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FISH, SHELLFISH AND THEIR PRODUCTS

Alinea Customs provide a guide to exporting fish and shellfish products

In addition to the requirement for export health certificate, import control pre-notification and entry via a Border Control Post,  there are additional requirements for exporters of Marine Caught Fish and CITES listed goods, that will need to meet line catch certificate requirements as detailed for fish, shellfish and their products.

Export of most UK marine caught fish, e.g.  freshwater fish, and shellfish must be accompanied by catch certificate, and official document to proof that the fish has been caught in UK waters.

Fish and shellfish exporters must create a catch certificate that has been landed by a UK flagged catching vessel. This must contain:

·      Details about the catching vessel including the PLN, vessel and license number

·      The species and commodity code

·      Amount of fish caught by species and net weight per vessel

·      Where and when the fish was caught


Storage document – for fish stored on premises in GB

 Fish that has been caught outside of the UK waters but are stored in the UK for longer than 24 hours but not processed will require a storage document to enable export to the EU, Iceland, Ivory Coast, Kuwait, Madagascar, Norway, Thailand, Tunisia and Ukraine.  

To create a UK storage document, you’ll need:

·      a Government Gateway user ID and password

·      the company name and address of the exporter

·      to say what products are being stored (and include the EU tariff commodity codes)

·      catch certificate numbers and export weights for each product

·      the dates and places that the products entered the UK (and transport details upon entry to the UK)

·      the name, address and facility approval number of each storage facility used

·      to say how each storage facility stores the product (frozen, chilled or both)

·      transport details for how the export will leave the UK, where it will leave from and when

·      the identification numbers of the containers used to export the product

Create a UK Storage Document. The original EHC must be presented to the Border Control Post when entering an EU country.

Exports of non-marine fish e.g. freshwater fish and shellfish and certain exempt marine species including mussels, cockles, oysters, cockles, scallops, fish fry or larvae are not subject to catch certificate requirements.


Live animals where intended for consumption by the consumer, such as live oysters, mussels, lobsters and crabs from Class A waters are classified as animal products and not live animals and will be subject to controls applying to animal products rather than live animal controls.

Groupage

2. A transit occurs where the products enter and exit the EU, without the products being received by the EU or entry onto the EU market, or where a consignment passes through an EU member state prior to reaching its final EU destination. A direct export occurs where the products enter the EU and are received by the EU for entry onto the EU market.

3. For example, a composite (e.g. pork pie) exported whole that is re-packaged at a deli counter for sale to the final customer. Bulk products exported for further processing are not in scope.

All exporters using the groupage scheme must source all of their products from a reputable supplier list. Products that have been frozen or are undergoing processing laster longer than six months (e.g. cheese undergoing maturing) may be covered by an SA provided that the relevant health and traceability details (as required by the Export Health Certificate) for any products supplied to the exporter in the six month period are suitably stable.


Groupage exporters must use the following wording as detailed within Annex II.


This document may only be used to facilitate EU export certification of groupage consignments of specific categories of products (including as required under the Northern Ireland Protocol for GB to NI movements of goods)


These categories are products of animal origin (POAO) for human consumption as listed below and processed pet food that is fully packaged for the final consumer (or purchase in the case of pet food), or to be re-packaged directly at the point of sale to the final consumer. They are products that are produced using only animal content from a traceable network of known suppliers. Included: Composite products 6, meat products 7, meat preparations 8, processed milk/matured or processed dairy products, fish/fisheries products, eggs/egg products, processed pet food, honey, frogs’ legs, snails and live bivalve molluscs. Excluded: Live animals, germinal products, fresh meat, raw milk, animal by-products (including raw pet food but excluding processed pet food). Some of these products may be included within a groupage consignment, but they must have been separately certified without the use of a 30 day SA.

SA’s must be fully completed and signed by a suitable representative of the supplying company, and a registered vet, FCCO or CSO acting under the direction of the CO.

UNIQUE DOCUMENT REFERENCE NUMBER (12) …………………………………. I. Supplier declaration I …………………………………………………………………….. (full name), being……………………………………………………..(official position in the company) of ………………………………………………………………………………………………… (name and address of supplying company), have authority and responsibility to sign this declaration on behalf of this supplying company. I hereby declare that the details in sections A and B below includes a complete list of the products of animal origin contained within the products to which this Support Attestation relates supplied to …………………………………………….. (company name of exporter). I confirm that the information within this support attestation is correct and that no changes will be made to affect its validity prior to its date of expiry. I will ensure that the registered veterinarian* / CSO (Certification Support Officer)* / Food Competent Certifying Officer signing the attestation in section II and the exporter listed above are immediately informed if any changes are made that affect the validity of this document and/or if I leave the employment of the supplying company detailed above. I understand that in such cases this support attestation will immediately become null and void. I understand that supplying false or misleading declarations that will be relied upon by the exporter in respect of the verifications provided in the relevant export health certificate is an offence and may result in rejection of the exported product and immediate removal of the exporter from the Groupage Export Facilitation Scheme as well as risk of liability for costs incurred. I will ensure that each consignment of products sent to the export depot that is covered by this support attestation is accompanied by a declaration signed on behalf of the supplying company and stating that “The evidence required to facilitate export of 12 A unique reference number must be given to each original support health attestation used. Suggested format: unique supplier number/sequential number/ unique number for vet, FCCO or CSO signing part II /year (e.g.: 15435/0000001/m159607/2019) 16 the products in this consignment has been provided in Support Attestation …. [insert unique reference number as above]. No changes have been made that affect the validity of the information provided in this Support Attestation.” A. Details of product(s): 1. Origin and Destination a) Address and, if available, Approval* / Registration Number* of the establishment(s) from which the consignment will be dispatched (e.g. supplier) : ..................................................................................................................................... ............................................................................................................................... b) Address and, if available, Approval* / Registration Number* of the establishment(s) to which the consignment will be dispatched (e.g. exporting depots): ..................................................................................................................................... ............................................................................................................................... 2. Description of the product(s) Product specific details of all products to which this support attestation relates (this may be attached as a schedule): ..................................................................................................................................... ............................................................................................................................... B. Traceability information: [INSERT REQUIRED INFORMATION RELATING TO ALL PRODUCTS LISTED ABOVE (IN A.2) AS AGREED WITH THE CERTIFYING OFFICER RESPONSIBLE FOR EXPORT CERTIFICATION] Authorised by Name:

Signature:

Position:

Date:

High level overview

Suitable forms of evidence which registered vets, FCCOs or CSOs may check before signing SAs could include:

• contractual agreements

• invoices

• HACCP plans/records • Standard Operating Procedures (SOPs)

• Traceability records

Visit Defra’s Groupage Export or contact GEFS@defra.gov.uk for further information.


Products of Animal Origin (POAO)


Exporters must ensure the containers for exporting animal products are clean.

·      POAO will require an Export Health Certificate (EHC) and other official documentation

·      Import pre-notifications must be submitted by the importer at least one working day in advance of arrival.

·      POAO must enter the EU by a suitable Border Control Post (BCP).


Exporters of certain animal products also containing POAO may also be subject to requirements. Exporters should check if their commodity code is listed Regulation 2019/2007 to find out if the POAO or ABP meet the above requirements.


Exporters of foods products listed in CITES, EUTR and UKWTR annexes such as caviar from the sturgeon family will also need to meet CITES-related requirements as detailed for CITES goods.  


Border Control Posts  


Upon arrival, POAO will be subject to documentary and identity checks and a throughout examination of all certification, and labelling and inspection. Goods may also be subject to physical checks.