Differences in the new EHCs from January 2022
1. Part II.2 now requires an Official Veterinarian signature
This applies when the fishery product (EHC 8361) is:
- Listed in EU legislation, and,
- Of aquaculture origin or hand gathered from the wild, and,
- If the species is intended for further processing in the EU.
This also applies when the Live Bivalve Mollusc (EHC 8364) is:
- Listed in EU legislation, and,
- Of aquaculture origin or hand gathered from the wild. Or
- Products (of the above) intended for further processing.
In both these cases an OV instead of a Local Authority Officer must now sign certificates when the Animal Health Requirements are not deleted.
Re EHC 8361the EU has clarified the definition of further processing in the EU to include any anatomical change to the fish or shellfish prior to final sale to the consumer – this includes bleeding, gutting, filleting and scaling. The ‘Notes for Guidance’ for this EHC will be updated to reflect the clarification. An Official Veterinarian signature is now required when the shipment is being sent for further processing.
Defra advises that if your fish, shellfish or fishery products will undergo any further anatomical change that produces waste in the EU, then the ‘further processing’ box must be checked. If this box is checked, and your consignment contains fish or shellfish listed in the legislation (for example Atlantic Salmon) and is also from an aquaculture source or is hand gathered, then the EHC must be signed by an Official Veterinarian (OV).
However, if the fish is wild caught and landed onto a fishing vessel or is not a species listed in the legislation, then it can also to be certified by a Food Competent Certifying Officer (FCCO).
If your fish products will not undergo further processing in the EU and are ready for human consumption, then you need to check the box ‘products for human consumption’. If this box is checked then the EHC can be signed by a Food Competent Certifying Officer (FCCO) or OV.
Only one of the main boxes must be checked – either the ‘further processing’ box or the ‘products for human consumption’.
(Labelling for Further Processing can be a secondary label so long as it is legible and visible on the exterior of each box).
2. Clinical inspection and Veterinary Oversight
Where Part II.2 applies
- Veterinary clinical inspection is required 72 hours before loading for the export of live or un-eviscerated fish species. Clinical inspections are also required in some cases for LBM and crustacean species packaged and labelled for human consumption.
- There is a requirement for veterinary oversight of aquaculture establishments to certify the animal health status of the site.
Food Standards Scotland (FSS) additionally advise that producers/suppliers of aquaculture or hand gathered products should ensure they have a Veterinary Animal Health Attestation issued before beginning of January ideally but crucially before 15th January. The Vet Support Attestations can be issued earlier by a vet and can be valid for up to 6 months.
Aquaculture or hand gathered products that are being exported for further processing will need a Veterinary Support Attestation. Without a Vet Animal Health Attestation, the COs in the Hubs will be unable to certify those loads from 15th January. The template for the Vet AHA can be found in the Annex from Guidance ET 197 (Annex II part I): Export Health Certification for Products of Animal Origin Away from the Premises of Origin (defra.gov.uk)
3. Labelling requirement
Where Part II.2 applies, there are new labelling requirements for live bivalve mollusc exports. The label of each container should include an estimated number of the animals.
In addition, FSS advise that labelling will also need to be on the product for the COs to be able to certify. This can be found in II.2.7. Labelling requirements on both EHC 8361 & 8364 (e.g. for salmon from aquaculture certified as for further processing the wording needed is ‘fish intended for further processing in the European Union before human consumption’).
More information on these changes can also be found in this online guide from Seafish: https://www.seafish.org/trade-and-regulation/uk-exit-from-the-eu/changes-to-health-certificates-for-seafood-exports-to-the-eu/
New health certification rules which will apply to seafood exports from GB to the European Union will be mandatory from 15th January 2022. From this date the use of new Export Health Certificates (EHCs) will be required.