Reenviamos Newsletter de la Embajada británica, relativa al BTOM, que incluye un listado de errores comunes en las tramitaciones de los despachos.
DEFRA Biosecurity Border and Trade Programme – Border Target Operating Model (BTOM) Newsletter
Updates
ALVS outage
Over the weekend of 11/12 May, a technical issue impacted Defra digital services. One of the systems affected is ALVS (Automatic Licence Verification System), the system required to process the imports of Sanitary and PhytoSanitary (SPS) controlled goods. We have worked at pace to get the systems back online and as of 15 May all systems are fully operational again. There have been no significant delays to border checks and we continue to protect our high standards of biosecurity in the UK through effective monitoring across all imports. We have put in place contingency arrangements for the clearance of affected vehicles and consignments at the border, working alongside HMRC and Border Force. Exceptionally, we are instructing SPS cleared goods to be removed from border locations and taken to their destination. Customs declarations will be finalised in HMRC systems as soon as possible.
Plants & Plant Products Update
Medium-risk plants and plant products: new sub-categories
Initially, plants and plant products were categorised into ‘high, medium and low’ risk and controls have been appropriately weighted against the risk. After further review, there will be a change to how the medium-risk category will look for plants and plant products.
The medium-risk category will be split into two parts, A and B. Therefore, the new risk-categories will be: High, Medium A, Medium B and low-risk.
- High risk goods will require a Phytosanitary Certificate (PC) and pre-notification before entering GB. Since 30 April 2024, in line with the phased import regime, these goods are subject to risk-based, physical and identity checks at a Border Control Post (BCP) or designated Control Point (CP).
- Medium-risk A goods require a PC and pre-notification before entering GB. From 30 April 2024, in line with the phased import regime, these goods are subject to risk-based, physical and identity checks at a BCP or designated CP.
- Medium-risk B goods only require a PC when entering GB.
- Low risk goods do not require a PC or pre-notification.
End date on easement for EU, Switzerland and Liechtenstein medium risk fruit and vegetables
There is currently an easement implemented for EU, Switzerland and Liechtenstein medium-risk fruit and vegetables meaning that they are not required to pre-notify or a have a PC. We can now confirm the end date for the easement is planned to be 31 January 2025. From this date, EU medium-risk fruit and vegetables will be subject to either medium-risk A or medium-risk B controls, dependent on their categorisation.
Updates to risk categorisation for certain commodities
Three commodities, parts of plants (other than fruits and seeds) of Ipomoea and Solanaceae and leaves of Spinacia oleracea have moved from the low-risk category to medium-risk for imports from EU.
All low-risk plants & plant products from EU, Switzerland and Lichtenstein are now considered de regulated, meaning there will no longer be plant health import controls for these products.
Link to Plant Health Portal:
Import plants and plant products from the EU to Great Britain – GOV.UK (www.gov.uk)
Sevington Border Control Post
In our last newsletter we confirmed that the inland border facility at Sevington in Kent had been designated as a border control post (BCP) for Plant (P), Plant Products (PP), Other Objects (OO), Wood Products (PP(WP)), Products of Animal Origin (POA) and Products Not of Animal Origin (PNAO), entering Great Britain via the Port of Dover and Eurotunnel, from 30 April. We have published detailed information gov.uk. This includes information on the physical facility as well as charges and inspections. Sevington border control post (BCP) – GOV.UK (www.gov.uk)
Latest Common Errors
The table sets out the most recent common errors traders have been making. and further guidance to aid traders. This has been shared with traders.
| Common Error | Guidance |
|
Low risk consignments with no accompanying commercial documents |
Low BTOM risk category consignments must come with relevant commercial documents from the supplier.
You do not need to provide a health certificate. Low risk consignments will not be subject to routine documentary, identity and physical checks. However, from 30 April 2024 checks may still be undertaken where intelligence indicates a specific risk. Guidance on what a commercial document accompanying a low risk should contain is available here for animal products for human consumption. |
| Composites being incorrectly categorised | Goods are being incorrectly identified as composite products, and therefore classified as low risk when this is not the case. Ensure your exporter has confirmed that product is a composite following the process set out here. |
| Multiple health certificates attached to a single pre-notification.
|
Generally, each health certificate should be attached to a single import notification. This means a mixed load containing multiple medium risk goods should have multiple import notifications.
‘Compound’ products (a single product containing medium risk POAO which does not meet the definition of a composite) would be treated differently. Further guidance on ‘compound’ products is forthcoming. |
|
Different risk categories (low/medium) on the same CHED |
A separate pre-notification should be submitted for any low risk products included in a load. These should not be added to a medium risk notification.
Different low risk products can be notified on the same CHED only if: · They are travelling to the same initial destination in GB · They arrive on the same means of transport Different medium risk products can be combined onto a single CHED so long as the above requirements are met and they are covered by a single EHC. Compound products with multiple EHCs for a single physical product are treated differently, see here. |
| Description of goods box on CHED P does not match EHC. E.g. Net weights, gross weights, commodity codes, package numbers and package description (e.g. pallets, boxes, crates). | The BCP inspector will need to be satisfied that the health certificate and/or commercial documents relates to the CHED notification, and so would advise notifying in a way which best supports identification and matches the health certificate and/or commercial documentation. Note: if a physical check is conducted the inspector will check that the product matches what has been declared and certified. |
| Consignee details on CHED P do not match EHC
|
Consignee details across the CHED and EHC should be consistent.
