Guidance

Plant Health News issue 41 - February 2021

Updated 26 September 2024

1. Plant health controls on importing and exporting wood, wood products and isolated bark now the transition period has ended

The UK has left the European Union (EU), and the Transition Period after Brexit ended on 31 December 2020. From 1 January 2021, changes to legislation were made to enable retained EU law to operate effectively and to address other deficiencies arising from the withdrawal of the UK from the EU.

This newsletter updates the version previously circulated in December 2020. It explains how the requirements for the import, export and movement of wood, wood products and bark from the EU have changed since 1 January 2021.

Full details of the changes can be found in the following legislation: * The Plant Health (Amendment etc.) (EU Exit) Regulations 2020 * The Plant Health (Phytosanitary Conditions) (Amendment) (EU Exit) Regulations 2020

Find out more information.

1.1 Plant health controls on forestry material from 1 January 2021

Imports from the EU

There are new requirements for the import of wood, wood products and bark. Certain types of firewood, which were currently subject to statutory notification, are now controlled material – for example, conifer kindling with bark. Further updates, including changes to regulatory requirements, can be found on the Plant Health Portal.

Types of conifer wood, wood products and bark subject to physical checks:

• all forms of conifer timber (with or without bark) and isolated bark from EU countries with pinewood nematode (Portugal and Spain) needs to be heat-treated and requires import Phytosanitary Certificates (PCs)
• similar measures also apply to pine and Douglas fir timber from Portugal and Spain where Fusarium circinatum is present
• all forms of conifer timber with bark, cut trees >3m and isolated conifer bark from all other EU countries requires import PCs that meet the landing requirements for bark beetles

Imports of conifer timber, which is bark free, is still permitted without PCs (unless it is from Portugal or Spain). It is recommended that any accompanying commercial documentation carries the statement that the product is bark-free (not de-barked)

For sawn timber, all associated dunnage (bearers, stickers and spacers) of the same type and quality of bark-free material need not be ISPM15 compliant provided it is banded together with the sawn timber product.

Types of hardwood and hardwood products subject to physical checks:

All forms of Castanea (unless free from bark) and Platanus. All forms of Juglans (walnut) and Pterocarya (wingnut). All forms of hardwoods which are hosts of Asian longhorn beetle (ALB) and the Red-necked longhorn beetle (RNLB) from EU countries where these pests are present:

• for RNLB, wood of Prunus requires PCs from Italy and Germany
• for ALB, wood of Acer, Aesculus, Alnus, Betula, Carpinus, Cercidiphyllum, Corylus spp., Fagus, Fraxinus, Koelreuteria, Medikus, Platanus, Populus, Salix, Tilia and Ulmus requires PCs from Italy, Germany, France and Finland

2. Important plant health information on the implementation of solid fuel firewood into the UK from Europe

Update on the importation and notification of solid wood fuelwood (firewood) including conifer kindling into the UK

As of January 2021, the EU exit transition period ended and new rules regarding the importation of certain specis and types of wood into the UK came into effect.

Certain types of firewood, which were subject to notification under the firewood statutory notification scheme (SNS) are now classified as regulated material – for example, conifer kindling with bark. The types of firewood that are now regulated need to be notified to Forestry Commission Plant Health Inspectors prior to landing and must be accompanied by phytosanitary certificates (PCs) issued by the country of export. They no longer need to be notified through the statutory notification scheme for firewood. If the firewood is not regulated, you should continue to use the Statutory Notification Scheme (SNS).

The Forestry Commission has summarised these changes and the change in processes involved. This note will help you understand these new rules as they specifically affect fuelwood and could affect your business.

1. As of January 2021, only unregulated hardwood firewood imported from both EU and third countries should continue to be notified under the Statutory Notification Scheme (SNS) as before. The requirements for regulated material are described below.

2. As of January 2021, certain types of conifer firewood and kindling from Europe are now treated as regulated material and must be notified to Forestry Commission Inspectors prior to landing.

3. As of January 2021, certain types of hardwood firewood from certain countries are now treated as regulated material and must be notified to Forestry Commission Inspectors prior to landing.

