I import seafood to Great Britain
Last updated: Wednesday 4th November 2020
1. How can I avoid delays at the border?
Most delays at the border can be avoided by obtaining the necessary authorisations and providing properly completed documents at the right time. It is important to liaise with your overseas counterpart so that the exporter understands the documentary requirements.
Authorised Economic Operator (AEO) status gives quicker access to some simplified customs procedures and, in some cases, the right to ‘fast-track’ your shipments through some customs procedures. There is guidance on achieving AEO status on the HMRC website.
If you import from the EU you may be able to use Simplified Customs Declarations.
2. How will UK border requirements change?
There will be minimal change in the short term to current veterinary controls and requirements for notifications for seafood, including live seafood, imported directly from third countries outside the EU. The only difference will be that importers or their agents will have to use a new import notification system, called the Import of Products, Animals, Food and Feed System (IPAFFS), which will replace TRACES. The requirement for health certification and catch certification will remain unchanged.
With direct imports of seafood from EU countries, the UK is introducing requirements and controls in three stages. Seafood listed as requiring a catch certificate (see the list here) in illegal, unreported and unregulated (IUU) regulations will require a catch certificate (and a processing statement or storage document if appropriate) from 1 January 2021. From 1 April 2021 all seafood from the EU will require a health certificate, and has to be notified via IPAFFS, but does not have to be imported through a Border Control Post (BCP). Documentary checks may take place remotely. From July 2021, there will be import checks at Border Control Posts (BCPs) on seafood from the EU. Consignments from the EU will have to be imported via a point of entry with an appropriate BCP.
A catch certificate and any supporting documents, validated by the country of export, will be required for most consignments of wild-caught seafood imported from the EU or elsewhere and for fish and fishery products landed directly into Great Britain by a non-UK flagged vessel. If the fish you’re importing into Great Britain has been caught by a vessel flagged to a country other than the exporting country, you will need the following documentation:
- If it has been stored for more than 12 hours, you’ll need a copy of the catch certificate and a storage document from the exporter;
- If it has been processed, you’ll need a copy of the catch certificate and a processing statement from the exporter – this must be filled in by the processor and endorsed by the authority in the country of processing.
To ensure efficient clearance of your consignment, you should provide the catch certificate to the port of entry in advance or at the time of your consignment’s arrival. If this is not possible, you should check with your port of entry. Some ports may agree to complete the checks if you provide them with electronic catch certificate documents, provided that hard copies of the documents follow.
If your product is listed in Annex I of the IUU Regulation, it is exempt from the catch certificate requirement. You should ensure that the accompanying commercial documents contain information to support your claim that no catch certificate is required, such as documentary evidence that the product is of aquaculture origin.
Non-UK vessels, including EU vessels, intending to land their catch in the UK will need to follow the same rules that will apply to UK-registered vessels accessing an EU port. For example, they’ll need to give notice of their plans to land. Fish must be landed in a designated UK port. EU vessels fishing in the NEAFC Convention Area and landing into the UK will need to complete a Port State Control form.
There will be new import requirements for imports of seafood from non-EU countries that arrive in GB via an EU country. They are described below in question "Will importing from outside the EU via the EU change?" The requirements will apply from the date when the UK leaves the EU.
3. What checks will take place at the UK border?
Checks on seafood imported directly from non-EU countries, and payment for the checks, will remain as they are currently. While there are no immediate plans to change the frequency or nature of the checks, this may be revised in the future on the basis of the UK-specific risk.
Seafood from EU countries will have to be accompanied by a catch certificate (and a processing statement or storage document if appropriate) from 1 January 2021. Products listed in Annex I of the IUU Regulation are exempt. Other requirements and checks will be staged as follows.
From 1 January 2021 to 31 March 2021, seafood from EU countries will not be subject to veterinary checks and will not have to be imported via a Border Control Post (BCP).
From 1 April 2021 to 30 June 2021, seafood from EU countries will require notification via IPAFFS and health certification. The import will not have to take place via a Border Control Post (BCP). Documentary checks may take place remotely.
From 1 July onwards, seafood from EU countries will require notification via IPAFFS and health certification, and will have to be imported through an appropriate BCP.
