I import seafood to Great Britain
Published: Wednesday 4 November 2020
Content updated: Tuesday 16 March 2021
- Amendment to answers in questions 1, 2, 3, 4, 6, 8, 9, 10, 11 and 12
- Added new question and answer; question 13
- Amended order of questions, question 13 onwards
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 customs procedures and, in some cases, the right to ‘fast-track’ your shipments through certain customs procedures. There is guidance on achieving AEO status on the HMRC website.
2. How will GB border requirements change?
Importing from outside the EU into Great Britain
There will be minimal change to current veterinary controls and requirements for notifications for seafood, including live seafood, imported directly from countries outside the EU.
- The new import pre-notification system, called the Import of Products, Animals, Food and Feed System (IPAFFS), which has replaced TRACES, is already in use for seafood imports from outside the EU.
- The current health certificates used by non-EU countries will remain acceptable in the UK until 1 April 2021. New health certificates will have to be used from 1 April 2021 onwards for all seafood imports arriving in Great Britain from non-EU countries. View the UK Government collection of health certificates. Our understanding is that current ‘EU’ health certificates accompanying goods still en route to GB and arriving after 1 April 2021 will be accepted, as long as they are dated earlier than 1 April 2021.
- The catch certification requirement is already in place and remains unchanged.
Importing from EU member states into Great Britain
A validated catch certificate and any supporting documents are required for most consignments of wild-caught seafood imported from the EU or elsewhere. Catch certification is also required for most fish and fishery products landed directly into Great Britain by non-UK flagged vessels.
If the fish you’re importing into Great Britain was originally caught by a vessel flagged to a country other than the exporting country, you will need the following documentation:
- An original catch certificate;
- 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; or
- 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 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 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 need to complete a Port State Control form.
There are 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 '4. Has importing from outside the EU via the EU changed?'
An export health certificate is required to accompany all seafood intended for importation from the EU into GB (except for certain composite products) from 1 October 2021 onwards. The health certificate to be used is available from the UK Government collection of health certificates.
A staged introduction of requirements for imports from the EU
With direct imports of seafood from EU countries, the UK is introducing requirements and controls in three stages.
From 1 January 2021 consignments of seafood requiring catch certification (according to illegal, unreported and unregulated (IUU) regulations) have to be accompanied by a catch certificate (and a processing statement or storage document if appropriate).
From 1 October 2021 all consignments of seafood from the EU will require a health certificate, and have to be notified via IPAFFS, but they do not have to be imported through a Border Control Post (BCP). Documentary checks may take place remotely.
From 1 January 2022, 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.
3. What checks take place at the UK border?
Checks on seafood imported directly from non-EU countries, and payment for the checks, have remained largely unchanged. There are plans to lower the frequency of checks carried out on some consignments from the EU on the basis of the UK-specific risk.
Since 1 January 2021, seafood from EU countries has had to be accompanied by a catch certificate and, where necessary, a processing statement or a storage document. Products listed in Annex I of the IUU Regulation are exempt. Other requirements and checks are staged as follows:
From 1 January 2021 to 30 September 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 October 2021 to 31 December 2021, seafood from EU countries will require health certification and pre-notification via IPAFFS. The import will not have to take place via a Border Control Post (BCP). Documentary checks may take place remotely.
From 1 January 2022 onwards, seafood from EU countries will require health certification and pre-notification via IPAFFS, 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. Has importing from outside the EU via the EU changed?
Yes, there are 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 is recorded in Part III of the CHED and in the EU’s Information Management System for Official Controls (IMSOC).
The seafood will then have to be presented to a GB BCP that is approved to handle the category of seafood you intend to import. Importers will need to:
- notify the UK authorities using the pre-notification system (Import of Products, Animals, Food and Feed System, IPAFFS),
- ensure that an export health certificate accompanies the shipment, and
- provide catch certification where necessary.
5. Has importing live animals for aquaculture changed?
See ‘I catch or farm seafood' guide.
6. Have controls on wooden packaging changed?
Yes. 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. Do imported products have to be labelled differently?