4. As of January 2021, imported regulated material and will require a Phytosanitary Certificate – not an EU plant passport. This material will also need to be notified to the Forestry Commission (using the appropriate notification of landing form) and not the SNS. This notification will then trigger a documentary check by a Forestry Commission Plant Health Inspector and possibly a physical inspection at either the Border Control Post (BCP) or a Place of Destination (POD). The material will also require a quarantine release certificate issued by the Forestry Commission (PHF28) in order to be release by HMRC.

Please see example scenarios below:

1. Consignment of 100% ash hardwood firewood from Latvia: This consignment will need to be notified under the SNS.

2. Consignment of 100% ash hardwood firewood from Germany: This consignment must be notified using the appropriate notification of landing form. This consignment does require a phytosanitary certificate, may require an inspection by the Forestry Commission and will require a quarantine release certificate, but should not be notified under the SNS.

3. Consignment of 80% ash hardwood firewood and 20% bark free conifer kindling from Latvia: The whole consignment will need to be notified under the SNS.

4. Consignment of 80% ash hardwood firewood and 20% non-bark free conifer kindling (KD to less than 20% MC) from Latvia: The ash will need to be notified under the SNS and the conifer kindling notified as controlled material using the appropriate notification of landing form. NB: The conifer element of the consignment does require a phytosanitary certificate, may require an inspection by the Forestry Commission and will require quarantine release certificate, but should not be notified under the SNS. Consignment of 100% bark free conifer kindling from all third countries: may be regulated or not depending on country of origin (see table below for controlled material by country).

5. Consignment of 100% non-bark free conifer kindling from any third country: This consignment must be notified using the appropriate notification of landing form, the consignment does require a phytosanitary certificate may require an inspection by the Forestry Commission and will require quarantine release certificate but should not be notified under the SNS.

3. Forestry machinery and vehicles

Used forestry machinery and vehicles (excluding chainsaws), require PCs stating that:

• machinery and vehicles are moved from an area free from Ceratocystis plantini; or
• that machinery and vehicles have been cleaned and are free from soil and plant debris prior to movement out of an infected area

(There are no requirements for movement controls within GB).

4. Exports to the EU

There are also new requirements for the export of wood, wood products and bark.

4.1 Types of conifer wood, wood products and bark including firewood

All conifer wood with bark, cut trees >3m and isolated bark moving to the Republic of Ireland and Northern Ireland must meet the landing requirements for conifer bark beetles, the wood must:

• be bark-free; or
• a UK phytosanitary certificate declaring the origin in a pest-free area for conifer bark beetles (the only GB PFA being the west of Scotland PFA); or
• a UK phytosanitary certificate declaring kiln-drying and evidenced as such by a mark such as ‘KD’.

Isolated bark must be accompanied by: * a UK phytosanitary certificate declaring that it has been subjected to fumigation or other appropriate treatments (approved by the Forestry Commission) against bark beetles; or * a UK phytosanitary certificate that it originates in a pest-free area for conifer bark beetles (the only GB PFA is the west of Scotland PFA).

Cut conifer trees >3m must come from a pest-free area for conifer bark beetles as declared on a UK phytosanitary certificate.

4.2 Types of forestry machinery and vehicles

Used forestry machinery and vehicles (excluding chainsaws), require PCs stating that:

• machinery and vehicles are cleaned and free from soil and plant debris.

(There are no requirements for movement controls within GB).

5. Wood packaging material (WPM)

• WPM must comply with ISPM 15 for movement with goods of all kinds between GB and the EU. This is in line with international requirements for trade and is in place to protect both the EU and GB from harmful plant pests and diseases.
• The WPM sector has ensured that sufficient stocks of ISPM 15 material are available for the movement of all goods.
• There has been no change to the biosecurity threat from WPM originating in the EU and we maintain our risk-based checking regime for EU wood packaging material.
• ISPM 15 compliant WPM is a requirement for all WPM moving from GB to Northern Ireland.
• WPM moving from Northern Ireland to GB, Northern Ireland to Republic of Ireland, or Republic of Ireland to * Northern Ireland does not need to be compliant with ISPM 15.

A detailed Q&A document for WPM is available on the Plant Health Portal.

6. Imports from countries outside of the EU

There have been some minor but important changes to the regulation of other materials since leaving the EU. The long-established trade agreements that the EU made with other countries need to be reviewed and, where appropriate, these need to be renegotiated to continue to operate for GB.

