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Exporting to the UK from Ireland


Changes to exporting to the UK (excl. NI)

Since 1 January 2021, things have changed for our agri-food industry, particularly for importers and exporters of agri-food products. As the UK is no longer in the EU Customs Union or Single Market, it now sets the import requirements for products into Great Britain.

The UK has however adopted a phased approach to the implementation of these import requirements, including sanitary and phytosanitary SPS controls.

Since 1 January 2021 EU exporters have been required to pre-notify exports to the UK authorities using the Goods Vehicle Movement Service (GVMS) or to avail of temporary storage at the point of import while import formalities are completed. Certain limited categories of plant and animal products, which the UK considers to be high risk (e.g. live animals, germinal products and high risk plants and plant products), also require pre-notification to UK authorities using Imports of Products, Animal, Food and Feed System (IPAFFS) by the UK importer, and the relevant Export Health Certificate, issued by the Department to be provided for the consignment.

On the 28 of April 2022 the UK government announced that the remaining import controls for agri-food goods, which were due to come into place later in 2022 would be postponed.

Controls that had already been introduced remained in place.

On the 29 August 2023, the UK Government released the final version of its new Border Target Operating Model (TOM) document. This sets out an overview of the UK’s new approach to control of imports of agri-food goods from the EU including new timelines commencing on 31 January 2024 (further details of these requirements are set out below).

If you have any queries in relation to export certification, please contact BrexitCall@agriculture.gov.ie

A range of Government supports is available, including training and grants, to help your business deal with these changes. A link to these supports is available here.

It is also important to note that you will also need to engage with your UK importer and with the UK authorities.

Register to Export

From Department of Agriculture, Food and the Marine

What the exporter must do

Since 1 January 2021, new regulatory and customs requirements are part of trading with or through the UK (excl. NI). There are a number of tasks those trading with the UK may need to comply with depending on their business and procedures.

Most traders will need to register with one or more government organisations. Traders need to examine each area set out in this section to check if they apply to their business.

In particular, traders requiring certification for products being exported to the UK (excl. NI) need to register to access the Department’s online export platforms.

How to register with the Department of Agriculture, Food and the Marine

The Department's online registration form here provides a quick and easy way to register to import or export.

For any queries on completing the registration process, contact BrexitRegistration@agriculture.gov.ie.

Current clients of the Department, who are continuing to trade with the UK should update their registration by clicking on the online registration form to indicate whether they are importers (the operator responsible for the consignment) and/or exporters.

How to register for TRACES

The Trade Control and Expert System (TRACES) is the European Commission’s online platform for the sanitary and phytosanitary certification required for:

• The importation of animals, animal products, food and feed of non-animal origin and plants into the European Union

• intra-EU trade

• EU exports of animals and certain animal products

If you are trading in live animals or products of animal origin, the operator responsible for the consignment will also need access to the online system TRACES.

When you register as an Importer or Exporter with the Department, TRACES registration will be initiated for you. Recorded generic TRACES training on How to create an Export Health Certificate and How to create an EU login and Operator Role Request may be helpful.

See our TRACES page for more details or email BrexitRegistration@agriculture.gov.ie for help.

Customs - Register with Revenue for an EORI number

Since 1 January 2021, you need an EORI number to move goods from, through or to the UK (excl. NI).

The Economic Operators Registration and Identification (EORI) number allows businesses to import or export with countries outside the European Union. To obtain an EORI number, companies can register directly through Revenue.

How to register with the Environmental Health Service of the HSE

You may also need to register with/notify the Environmental Health Service (EHS) of the Health Service Executive (HSE) in relation to the import and export of food products of non-animal origin.

If an export certificate is required for foods of non-animal origin or a food business wishes to notify the HSE, this facility is available through the HSE online service.

Changes to exporting to the UK (excl. NI) in effect since 1 January 2021

The requirements and procedures for exporting the following animals and commodities to the UK (excl. NI) since 1 January 2021 are set down below:

On 29 August 2023, the UK Government published its final Border Target Operating Model (TOM) which sets out, at a high level, the UK’s approach to controlling imports of goods to Great Britain, including goods from the EU. This document takes into consideration feedback from stakeholders on the draft TOM which the UK Government published in April 2023.

