Policy paper

How to take part if you have been selected for the Certification Logistics Module Pilot

Published 24 January 2024

This was published under the 2022 to 2024 Sunak Conservative government

This page sets out the rules you must follow if you are a business selected by the Department for Environment, Food and Rural Affairs (Defra) to participate in the Certification Logistics Module Pilot (CLP).

If you do not follow this criteria, you may be unable to continue participating in the pilot.

If you have not been selected by Defra you must not follow this guidance. You should instead read how to complete a health certificate to export to Great Britain.

The following businesses have been selected by Defra to participate in CLP:

• DFDS Logistics Limited
• ECS European Containers
• Foodpol Ltd
• Jan Zandbergen UK Ltd
• KM Distribution Centre Ltd
• Lidl UK Trading Ltd
• Nagel Group Ltd
• Stef Langdons Ltd
• Thermotraffic UK Ltd
• Wabar Limited

Import requirements for participants during the pilot

You must meet import requirements for eligible medium-risk products by following pilot-specific procedures rather than standard import requirements.

When importing eligible goods into Great Britain (England, Scotland and Wales) under CLP you must use an Export Health Certificate (EHC) from the point of origin of the goods rather than the point of dispatch. The point of origin is the final manufacturing or processing site.

The point of origin EHC must be accompanied by additional information specific to the pilot, the trusted trader declaration. This must contain:

• unit-level identifiers to identify the goods included on the EHC travelling on a particular load to Great Britain
• relevant consignee details
• a declaration that you have ensured the safety and security of the goods during their end to end journey

Defra will provide this additional documentation, including the trusted trader declaration, to you directly. The exact nature and form of this documentation will be agreed directly with participants during the pilot phase.

Criteria for the Certification Logistics Module Pilot

To participate in the pilot you must meet criteria for your: 

• consolidation hub sites
• supply chain assurance and traceability
• food safety management system

Consolidation hub sites criteria

Consolidation hubs must export medium-risk packaged products of animal origin (POAO) or animal by-products (ABPs) under the pilot criteria. This excludes high-risk POAO and ABP.

The animal product risk categories are defined by the Border Target Operating Model.

A consolidation hub must be:

• listed to export animals and animal products to Great Britain
• registered or approved by the competent authority of the country it is in, under Regulation (EU) 852/2004 or 853/2004 as applicable to the type of establishment and as required by the regulations and the EHC

The United Kingdom based entity of your business takes responsibility for the EU based consolidation hubs involved in the end-to-end process of the goods’ journey to Great Britain.

Supply chain assurance and traceability criteria

Standard operating procedures must be verified and implemented. The supply chain must allow for products to be easily identified and traced.

Your systems and procedures must allow for:

• products to be traced from the place they were originally processed or manufactured to their intended destination
• consignments and products to be verified at arrival
• products to be rejected, withdrawn, or recalled during intake, storage and dispatch

You must keep records which show you conduct internal audits to check you comply with the criteria of the pilot.

Food safety management system criteria

You must follow hazard analysis and critical control point procedures. 

You must maintain legal temperature controls throughout the process from intake to dispatch for all products and rooms. This includes marshalling areas as well as chillers and freezers.

Products which are intended for sale in Great Britain must be hygienically stored in dedicated areas.

You must have processes to distinguish between products which are eligible for CLP and products which are not eligible for CLP during storage.

The design and layout of the facilities must allow for good food hygiene practices and protect against contamination.

You must keep records which show your procedures and staff are effective and competent. You must keep evidence that staff are trained and supervised.

Requirements for completing an EHC for eligible goods moved under CLP

To use an EHC from the point of origin for your goods under CLP, you will need to make sure the EHC includes some additional information from the certifying officer.

Requirements for completing an EHC for eligible goods to be moved under CLP will remain largely the same as existing guidance on how to complete a health certificate to export to Great Britain. There are some minor exceptions to account for specific requirements for certifying CLP goods.

You will be responsible for making sure that the full documentation and details, including a trusted trader declaration, are uploaded to the import of products, animals, food and feed system (IPAFFS) before the goods being dispatched to Great Britain.

You must include the trusted trader unique reference number that Defra has issued to you in any IPAFFS notifications raised for goods moved under CLP. If you are raising an IPAFFS notification for goods not moved under CLP, you must not include this reference number.