The Port Health Authority at the point of entry will charge the importer (or the ‘person responsible for the consignment’) a standard fee for the checks. If the consignment requires further checks, for example if the consignment is subject to intensified official controls, these will be charged to the importer.
4. Will importing from outside the EU via the EU change?
If there is no future agreement negotiated with the EU beyond the Withdrawal Agreement, there will be new requirements for imports of seafood from non-EU countries that move through the EU before arriving in Great Britain.
Seafood that is cleared for free circulation in the EU (and Liechtenstein, Norway and Switzerland) and subsequently imported into the UK will be treated as an import from the EU.
Seafood intended to transit through the EU must enter the EU territory via a Border Control Post (BCP). Each consignment will need a Common Health Entry Document (CHED) (generated by the exporter on TRACES NT) and will be subject to documentary and identity checks. If there is any suspicion of non-compliance with the EU’s requirements on animal health or food safety, it may undergo a physical check.
The consignment must be directly transported under customs supervision, without the goods being unloaded or split. It must leave the EU via the BCP named in the CHED and it must reach this BCP within 15 days.
The officers at the exit BCP will carry out an identity check to ensure that the consignment corresponds to the consignment referred to in the CHED. In particular, they verify that the seals fixed on the vehicles or transport containers are intact. The outcome of the controls are recorded in Part III of the CHED and in the EU’s Information Management System for Official Controls (IMSOC).
The seafood will have to be imported through a GB BCP to ensure that the necessary checks are carried out. Importers will need to notify the UK authorities using the new import notification system (the Import of Products, Animals, Food and Feed System, IPAFFS), which will replace TRACES. The UK requirements will apply from the end of the transition period (1st January 2021). However, some aspects will not take effect until April 2021 or July 2021 – see the question above for details on the phased introduction of controls.
5. Will importing live animals for aquaculture change?
See ‘I catch or farm seafood' guide.
6. Will controls on wooden packaging change?
Yes. From 1 January 2021 all wood packaging material (WPM) entering Great Britain may be subject to controls to check if it meets ISPM15 international standards. The standards apply to solid wood packaging such as pallets, packing cases, boxes, crates and dunnage (loose wood used to protect goods and their packaging). They don’t apply to processed woods like plywood, raw wood less than 6mm thick, cardboard or certain other packaging.
Checks on WPM will continue to be carried out in Great Britain on a risk-targeted basis only. The plant health risk from WPM imported from the EU and Northern Ireland is considered low.
If the packaging fails an inspection and you’re given the option to treat it, you can either:
- find a company authorised to carry out treatment to ISPM15 standards
- send the wood packaging back to the supplier
7. What labelling should I have on the consignment?
The consignment presented for import will need to display clearly a legible and indelible identification mark (‘health mark’). The mark must indicate the approval number of the establishment and the country of origin. Inspectors should be able to see the mark without having to break the packaging.
8. Will imported products have to be labelled differently?
The current EU labelling Regulations will be rolled over into national legislation. For seafood originating in an EU member state, ‘EU’ can continue to be used as a country of origin. All pre-packed food imported into Great Britain will need to be labelled with the name and UK address of the business operator under whose name the food is marketed, as this is the business operator responsible for the product regardless of the actual producer. An EU address alone would no longer be valid for the UK market.
More detail can be found in the government guidance on ‘Food labelling and packaging ’.
Customs and Tariffs
9. How will Customs requirements change?
If you have been importing from non-EU countries, you will already have arrangements in place with HMRC and these will remain unchanged.
If you want to import from an EU country, you will have to apply the same customs rules to goods moving between the EU and the Great Britain as currently apply in cases where goods move between a country outside of the EU and the UK. There is guidance on this in the UK government’s Border Operating Model document.
Actions to take in preparation for the future
- Register for a GB Economic Operator Registration and Identification (EORI) number.
- Decide if you want to make customs declarations yourselfor appoint a Customs Intermediary. If you decide not to use an intermediary, you will need to make declarations yourself. To do this you will need to access HMRC systems and to purchase software. You could be entitled to financial help to help your business complete customs declarations.