The rules that applied to the import of certain sawn wood from North America were subject to EU derogations that allowed the trade of material under mill certification schemes. The derogations used to offer the option to relax the normal requirement of requiring export PCs to accompany all consignments of timber as long these were subjected to 100% physical checks on arrival at Border Control Posts.

Renegotiation of these derogations is underway. During this process, the same entry requirements for sawn timber will continue to apply as a temporary measure. So, at the present time, the same types of conifer and hardwood timber can continue to be imported either under the relevant mill certification schemes or with export PCs. All these imports will continue be subject to 100% physical checks on arrival in GB.

The requirements for certain types of timber have been reassessed in relation to the risk of their entry into GB. Sawn oak from Canada is now required to have PCs that declare that it meets new GB landing requirements to protect against oak wilt (Bretziella fagacearum).

Further amendments to legislation are planned that will clarify the requirements that apply to wood from any country:

• associated dunnage will be allowed with all consignments of regulated sawn timber
• measures have been added that apply controls on wood and bark from pines and Douglas fir in the form of sawn wood and to bark, chips, particles, sawdust, shavings, wood waste and scrap
• requirements for sawdust will be added as a measure that applies in relation to imports from countries where Asian longhorn beetle is present
• details of fumigation, as a phytosanitary treatment for conifer bark, will be permitted only where the national plant protection organisation of the country of origin has previously provided the national plant protection organisation of the United Kingdom with written details of fumigation

A consequence of making the necessary changes to retained EU legislation is that the order in which the requirements are now presented differs from the original EU legislation. Although most of the third country requirements remain the same, the references for imports into the GB now differ to those destined to the EU.

As a transitional measure, our inspectors have been advised to accept declarations which were appropriate to the legislation prior to amendment. This is to allow third countries time to update their own systems for adding declarations to PCs for export to GB.

6.1 Operational processes and procedures from 1 January 2021

Import Phytosanitary Certificates (PCs)

• PCs issued by Plant Health Authorities in EU member states have replaced EU plant passports for the import of goods from the EU and landing in GB on or after 1st January 2021.
• Pre-notification of landing of controlled EU goods is required.
• On entry to GB, remote documentary import checks are now required on PCs. Physical checks on the material may also be carried out, according to the risk-based priority for the commodity concerned.
• Checks may be carried out inland at Places of Destination (PoDs) until July 2021 for EU origin material. If appropriate, physical checks may also take place at Border Control Posts (BCPs).
• Import fees will not apply to imported EU material until 1 April 2021, but Certificate of Clearance forms (PHF28s)/Quarantine Release Certificates (QRCs) will be issued to importers by Forestry Commission Inspectors.
• There is no change to the operational processes for importing into GB from non-EU third countries, for example pre-notification will continue to be required and checks are still carried out at BCPs.
• Regulated material that is imported into the EU (from non-EU third countries after 1 January 2021) and is then re-exported to GB will need to be pre-notified and will be subject to checks. Copies of the original PCs from non-EU third countries must accompany such material. (see ‘Requirements for goods originating outside of the EU’ below).

What you have to do:

• Importers need to register with the Forestry Commission as a professional operator.
• Once registered, importers will need to pre-notify the arrival of consignments of controlled material from the EU using the FC notification of landing form.
• For the period between 1 January 2021 and 1 July 2021, checks may be carried out inland at Places of Destination rather than at Border Control Posts. You will need to include the information about where checks will take place on the Notification of Landing form.

Import checks and Places of Destination

Great Britain has developed a 3 stage phased import regime for plants and plant products which include wood, wood products and isolated bark from the EU. This allows importers time to adjust to the new regime and to reduce the risk of delays at the border. This is most relevant to the movement of perishable goods entering via road transport across the Channel. The regime is as follows:

• From now, all ‘high priority’ materials must have a phytosanitary certificate and require pre-notification. These will be subject to non-chargeable physical and identity checks that will occur at a place of destination (PoD) when these are designated by importers. High priority forestry materials are detailed in Plant health controls on forestry material from 1 January 2021 above.
• From April 2021, all regulated material must have a phytosanitary certificate and pre-notification. Only EU high priority goods will require physical (plus documentary and identity) checks at PoDs but these will be chargeable.
• From July 2021, the number of physical and identity checks on regulated plants and plant products, wood, wood products and isolated bark will increase. These checks will be performed at Border Control Posts (BCPs).

