Since the start of this year, food businesses need to apply for an export health certificate (EHC) – a legal document confirming certain information, health standards and regulations have been met – so that products of animal origin (POAO), including salmon, trout and seafood, can be exported from Scotland to the EU and Northern Ireland.
Our Deputy Chief Executive, Ian McWatt, answers some frequently asked questions about the export health certification process.
Who is responsible for what?
Exporting food businesses are responsible for initiating the EHC application process with the Animal Plant Health Agency (APHA), using the online service. This includes completing all necessary online paperwork, and making sure that your POAO export consignments are compliant with regulations.
Every consignment for export to the EU from the UK requires an EHC.
It is the responsibility of food business owners to make sure your staff are trained in how to complete the EHC properly.
To help exporters and certifiers become familiar with the requirements for EU export EHCs, Notes for Guidance have been published with each commodity EHC on the Animal and Plant Health Agency’s EHC Form Finder.
Food Standards Scotland (FSS) provides a supplementary EHC service at three logistics hubs in North and South Lanarkshire: DFDS in Larkhall, Mesquen in Harthill, and O'Toole International Logistics Ltd in Bellshill.
Certifying Officers (COs) and Certification Support Officers (CSOs) employed by FSS, and local authorities (on request and for exports to non-EU third party destinations), sign the completed EHC after checks.
What are the key challenges?
We are all learning how to manage the considerable burden of this new bureaucracy on exporting food products. These early days are not an easy time for any of us as we adjust to the new requirements in place for EHCs.
A number of issues have emerged in recent days, which include:
Properly completed paperwork in Scotland results in less checks overseas, so it is paramount the industry accurately completes the necessary paperwork to avoid delays.
There is also a significant risk that combined loads could be refused because of inaccuracy from one operator, so there is a collective responsibility here to ensure clearance for whole consignments.
Communication is key to ensuring load numbers and EHC numbers link together, and we all need to familiarise ourselves with new terminology. Examples of communication issues include:
- EHCs being completed by the COs, but hubs later advising that these are not required
- No common terminology to identify a specific load, leading to delays in reconciliation
- Lack of agreement currently in place regarding the saving and sharing on final EHC information
Administration and IT
Delays have occurred as a result of equipment being sent to the wrong address. Various issues have also been reported relating to lack of access to printers and internet connectivity problems.
Examples of further technical and operational issues include:
- Issues with the EHC platform related to numbering and references, resulting in the CO needing to complete entries manually, which takes time
- EHC being returned by the FBO for amendment following changes to product, weights etc., resulting in a new EHC having to be issued
- Lack of clarity regarding the differences between batch and harvest codes
- Daily schedule of loads not being provided in advance
What’s FSS doing to help?
FSS is supporting the three logistics hubs in improving efficiency of operations as priority, including meeting the hub management teams regularly to discuss issues.
FSS has the necessary veterinary capacity at the hubs and we are continuing to work closely with businesses and organisations to ensure that we are all doing everything possible to minimise delays and expedite product journeys.
It is in both industry and government’s shared interest to get Scottish food and drink products to key markets in the EU without undue delay.
In order to improve efficiency, we have called on industry to invest time training staff in how to generate the EHC and supporting documentation. We also ran industry webinars on 8 January 2021 with further guidance.
What else do I need to know?
The EHC journey involves significant preparation and input by food business operators. It’s important to remember that there is no ‘one size fits all’ approach to the EHC signing process.
Food business operators preparing products for export need to ensure that all documents are completed and staff are familiar with the EHC process, to help the delivery go smoothly.
Please make sure you are prepared with all the necessary information on load size, type, destination, and planned logistics, and able to provide this in advance. This is not a rubber stamping exercise and we want to avoid loads being rejected. It is far better for problems to be identified and resolved here in Scotland and not have consignments being turned back hundreds of miles away or refused when they arrive at the end of their journey.
Remember to set realistic expectations – this is a new process for us as well and not our primary role. We must all work together to overcome the current challenges.
Finally, I would like to extend my support and thanks to staff and the industry for everything that you have been doing under extremely taxing circumstances. Thank you for your continued support during this challenging time.
More guidance is available on our food and drink exports page.