Guidance for certifying officers

The following sections have been developed as guidance for certifying officers in EU member states and European Free Trade Association (EFTA) countries.

How certifying officers must complete an EHC for eligible goods moved under CLP

As a certifying officer, you should complete an EHC as normal except for information about the:

• consignee or importer (usually box I.5)
• place of destination (usually box I.12)

For these boxes you should provide the details of the representative of the CLP participant in the UK.

The actual consignees and place of destination must then be provided by the CLP participant in a separate document, the trusted trader declaration, and in the IPAFFS notification for the goods before they move from the consolidation hub to Great Britain.

From 30 April 2024, you should include the border control post (BCP) (usually box I.16) through which goods will enter Great Britain if known at the time of certification.

If this is not known at the time of certification, provide the BCP that the CLP participant has indicated the goods are most likely to enter through. If issuing through Trade Control and Expert System (TRACES), simply select country and then United Kingdom.

The actual entry BCP must then be provided by the CLP participant in the IPAFFS notification before the goods move to Great Britain from the consolidation hub.

Complete the remainder of the EHC as normal

You should complete the remainder of the EHC with the principles that usually apply when completing Part I of a Great Britain health certificate, as if the goods were intended to move directly from the point of certification to Great Britain.

You should complete the country of origin (usually box I.7) in line with existing guidance by entering the country where the goods were produced, manufactured or packaged.

You should complete the place of loading (usually box I.13) to identify the place where the goods are loaded into their means of transportation to the consolidation hub. This is the place where the goods are being certified.

You should not list the consolidation hub which will be the place of final dispatch to Great Britain for goods moved under CLP. This information will be provided by the CLP participant before the goods move to Great Britain from the consolidation hub.

You should complete the date and time of departure (usually box I.14) and means of transport (usually box I.15) in line with existing guidance. Provide the means of transport and date of departure of the goods as they depart the place where they are being certified.

You do not need to include the final means of transport to Great Britain. This information will be provided by the CLP participant before the goods move to Great Britain from the consolidation hub.

Requirements for incorporating unit-level identifiers for CLP goods into an EHC

Where you issue an EHC for a consignment of goods that will be moved under CLP, unit-level identifiers of the goods being certified must be incorporated in the certification and recorded on the EHC. For example, a list of unique identifiers recording all the pallets, boxes or containers of goods certified under that EHC.

The CLP participant must use these unit-level identifiers later in the process to identify precisely which units from the EHC are moving in any particular load to Great Britain.

The exact nature and format of the unit-level identifiers is up to the CLP participant and their suppliers, but in general must be provided at the level at which goods will be divided at the consolidation hub. For example, pallet-level identifiers if goods are to be divided at pallet-level or box-level identifiers if the goods are to be divided at box-level.

Consignments can only be divided at the consolidation hub at the level of the unit-level identifiers used. For example, if pallet-level identifiers are used, the CLP participant cannot divide pallets down into boxes at the consolidation hub and must keep goods in their original pallets.

How to incorporate unit-level identifiers into an EHC

You should incorporate Unit-level identifiers into the EHC at container number or seal number (usually box I.23).

If goods are appropriately sealed for official recording of seals on the certificate, which should be at the unit-level, the seals should constitute the unit-level identifiers and be recorded as seal numbers. Where the identifiers do not constitute a seal, they should be recorded as container numbers.

If these unit-level identifiers cannot all be inserted into box I.23, a schedule to the EHC should be created where the full list of unit-level identifiers can be provided and referenced to this box.

If incorporated to an electronic EHC, where a verifiable PDF EHC will accompany the consignment, the schedule should be referenced in container number or seal number (usually box I.23) and uploaded in accompanying documents (usually box I.17).

Verifiable PDF certificates for imports of products of animal origin from the EU and EFTA countries to Great Britain will be accepted from TRACES. Check the list of countries Great Britain will accept validated PDF GB health certificates from.

If incorporated into a physical EHC, the schedule should be referenced in container number or seal number (usually box I.23).

For both electronic and physical EHCs, you should:

• prepare the schedule according to existing guidance for schedules to EHCs
• include, for example, the EHC reference number on each page along with stamp and signatures as appropriate