23rd April, 2024

From 30th April, 2024, new post-Brexit regulations will be introduced for sanitary and phytosanitary (SPS) imports into Great Britain (GB). These new regulations will affect the places where checks take place. They also affect the documentation the trader must have ready for the consignment, as well as the type of checks the consignments will be undergoing. Please refer to our March article for more details: Are you ready for the new Import Controls on 30th April, 2024?

Introduction of the post-Brexit Common User Charge

One aspect that traders might be unfamiliar with is the charges that will apply to eligible imports coming into GB. The so-called Common User Charge will apply to imports of animal products, plants and plant products entering GB through the Port of Dover or Eurotunnel which are eligible for sanitary and phytosanitary (SPS) checks at a government-run Border Control Post. 

The UK government applied these charges to fund the government-run Border Control Posts at the Port of Dover and Eurotunnel.

How it works in practice

The Common User Charge will apply to common health entry document (CHED) notifications on the import of products, animals, food and feed system (IPAFFS) that are submitted or changed on or after 30th April, 2024.

It will apply to each commodity line in a CHED with a maximum of 5 commodity lines, even if there are more than 5 commodity lines present in the CHED. Medium and high-risk CHEDs will be capped at £145. Low-risk products of animal origin (POAO) CHEDs and POAO transits will be capped at £50.

If a CHED has commodity lines with different risk categories, the rate of the highest risk category will apply to all commodity lines.

The Common User Charge rates for live animals will be published in a later stage. 

It is important to note that the Common User Charge will be applied to all eligible imports, irrespective of whether the import is selected for a physical check at planned government-run Border Control Post facilities. 

Further details can be found on the GOV.UK website here.

What can you do to prepare for these new post-Brexit import controls?

Traders should be aware and understand that their operating costs will increase if a Common User Charge applies to their imports. This Common User Charge is in addition to the inspection fees from the Port Health Authority (for products of animal origin) and/or the Animal and Plant Health Agency (for plant and plant products) that also apply upon entering GB.

Commercial (private) ports are to set their own charging structure and rates for traders using their services.

Additional charges will apply in situations of late payment or payment avoidance of the Common User Charge. 

The first digital invoices will be issued later in the year for charges incurred from Apri 30th, 2024. Thereafter, invoices will be issued monthly. 
If you have any questions about the Common User Charge or any other aspect of importing into GB from 30th April, 2024, please get in touch with us today.

To meet your compliance obligations and minimise disruption, make sure your business is prepared for the new import controls. Taking effect on April 30th, 2024, these regulations will introduce new requirements for imports into Great Britain (GB). If you have any concerns or queries, please contact us.

In the meantime, let’s look at these changes in detail:

Entry through Designated Border Control Points

From April 30th, 2024, traders must ensure goods from the EU/EFTA enter GB through appropriately designated Border Control Posts (BCPS) or Control Points (CPs) to specify their commodity type. Risk-based documentary, identity and physical checks will take place here.

High-risk plants and plant products from the EU, Switzerland, and Liechtenstein  

Inspections for these will change from Places of Destination (PoDs) to BCPs and CPs. When called upon, you must present consignments for inspection here.

Fishery Products documentation

If you import fish or fishery products for human consumption, you must upload IUU (Illegal, Unreported and Unregulated) documents to the CHED import notification in IPAFFs before submission.         

Imports from non EU-EFTA risk-assessed countries will align with the Border Target Operating Model (BTOM)

Imports will be simplified, and health certification for low-risk animal products will be removed.

• There will be reduced physical and identity checks on medium-risk animal products.             
• Check rates will be adjusted, and import control requirements for some low-risk plants and some low-risk plant products will be removed.
• High- and medium-risk plants will be subject to proportionate levels of checks at Border Control Posts (BCPs) or Control Points (CPs) upon entry into GB. 
• The requirement of a Phytosanitary Certificate (PC) and CHED import notifications made on IPAFFS will remain.

If you are unsure about any of the above, please contact us for guidance

Or find out more about non-EU/EFTA BTOM risk categories for Animal Products or non-EU/EFTA BTOM risk categories for Plant Products.

