There is currently no certainty as to what kind of changes will occur in exports to the UK. If the outcome is a no-deal or hard withdrawal, EU countries will seek to act in concert and primarily look for EU-level solutions. Finland will also adapt its national actions to what has been jointly agreed upon at the EU level.
The EU’s objective is to effect a withdrawal agreement and an orderly and controlled withdrawal. If an agreement for the transition period can be negotiated, the UK will comply with the EU regulations during the transition period and will be part of the internal market but will not be able to participate in the EU decision-making. If an agreement for the transition period cannot be negotiated, this may pose significant effects on exports as of 1 November 2019. The UK is to withdraw from the EU on 31 October 2019.
Plants and plant products
After Brexit, the UK will require a phytosanitary certificate for any plants and plant products for which a plant passport is used within the EU area. These include the host plants of quarantine pests.
Products of animal origin, live animals, gametes and embryos
In the Brexit seminar arranged by the EU Commission on 17 September 2019, it was told that the United Kingdom has announced that it will keep the current practices in force as regards the export of animals and products of animal origin to the UK for a period of nine months after its withdrawal from the EU.
However, exporters should note that live animals and products of animal origin may only be exported from Finland outside the EU by exporters who have registered in the exporter register maintained by the Finnish Food Authority. Companies are also required to follow the customs clearance procedures, which are mandatory in any trade with third countries.
According to DEFRA's (Department for Environment Food & Rural Affairs) webpages updated on 30 September 2019:
- The process for importing feed and food from the EU to the UK won’t change after Brexit. There will be no additional controls or checks and no need to use the import of products, animals, food and feed system (IPAFFS).
- There will be no additional controls or checks for category 3 ABP imports from the EU after Brexit. It is possible that it is not permitted to export to UK category 1 and 2 ABP from the EU after Brexit.
- When importing from EU to UK live animals and germplasm, the UK importer must notify UK authorities at least 24 hours in advance.
- When importing from EU to UK ABP consignments travelling under a DOCOM (commercial document), the UK importer must notify UK authorities when the consignment arrives.
- When notification is required, APHA (Animal & Plant Health Agency) provides the importer a UNN (Unique Notification Number). UNN must be added to the commercial documentation or health certificate (if one is required).
NB! In its letter 9 October 2019 to EU Commission, Defra confirmed that if the Britain continues to have access to TRACES import notification and certificate sections, there will be no requirement for EU operators exporting to the UK to obtain a UNN or to use UK versions of import certificates.
The previous (11 March 2019) instructions issued by DEFRA (Department for Environment Food & Rural Affairs) on the export of live animals / gametes / embryos, products of animal origin that are subject to special safeguard measures and animal by-products that currently move under a commercial document from the EU to the United Kingdom and Northern Ireland in the event of a potential hard withdrawal:
Export to the United Kingdom
- In the event of a hard withdrawal, no changes will take place in the export regulations concerning the products indicated in the title above (live animals / gametes / embryos, products of animal origin that are subject to special safeguard measures and animal by-products that currently move under a commercial document). Passing through border control stations will not be required. However, if the United Kingdom fails to reach an agreement on the use of the Traces system, changes will occur in the document requirements.
- With regard to the products indicated in the title above, the APHA (Animal & Plant Health Agency) requires a notification 24 hours prior to the arrival of the lot. After receiving the notification, the APHA will provide the importer with an UNN (Unique Notification Number). After receiving the UNN via the importer, the veterinarian issuing the veterinary certificate may complete and issue the certificate.
- In the export of live animals, the current intra EU-trade certificates will be used with a 6-month transition period, following which new UK Health Certificates* will be used. In the export of products of animal origin, the UK Health Certificates will only be used when the product is subject to special safeguard measures.
- Animal by-products that currently move under a commercial document will not need a veterinary certificate, but a commercial document intended for by-products (ABP Commercial Document*).
- The UNN must also be recorded in insurance policies concerning the health of registered horses.
Shipments documents must be submitted electronically to the APHA, with hardcopies accompanying the shipments.
Export to Northern Ireland
- With regard to live animals, gametes and embryos, the notice must be filed with DAERA (Department of Agriculture, Environment and Rural Affairs) 24 hours prior to the arrival of the lot.
- With regard to products of animal origin that are subject to special safeguard measures and animal by-products that currently move under a commercial document, an import licence as well as an ITAHC (Intra Trade Animal Health Certificate) or DOCOM (commercial document) must be applied for from DAERA 7 days prior to the arrival of the lot.
- Scanned copies of veterinary certificates and commercial documents must be e-mailed to DAERA prior to the arrival of the lot.
*Certificates for different products can be requested here.