The EU labelling Regulations has been 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 needs 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. There is a grace period: you can continue to use an EU, GB or NI address for product sold in GB until 30 September 2022.
More detail can be found in the government guidance on ‘Food labelling: giving food information to consumers’.
Customs and Tariffs
9. How have Customs requirements changed?
If you have been importing directly from non-EU countries, you will already have arrangements in place with HMRC and these will remain unchanged.
If you import non-EU goods via an EU member state, and clear customs in the member state, you are likely to lose any trade preference on those goods, and you will have to pay the full import duty on entry into the UK. To maintain the trade preference, you will need to ensure that the goods are not customs cleared in the EU by using an appropriate customs procedure (such as temporary storage, customs warehousing and/or customs transit).
If you want to import from an EU country, you will have to follow the same customs procedures that apply to importing goods from a country outside of the EU. For example, you will have to make a customs import declaration and pay the tariffs that apply. There is guidance on this in the UK government’s Border Operating Model document.
Seafood originating in the EU can be imported into the UK tariff free under the terms of the UK–EU Trade and Cooperation Agreement (TCA). You can check Seafish online information on trading seafood under the TCA.
Actions to take in preparation for importing
- Register for a GB Economic Operator Registration and Identification (EORI) number.
- Decide if you want to make customs declarations yourself or 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 you need a UK Economic Operators Registration and Identification (EORI) number. You might also need an EU EORI number.
A UK EORI number allows you to import goods into the UK. It allows 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 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.
12. How do I check import tariffs?
HMRC publishes tariff data online, which importers can continue to use to check UK tariffs on imported goods.
13. How can I avoid paying the full tariff?
The main ways to avoid paying the full tariff on an import by taking advantage of a preferential trade agreement, using the Generalised Scheme of Preferences (GSP), or using a tariff quota or duty suspension.
The UK has negotiated preferential trade agreements with several of its trading partners, including the EU, allowing the importation of tariff-free or low-tariffed seafood from those countries. The UK government website has information on the UK’s trade agreements. You can also check Seafish information on trading seafood with the EU under the UK–EU Trade and Cooperation Agreement.
The UK’s GSP reduces or removes rates of duty (tariffs) on imports into the UK from eligible developing countries. There is more information on the UK government website’s page on trading with developing nations.
Tariff quotas and duty suspensions have been made available for the tariff-free or low-tariffed importation of seafood intended for further processing in the UK. The zero or reduced tariffs are applicable irrespective of the origin of the seafood. There are duty suspensions for 2021 on fresh cod and haddock; frozen cod, haddock and hake; and frozen fillets of some species, but not frozen cod fillets. The full list of duty suspensions is available in The Suspensions of Import Duty Rates Document Version 1.1. Tariff quotas are listed here Tariff Quotas, version 2.0 (see in particular page 23).
14. What is the status of EEA trade agreements?
Iceland, Liechtenstein, Norway and Switzerland trade with the EU under a free trade agreement.
The UK Government has concluded trade agreements with the Faroes, Liechtenstein and Switzerland as well as some other non-EU countries. This allows imports from these countries to continue to enjoy preferential tariffs. Continuity trade agreements with Iceland and Norway have also been agreed. View the latest information on signed trade agreements.
Note that the rules of origin that have been written into these trade agreements do not offer the same flexibility in terms of cumulation that was available previously. Processing Norwegian fish in the EU, for example, may result in a tariff being payable on import into the UK.
15. Do the EU free trade agreements still work for UK imports?
No, the UK is no longer a party in these agreements. The UK has made separate arrangements with several trading partners to ensure that trade continues under similar conditions following a no-deal exit. UK businesses should refer to government guidance in ‘Existing trade agreements with non-EU countries’ for the latest developments.
Some of the EU’s free trade agreements have not been replicated. If there is no other preferential agreement, imports from these countries can continue on World Trade Organization (WTO) terms using ‘Most Favoured Nation’ (MFN) tariffs as detailed in the UK Global Tariff
16. Is there 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.