How to submit your import notifications and customs declarations:

Submit import notifications through Defra’s Import of Products, Animals, Food, and Feed System (IPAFFS).

Submit customs declarations via HMRC’s CDS (Customs Declaration Service).    

You must ensure there is alignment between these systems

Otherwise you may encounter a ‘No Match’ error, which could divert your consignments to Border Control Posts. 

• Background processes validate the import notification reference, commodity code(s) and net weight(s) of consignments.
• These processes provide the SPS inspection decisions for the import notification to CDS.
• All cross-checking import notifications and customs declarations for consignments from EU/EFTA countries will be enforced from April 30th, 2024.

Here’s what you must do from April 30th, 2024:

1. Submit the import notification before the customs declaration.
2. Address any inconsistencies promptly to prevent “No Match” errors.
3. If any inconsistency is found and there is an error message on CDS and the IPAFFS dashboard, correct the errors in both systems as quickly as possible. You must do this before the consignment reaches the port of departure to avoid the consignment being directed to a BCP.

We know this will be a challenging transition for many businesses

Fortunately, our team at Cutraco can help you proactively prepare for this change to prevent any disruption to your business. In fact, we are currently supporting companies and processing customs declarations for products that are covered by the new regulations. 

If you have any questions or concerns about these new import controls, please contact us today.

The amendments regarding risk categorisation for CHED-D products (Common Health Entry Documents for high-risk food not of animal origin – i.e. the retained EU Regulation 2019/1793) have recently been published and will come into force on the 7th March 2024.

The current list of high-risk food and feed of non-animal origin (HRFNAO) will be amended from 7^th March 2024.

Some background information can be found here

Why were these changes introduced?

The regulation has been amended to reflect the changes to hazards affecting imported food to ensure the safety of consumers.

To view the latest changes please click here.

Below is an overview of (new) products that have now been categorised as medium and / or high-risk products. For these products, importers will need to submit CHED-Ds (and any other required documentation such as health certificates) when bringing them into Great Britain if they have an arrival date in the UK of 7th March 2024 or after:

• Enoki mushrooms from China
• Granadilla (Passiflora ligularis) and passion fruit from Colombia
• Bananas from Ecuador
• Oranges from Egypt
• Vine leaves from Egypt
• Peppers from India for pesticides
• Cinnamon and cinnamon-tree flowers from India
• Cloves (whole fruit, cloves and stems) from India
• Drumsticks (Moringa oleifera) from India
• Ginger, saffron, turmeric (Curcuma), thyme, bay leaves, curry and other spices from India
• Nutmeg, mace and cardamons from India
• Seeds of anise, badian, fennel, coriander, cumin or caraway, and juniper berries from India
• Rice from India
• Melon seeds from Iran
• Hot peppers (Capsicum spp.) from Kenya
• Cow peas (Vigna unguiculata subspp.) from Madagascar
• Rice from Pakistan
• Enoki mushrooms from South Korea
• Sesame seeds (Sesamum) from Syria
• Tahini and halva from Sesamum seeds from Syria

Which products have been removed from the list or moved to a lower risk profile?

From 7 March 2024 – Hazelnuts from Turkey have been removed from the list and therefore no longer require CHED-Ds and / or health checks upon entry into the UK.

Furthermore, Pitahaya (dragon fruit) from Vietnam has been moved to a lower risk profile. Although CHED-Ds are still required to be submitted, shipments departing from Vietnam from 7 March 2024 onward will no longer require health certificates or test reports.

Which products have been moved to a higher risk profile?

In contrast, Spice mixes from Pakistan have been moved to a higher risk profile. CHED-Ds were already required to be submitted, but shipments departing from Pakistan from 7 March 2024 onward will now also require original health certificates and copies of test results to be submitted to port health along with CHED-Ds.

Finally, it has been announced that the scope of controls for groundnuts has been extended to include groundnut paste from certain countries.

How you can prepare for these changes:

Review your product portfolios

Ensure that the CHED-D and any other required documentation is obtained and available.

Update the details on the Master Data tab in the import declaration template.

Please let us know if you need our support to review the current master data table and / or update the master data table for these changes per 7 March 2024.

You can also contact us if you have any questions and / or would like a call to discuss this in more detail.