Trading seafood with the EU - what's new in 2022

Seafood businesses have been adapting to trade with the EU since the end of the EU exit transition on 1 January 2021. Additional changes will affect importers and exporters this year. 

Changes for exporters

Since 1 January 2021, businesses exporting seafood to the EU have been compliant with EU rules. From 15 January 2022, the EU animal health rules are changing. The process of exporting to the EU is the same but a different Export Health Certificate (EHC) is now in use on the government portal.

Export Health Certificates certify that goods meet the EU human and animal health requirements. The purpose is to protect human health and animal health from disease carried on imported foods.

So what EHCs are changing?  

The graphic above shows:

• EHC 8270 (Fishery products intended for human consumption) is replaced with EHC 8361 (Live fish, live crustaceans and their products for human consumption).
• EHC 8249 (Live bivalve molluscs, echinoderms, tunicates, gastropods intended for human consumption) is replaced with EHC 8364 (Live bivalve molluscs, echinoderms, tunicates, gastropods and their products intended for human consumption).

These new certificates do not just replicate the old certificates. They introduce many changes which businesses need to become familiar with. Most of the changes relate to information needed to improve traceability and biosecurity. There are more significant changes for aquaculture businesses.

Scallops and processed shellfish are reclassified from ‘Fishery products’ to ‘Live bivalve molluscs and their products’. This brings these products in the scope of greater disease controls.

There is a new rule intended to control the spread of animal disease. Certain species are ‘listed’ as being at risk of carrying disease, or a ‘vector’ for the disease of another species. These ‘listed’ and ‘vector’ species must be inspected and certified as disease free by an official veterinarian before export to the EU.   

This new rule will not apply where there is no risk of the spread of disease such as:

• any wild caught product landed by a fishing vessel;
• non-listed and non-vector bivalves mollusc species;
• any bivalve mollusc products (dead/processed) for direct human consumption, wrapping or packing. For example, not for further processing as the waste could spread disease;
• gastropod, tunicate and echinoderm species, exported alive or dead.

Changes for EU packaged goods returning to the EU
There is a difference for seafood packaged in the EU which passes through Great Britain to another EU country without further processing. These products cannot use the certificates listed above, as they require some processing to have occurred. A new EHC 8461 is available for these products.  

Read our full guidance on the changes required by the new EHCs 

Changes for importers

Import controls on seafood entering Great Britain from the EU were delayed to allow businesses to prepare. There are 3 changes coming throughout the year.

Customs declaration and IPAFFS notification
From 1 January 2022 goods imported from the EU need customs declarations before leaving the EU.

If you are importing seafood, you must notify the enforcement authorities before your goods arrive in Great Britain. You must do this using the online Import of Products, Animals, Food and Feed System (IPAFFS). Make sure you pre-notify your consignment at least 4 hours in advance of it arriving into Great Britain. The 4-hour rule will remain in place until 30 June 2022.

IPAFFS  generates a reference number for use on the customs import declaration. Without the reference number, your customs agent can’t complete the declaration. This might delay the departure of your consignment.

Border Control Posts (BCPs) and health certificates
From 1 July 2022 all seafood will have to be imported through a point of entry with a suitable Border Control Post (BCP).

From 1 November 2022, consignments from the EU must be accompanied by a health certificate. BCP officers may carry out checks on the consignment. We expect the Government to provide more information on the requirements later in the year.

Transits through Great Britain
Products of animal origin, including seafood, that are transiting from the EU to Great Britain and back to the EU are covered by sanitary and phytosanitary requirements. These are laid down in retained EU law.

New import controls were introduced on 1 January 2022 for products of animal origin (POAO) and animal by-products (ABP) for land-bridge transits from continental EU countries to the island of Ireland via Great Britain. POAO and ABP from continental EU countries to the island of Ireland via Great Britain will need to be pre-notified on IPAFFS at least 4 hours before they arrive into Great Britain. You will also need to inform Defra by email once the consignment has left Great Britain. The goods can enter and exit Great Britain through any point of entry until 30 June 2022.

POAO and low risk ABP moving from the island of Ireland to continental EU countries via Great Britain are exempt from these new requirements until further notice. There is more information on the requirements in the UK Government guidance Transiting animals and animal products through Great Britain.

Advice and guidance

With more changes coming this year, our regulation experts are here to help seafood businesses. If you need more information or some guidance, please email regulation@seafish.co.uk 

We are updating our EU Exit guidance on our website as changes are confirmed. Follow the links below for more detail on the new requirements: