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RCVS Council agrees to prepare time-limited supplementary guidance on export health certification in case of no-deal Brexit

23 October 2019

The Council of the Royal College of Veterinary Surgeons (RCVS) has agreed to an urgent request from the Animal and Plant Health Agency (APHA) to prepare supplementary guidance on certification for veterinary surgeons in case of the ‘extraordinary’ circumstances that might be seen if the UK leaves the EU without a deal.

The supplementary guidance [see below] would relate specifically to the veterinary export health certification of groupage consignments, ie those which contain multiple low-risk food product types in a single consignment, for export to, or transit through, the EU.

Currently, Export Health Certificates (EHC) are not required for such consignments; however, in the event of a no-deal EU Exit, the UK would assume third-country status and be required to develop a scheme to enable the substantial volume of these product export/transit arrangements to continue.

Such low-risk products would include products of animal origin for human consumption, eg composite products like pizzas and quiches, meat products and processed milk, along with processed pet food; they would not include products like fresh meat, raw milk, raw pet food or live animals.

"Council put in place a number of caveats to preparing its supplementary guidance, including that it would be time-limited, subject to review, and only applicable in the extraordinary circumstances of a no-deal Brexit."

Niall Connell, RCVS President

APHA’s proposed scheme [see 'Related documents' box below] is intended to facilitate the provision of relevant consignment information to the Official Veterinarian (OV) responsible for issuing the EHC in a manner that meets their professional obligations whilst also accommodating the scale and complexity of the supply chains involved.

The College’s supplementary guidance would recognise that it would be neither practical nor possible for the certifying OV at the point of export to have personal knowledge of all relevant products contained within a groupage consignment. Instead, the scheme would involve the OV relying on a ‘support attestation’ containing:

a. a ‘supplier declaration’ made by a representative of the supplying company who has ‘authority and responsibility’ to do so, such authorisation coming in writing from the managing director or equivalent; and,

b. a declaration by a registered veterinary surgeon (or Certification Support Officer acting under the direction of an OV) carrying out relevant checks in relation to the supplier.

The supplementary guidance would further acknowledge that for such a scheme to be workable, veterinary surgeons would need to place reliance on exporters and suppliers of goods providing batch specific information valid for 30 days (with additional assurance provided by vets carrying out periodic checks of the supplier’s premises and records ).

However, the system would be limited to use only in stable supply chains, with APHA’s implementation of a Trusted Supplier Scheme (TSS) intended to provide confidence in the accuracy of support attestations. Any exporters found to be non-compliant could be immediately removed from the TSS, potentially permanently.

The College’s supplementary guidance would then advise OVs to ensure they read, understood and strictly followed APHA’s new guidance on export health certificates, and would offer the reassurance that, providing they act with integrity and adhere to the guidance, no personal liability would attach to them in the event that the information contained with a supplier declaration is incorrect or incomplete.

RCVS President Niall Connell stated: “In discussions at its October meeting, in which we were pleased to have invited the British Veterinary Association to participate, RCVS Council had some concerns around this departure from our usual guidance and therefore sought a number of clarifications and changes to APHA’s original scheme.

“Whilst acknowledging the steps taken by APHA to address these concerns, Council then put in place a number of caveats to preparing its supplementary guidance, including that it would be time-limited, subject to review, and only applicable in the extraordinary circumstances of a no-deal Brexit.

“It also accepted assurances from APHA that these certification changes would not compromise public health, or animal health and welfare, but would be urgently necessary under no deal in order to be able to maintain the UK’s existing food export arrangements."

The caveats to Council’s agreement with APHA to prepare this supplementary guidance are as follows:

  • It would only applied in the event that the UK were to leave the EU without a deal;
  • It would be a temporary, time-limited measure, as a result of these exceptional circumstances;
  • RCVS Council would review this guidance within 12 months of its implementation; and
  • The scope of the guidance would be strictly limited to the process for issuing Direct Export or Transit Export Health Certificates for groupage consignments containing low risk products being exported to, and transiting through, the EU.

Apart from the specific situation that would be set out in the supplementary guidance, the rest of the RCVS guidance on veterinary certification would continue to apply.

