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Alinea Customs Briefing – Guidance for the Agri-Food, Food Distribution and Wholesalers, and Restaurants sector. In accordance with the Border Target Operating Model (BTOM) all imports of composite products entering Great Britain from the European Union must be accompanied by a commercial document completed by your exporter. The details that must be entered on the commercial document are set out below.

Commercial document

This document must travel with the consignment and include the following essential details:

  • A description of the goods, including product type (e.g., ‘cooked meat’) and volume or quantity details, or a copy of the food label.
  • The name of the person or organisation sending the goods.
  • The name of the person or organisation receiving the goods.
  • The address of the premises of origin.
  • The address of the destination premises.
  • A reference identifying the lot, batch, or consignment.
  • The date the consignment was sent.
  • The name and address of the transporter, along with details of the transport method.

Failure to provide this document may result in delays or refusal of entry at the border. We strongly advise you to communicate this requirement with your EU-based suppliers to ensure compliance and smooth processing of your shipments.

Composite products are also deemed to be low-risk and will require an IPAFFS pre-notification and common health entry document (CHED-P), subject to the exceptions set out below. The importing company may submit the IPAFFS notification internally and send Alinea Customs the reference, or they may add Alinea Customs as an intermediary agent to their account, so that our team can complete this on behalf of the company. In order to submit the IPAFFS entry, we will require the following information and documents:

  • Commercial invoice
  • Packing list
  • CMR
  • Port of entrance into the UK
  • Vehicle registration plate
  • Day of arrival into the UK
  • Estimated time of arrival

Alinea Customs are required to enter the CHED number on the import declaration, and the prenotification and CHED should be submitted in advance of arrival and entry into the United Kingdom.

  • Low risk IPAFFS notifications are subject to a £10 common user charge per commodity billed by Defra.
  • The Port Health authorities may also potentially levy an administrative fee for document inspection of the CHED-P.

Derogations from the obligation to submit an IPAFFS prenotification to generate a CHED-P are set out below:

The following composite products, not containing any meat products, shall not be subject to any official controls:

(a) composite products containing less than half of their substance of any other processed product provided such products are:

(i) shelf-stable at ambient temperature or have clearly undergone in their manufacture a complete cooking or heat treatment process throughout their substance, so that any raw product is denatured;

(ii) clearly identified as intended for human consumption;

(iii) securely packaged or sealed in clean containers;

(iv) accompanied by a commercial document and labelled in English (whether or not it also appears in any other language), so that that document and labelling together give information on the nature, quantity and number of packages of the composite products, the country of origin, the manufacturer, and the ingredient;

(b) composite products listed in Annex II of Decision (EC) 2007/275.

2 .However, any milk product included in any composite products shall only be derived from countries listed in Annex I to Commission Regulation (EU) No 605/2010 (1) , and treated as indicated in that Annex.

Unless the composite product is exempt from official import controls, all EU composite products are in the low BTOM risk category pending further risk assessments from the Department of Food, Environment and Rural Affairs (Defra).

Low risk consignments are not subject to routine inspections, only intelligence led inspections.

If you require any further clarification or assistance regarding these requirements, please do not hesitate to contact our team at Alinea Customs, telephone: +44 (0) 207 101 4242 or email: customs@alineacustoms.com.

Further guidance on importing products of animal origin from the European Union is available: here

Government guidance is available: here.

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