IPAFFS. An electronic copy of the Health Certificate should also be uploaded. The instruction is that the original documentation should travel with the consignment.
We appreciate that this presents a challenge for unaccompanied consignments and obtaining those documents for the shorter journey times and these concerns have been raised with DEFRA. We will of course keep you updated as soon as we receive a response.