From April, it will be possible to notify the PHA of changes to the consignee information that take place after a certificate has been issued, without the need for a replacement certificate to be provided. |
| Consignor details on CHED P do not match EHC | The consignor details set out in the CHED and EHC should be consistent, including spellings and abbreviations. Note: For goods imported under the Certification Logistics Pilot (CLP) this may not match from CHED to EHC. |
| EU address being provided for the operator responsible for the consignment instead of a UK address.
|
The operator responsible for the consignment is the person responsible for completing and submitting the CHED in IPAFFS, they may be the importer or a person acting on the importer’s behalf. Importers and EU/EFTA-based producers and exporters, who are responsible for the end to end import process, for example Delivery Duty Paid, must establish a registered UK business premises or office or appoint a representative who is based in the UK, such as a customs clearing agent, if they do not have a physical presence in the UK. |
| Not completing the establishment field in the CHED
|
The establishment of origin should be included the import notification |
| Signed and Verified Electronic PDF certificates in TRACES that have been altered to add electronic versions of physical stamps and electronic versions of wet signatures. | Signed and Verified Electronic PDF certificates in TRACES should not be altered in any way.
|
| Data missing from the model health certificate
|
The model health certificates cover all of the import requirements for animals and animal products in Great Britain, the Channel Islands and the Isle of Man.
You must not directly copy the model health certificates provided on GOV.UK. Competent authorities should create their own official documents for use by exporters. These should include all the information from the model certificates |
| Region of origin displayed on CHED but missing on Part one of the EHC
|
This is required to be completed and correct before the import notification is submitted
|
| Attestations incorrectly deleted and information not included | Attestations need to be deleted correctly with all the relevant information required included in the attestation.
|
| Region of origin not completed correctly
|
Please see link to guidance EU and EFTA countries approved to export animals and animal products to Great Britain – data.gov.uk
|
| Local authority given as name of city or area rather than an actual local authority
|
This should be the organisation responsible for issuing and overseeing the certification. It is not always a local authority that does this. In such cases the central and local authority are the same organisation and this should be reflected here.
|
| EHC signed and dated after dispatch date
|
Certificate must always be signed and issued on or before the date of dispatch. The only exception to this would be a cancel and replacement (C&R) certificate, if one has been permitted by the Port Health Authority. The C&R would then be cross linked and referenced to the original certificate and date of issuing and the original must be signed in advance of dispatch. Note: For animal products the time of dispatch is not required in the EHC |
| Attestation incorrectly deleted
|
Check attestations are completed in accordance with the model certificate ‘notes for completion’ and all non-applicable attestations are correctly deleted or omitted from the certificate.
Deletions carried out by hand must be initialled and stamped. If completed electronically as a verifiable PDF the signature and stamp per page is sufficient. |
|
Incorrect model certificate provided |
Competent authorities in EU countries must provide a health certificate to exporters of animals and animal products to Great Britain (England, Scotland and Wales), the Channel Islands and the Isle of Man.
The model health certificates cover all of the import requirements for animals and animal products in Great Britain, the Channel Islands and the Isle of Man. You must not directly copy the model health certificates provided on GOV.UK. Competent authorities should create their own official documents for use by exporters. These should include all the information from the model certificates. Certain consignments have been imported using certificates bearing the ‘model certificate only’ watermark that have been downloaded from Gov.uk. If your product is medium risk and no EHC is provided for it on Gov.uk, you may need an import license or authorisation. More detail is available on Gov.uk If your product is medium risk and an EHC is provided for it on Gov.uk but you are unable to obtain an EHC from an EU competent authority, you should contact imports@APHA.gov.uk |
| Signature errors
|
If a paper certificate is used it must bear the signature and stamp of the certifying officer. Verifiable PDF certificates must bear a valid digital signature. |
| Pages not numbered or numbered incorrectly | All pages of the certificate must be sequentially numbered.
|
| No regionalisation code provided
|
If a product is subject to regionalisation measures, you must include the correct regionalisation code as selected from the list on Gov.uk |
The common errors listed in the table above can also be found here in HTML version should you wish to share them
For information only: Trader emails
Since our last newsletter we have sent these emails to traders
createsend.com/t/y-F48EB0D8DA8E2F1B2540EF23F30FEDED
createsend.com/t/y-6ED250320392BF822540EF23F30FEDED
createsend.com/t/y-0BF17750F3D2116C2540EF23F30FEDED
createsend.com/t/y-AF467C2F789DF3D52540EF23F30FEDED
createsend.com/t/y-29608CA5946BD26B2540EF23F30FEDED
| Economics & Public Policy | British Embassy Madrid
Torre Emperador, Paseo de la Castellana, 259D | Madrid | 28046 |
Atentamente,
Martín Fernández
Secretario Técnico
FETEIA
Via Laietana, 32-34, 3º · 08003 BARCELONA
( (+34) 932 689 430