The final TOM includes provisions related to customs and Sanitary and Phytosanitary (SPS) requirements for imports of goods from the EU, including Ireland. The application date for these new requirements commenced from 31 January 2024. The new deadlines for the implementation of UK SPS import controls can be summarised as follows:

1 January 2024

Since 1 January 2024 UK authorities are applying some new food labelling requirements in respect of:

a) Requirement for the UK’s importer address to be applied on pre-packaged food or caseins and

b) Requirements related to country-of-origin labelling

a) Importer Address

Since 1 January 2024, pre-packaged food or caseins sold in Great Britain (GB) must:

- include a label with a UK address for the Food Business Operator (FBO) whose name the food is marketed under,

Or

- If the FBO is not based in the UK, include the company address of the importer in the UK.

- Product sold in Northern Ireland (NI) must have either a NI address or an EU address on its label.

The UK has stated that the company address must be a physical one. It cannot be a PO box, email address or phone number.

For more information on these new UK labelling address requirements please see DEFRA Food labelling guidance and the UK Border Target Operating Model

b) Country of origin Labelling

Specific country of origin labelling requirements by product also changed from 1 January 2024. The UK Government’s guidance on these changes is available in links below:

For further advice on these changes, you should contact your GB trading standards office.

31 January 2024

• Export health certificates and phytosanitary certificates are required for medium risk animal products, plants and plant products imported to Great Britain from the EU, including from Ireland.

• Prenotification of imports of SPS goods from Ireland on the UK’s SPS import system (IPAFFS) are required (this requirement already applies to imports of such goods from the rest of the EU since 1 January 2022).

30 April 2024

• Documentary checks and physical and identity checks at the border were introduced for medium risk animal products, plant and plant products imported to Great Britain from the EU, excluding those goods being imported from Ireland.

• Existing inspections of high-risk plants/plant products from the EU moved from point of destination in Great Britain to UK Border Control Posts.

31 October 2024

• Safety and Security declarations for EU imports will come into force.

• Documentary and risk-based identity and physical checks on medium risk animal products, plants, plant products and high-risk food and feed of non-animal origin from Ireland will be introduced at ports on the west coast of Great Britain (the date for the commencement of physical checks for non-qualifying goods moving from the island of Ireland have not yet been confirmed).

This will apply to a wider range of agri-food goods than is currently the case, including products of animal origin and all regulated plants and plant products. It will be based on a risk categorisation of high, medium, and low risk as defined by UK Government, depending on country of origin and product definition.

There are 3 TOM risk categories

  • Low
  • Medium
  • High

It is dependent on the product type and its risk level if you will require pre-notification on the UK’s Import of Products, Animals, Food and Feed System (IPAFFS) notifying UK authorities before the goods arrive in Great Britain from 31 January 2024.

Low Risk

• No pre-notification requirements for low-risk plant and plant products from the EU.

• From 31 January 2024 pre-notification required for low risk products of animal origin.

• Do not need an export health certificate.

• Requires a commercial document from the supplier to allow traceability.

Medium Risk

• From 31 January 2024 the consignment must be pre-notified on UK IPAFFS system.

• From 31 January 2024 the consignment must have an export health certificate issued by the competent authority in the country where the goods originate, or an official importer declaration (where applicable).

• From 31 October 2024 consignments may be subject to risk based physical import checks. A date for application of Border Control Post SPS entry controls (identity and physical inspection controls) for Irish goods moving to GB will be confirmed shortly.

High risk

• Each consignment must be pre-notified on UK IPAFFS system.

• The consignment must have a health certificate issued by the competent authority in the country where the goods originate.

• Most high-risk consignments are already subject to physical import checks. These will continue after January 2024.

Health Certificates

On the 28 of April 2023, the UK’s Department for Environment, Food and Rural Affairs (DEFRA) published new/revised UK Export Health Certificates, (EHCs) for the EU, including Irish products. These certificates must be used from 31 January 2024 for export of EU agri-food goods to Great Britain.

If you have any queries in relation to export certification, please contact BrexitCall@agriculture.gov.ie

Changes to Landbridge

For up-to-date information on moving goods using the GB landbridge please click here.

UK Government Resources

The UK Government has set out its general guidance for EU businesses wishing to export goods into the UK here.

The responsible UK authority is the Animal and Plant Health Agency (APHA) of the Department for Environment, Food and Rural Affairs. The webpage will be updated as further guidance is issued by the UK authorities.

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