- Apply for a Duty Deferment Account (DDA). This enables customs charges including customs duty to be paid once a month through Direct Debit instead of being paid on individual consignments.
- Prepare to pay or account for VAT on imported goods. VAT registered traders will be able to account for import VAT on their VAT return by using postponed VAT accounting from 1 January 2021. Unless they are eligible to defer their supplementary declarations, they will not be compelled to use postponed VAT accounting.
- Ensure drivers have correct International Driving Permits. For example, an international driving permit (IDP) or an additional licence may be required to drive in some countries. More information will be provided on GOV.UK as the requirements are clarified.
- Additional actions for Customs and VAT processes:
- Check suitability for facilitations Section 1.1.5 and Section 4.1.5. of the Border Operation Model document that will make processes smoother.
- Find the right commodity code for your goods.
- Businesses importing goods into GB should ensure they are familiar with using the ‘Trade with the UK’ tool which provides detailed information on tariffs, taxes and rules. The tariffs shown are those currently being applied until 1 January 2021. Use the UK Global Tariff tool to check the tariffs that will apply to goods imported from 1 January 2021.
- Check whether any duty relief schemes apply- these let you pay less (or no) duty on imports.
- Consider commercial arrangements (Incoterms). Individual commercial contracts and arrangements may alter the default legal responsibilities and requirements. Contractual obligations for international commercial transactions are outlined in the Incoterms rules, which are administered by the International Chamber of Commerce.
10. Do I need an EORI number?
Yes, in order to trade with the EU after the end of the transition period you will need a UK Economic Operators Registration and Identification (EORI) number. You might also need an EU EORI number.
A UK EORI number will allow you to import goods into the UK. It will allow you or your agent to submit the necessary customs declarations and to apply for customs simplification procedures. Your UK EORI number will start with ‘GB’ and be followed by 12 digits which will include your VAT number. You may already have a UK EORI number if you trade with non-EU countries.
Obtain a UK EORI number by visiting the GOV.UK website
You’ll need an EU EORI number only if your business will be making customs declarations or getting a customs decision in the EU. Apply for an EU EORI number from the customs authority in the EU country where you submit your first declaration or request your first decision.
11. Will I need a customs agent?
Most businesses use a customs broker/agent or freight forwarder to make customs declarations for them. This can make importing simpler and faster and can reduce the risk of delays at the border.
It is possible to make your own customs declarations if you have the appropriate qualification and use approved software. Given the complexity of the process, this approach is generally better suited to the more experienced exporter but can be more cost effective than using an agent. Grant funding has been made available to help UK businesses complete customs declarations themselves, in preparation for the end of the transition period.
12. How do I check import tariffs?
HMRC publishes tariff data online, which importers will be able to continue to use to check tariffs on imported goods.
After the end of transition, there will be a number of changes to tariffs. The trade tariffs that will apply from 1 January 2021 can be checked on the UK Global Tariff website.
13. What will happen to EEA trade agreements?
Iceland, Liechtenstein, Norway and Switzerland trade with the EU under a free trade agreement. UK trade with these countries will be treated as trade with EU member states in accordance with such agreements during the transition period.
The UK Government has concluded trade agreements with the Faroes, Liechtenstein and Switzerland as well as some other non-EU countries. This will allow imports from these countries to continue with minimal changes after the transition period ends. Trade agreements with Iceland and Norway have been agreed in part. These agreements cannot be concluded until the exact nature of the UK–EU relationship is known. View the latest information on signed trade agreements.
14. Will the EU free trade agreements still work for UK imports?
No, the UK will no longer be a party to these agreements after 1 January 2021. However the UK has been making arrangements with these countries to ensure that trade continues under similar conditions following a no-deal exit. UK businesses should refer to government guidance on ‘Existing trade agreements with non-EU countries’ for the latest developments.
Some agreements will not be in place by the end of the transition period. In this case, imports from these countries would take place on World Trade Organization (WTO) terms using ‘Most Favoured Nation’ (MFN) tariffs as detailed in the UK Global Tariff.
15. Will there be mutual recognition of EU goods?
No, foods in the European Economic Area (EEA) that are compliant with EU requirements are not automatically recognised as compliant with UK requirements.