Supplementary guidance

Certification of groupage consignments for distribution in, or transit through, the EU in the event of a no-deal EU Exit

1.  Prior to the UK leaving the EU, Export Health Certificates (EHCs) were not required for groupage consignments containing low-risk products being exported to, and transiting through, the EU. In anticipation of the UK’s exit from the EU without a deal, it has been necessary for the Competent Authority to develop a scheme to allow such exports to continue.

2.  This scheme is intended to facilitate the provision of relevant consignment information to the Official Veterinarian (OV) responsible for issuing the EHC in a manner that meets their professional obligations whilst also accommodating the scale and complexity of the supply chains involved.

3.  It is recognised that it is neither practical nor possible for the certifying OV at the point of export to have personal knowledge of all relevant products contained within a groupage consignment. Instead, the scheme involves the OV relying on a ‘support attestation’ containing:

a. a ‘supplier declaration’ made by a representative of the supplying company who has ‘authority and responsibility’ to do so, such authorisation coming, in writing, from the managing director or equivalent; and,

b. a ‘health attestation’ signed by a veterinarian (or Certification Support Officer (CSO) acting under the direction of an OV) carrying out relevant checks in relation to the supplier.

4.  In order for this scheme to be workable, it requires that veterinary surgeons must place reliance on exporters and suppliers of goods providing batch-specific information valid for 30 days (with additional assurance provided by vets carrying out periodic checks of the supplier’s premises and records). The system will be limited to use in supply chains that are stable, implemented via a trusted supplier scheme.

5.  While this arrangement is somewhat of a departure from the RCVS Principles of Certification, RCVS Council has accepted that this departure is necessary to meet the extraordinary circumstances arising out of a ‘no-deal’ EU Exit, but only on the following basis:

  • It is only applied in the event the UK leaves the EU without a “deal”
  • It is a temporary, time-limited measure, as a result of these exceptional circumstances
  • RCVS Council will review this guidance by October 2020
  • The scope is strictly limited to the process for issuing Direct Export or Transit Export Health Certificates for groupage consignments containing low-risk products being exported to, and/or transiting through, the EU.

6.  It covers products of animal origin (POAO) for human consumption as listed below and processed pet food that is fully packaged for the final consumer (or purchase in the case of pet food)

Included: Composite products , meat products , meat preparations , processed milk/matured or processed dairy products, fish/fish products, eggs/egg products, processed pet food

Excluded: Live animals, germinal products, fresh meat, raw milk, animal by-products (including raw pet food but excluding processed pet food)

(for full definitions see below and also Animal and Plant Health Agency (APHA) guidance)

7.  Veterinarians should read, understand and strictly follow the relevant guidance issued by APHA. ( link to pdf of the APHA guidance )

8.  Veterinarians are to be reassured that in the event that information contained within a supplier declaration is incorrect or incomplete, no personal liability will attach to them providing they have acted with integrity and adhered to the relevant APHA guidance.

9.  Veterinarians are reminded that, apart from the specific situation as set out in this section, the rest of guidance contained within this chapter of Supporting Guidance to the Code of Professional Conduct continues to apply.

Definitions

An Export Health Certificate (EHC) is the official EU export certificate. EHCs are based on an EU model and as such, the wording in this certificate cannot be changed.

A groupage consignment is a consignment containing multiple product types or lines in a single consignment, e.g. multiple composite products, composite products combined with other products of animal origin.

A low-risk product is a POAO for human consumption as listed below and processed pet food that is fully packaged for the final consumer (or purchase in the case of pet food) and produced using only animal content from a traceable network of known suppliers. The following products are therefore classified as low-risk products: composite products, meat products, meat preparations, processed milk/matured dairy products, fish/fish products, eggs/egg products and processed pet food. By way of contrast, the following products are not classified as low-risk products: live animals, germinal products, fresh meat, raw milk, animal by-products (including raw pet food).

A composite product is a product for human consumption containing a both processed products of animal origin and products of plant origin (e.g. sandwiches, pizzas, ready meals, quiches).

A meat product is a processed product resulting from the processing of meat or from the further processing of such processed products, so that the cut surface shows that the product no longer has the characteristics of fresh meat.

A meat preparation is fresh meat, including meat that has been reduced to fragments, which has had foodstuffs, seasonings or additives added to it or which has undergone processes insufficient to modify the internal muscle fibre structure of the meat and thus to eliminate the characteristics of fresh meat.

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