You should start to prepare for the changes that will come in to force from April now. If you import regulated material, you can speak to the exporting country to understand what information they require to produce a phytosanitary certificate. You can also find out more about the requirement for pre-notification on GOV.UK.

Place of Destination

You can apply for your premises to be registered as a Place of Destination for plant health physical inspections on high priority EU material between January 2021 until July 2021. Alternatively, importers of wood and wood products can choose for inspections on high priority material to take place at existing BCPs. To comply with the requirements of this new temporary system, you must be registered as a professional operator to import or store regulated material. There are several other criteria you must meet for your application to be approved. These can be found in more detail on GOV.UK.

High priority material must be made available for inspection at the place of destination before it is split or moved to other locations. The onward movement of regulated wood, wood products and isolated bark from a place of destination to other locations, within the UK, may require a UK plant passport. You can find out more about plant passporting and how to become an authorised professional operator to issue plant passports on GOV.UK.

Plant Passports

*Phytosanitary certificates (PCs) have replaced plant passports for movements of regulated material between the EU and GB, and vice-versa. * EU plant passports can no longer to be used to accompany regulated plants and plant products, including wood, wood products and isolated bark, between the EU and GB or within GB. * EU plant passports continue to be applicable for movements of Qualifying Northern Ireland Goods (QNIGs) from NI to GB. * The format for the GB internal movement passport has changed from the EU passport to a UK passport. * GB no longer uses plant passports with a Protected Zone designation. * UK plant passport requirements apply to all movements within GB. Including conifers, Castanea (including sweet chestnut), Platanus (plane), Juglans (walnut) and Pterocarya (wingnut).   *The same procedures for registration and authorisation of professional operators apply. There is no need for re-registration. * UK passports cannot be issued by the EU and EU passports cannot be issued or attached in GB (passports issued in the UK may be attached in the EU until July 2021). * Export PCs are required for regulated wood, wood products and isolated bark moved from GB to Northern Ireland, not plant passports. * UK plant passports also apply to the movement of material from GB to the Isle of Man, to Jersey and to Guernsey.

What you need to do:

• If you are authorised to issue plant passports you should amend the format of these to comply with the UK guidance.
• Continue to issue UK plant passports for regulated material moving within GB and to the Crown Dependencies
• Apply for an export PC for movement of regulated material to the EU or Northern Ireland.
• The PCs must be issued by the relevant plant health authorities within GB rather than by professional operators. PCs for regulated forestry material will be issued by the Forestry Commission.
• Consignments entering the EU and GB will be subject to physical checks that will differ in frequency according to the risk priority for the commodity concerned.

You can find more information about the format for plant passports now in the latest Plant Passporting Factsheet. The associated Forestry Commission e-learning has been updated to reflect these changes.

Export Phytosanitary Certificates

• Export phytosanitary certificates have replaced EU plant passports for movement of regulated material from GB to the EU.
• PCs are necessary for the entry of regulated products at the country of destination.
• Exporters need to register as an exporter with the Forestry Commission to move regulated material outlined under 1.1 from GB to the EU.
• Exporters need to use the electronic application system to apply online for export phytosanitary certificates (EAPC) to supply the information necessary for the Forestry Commission to issue PCs to accompany regulated material.
• Exporters applying for export phytosanitary certificates online using the EAPC system may continue to do so. Please note, we are reviewing this service and developing a new online solution to replace EAPC for all new and existing service users requiring export phytosanitary certificates. Further updates on this will follow in future newsletters.
• Where necessary, PCs must carry additional declarations that are relevant to the accompanying consignment of wood or wood products or isolated bark.
• Inspections may be required prior to export, dependent on the requirements of the EU.
• Checks apply to regulated material as it enters the EU from GB.
• Northern Ireland remains within in the European Union’s Sanitary and Phytosanitary zone, so EU import requirements continue to apply to imports into Northern Ireland.

Phytosanitary Certificates for re-export

• The phytosanitary requirements that apply to the imports of non-EU origin timber continue to apply if the material is re-exported to the EU from GB.
• The procedure to request a PC for a re-export is the same as for other exports (above).
• A copy of the original third country import PC should be supplied to accompany the PC application.

What you need to do:

The process for sending regulated material to the EU is the same as the current process for exporting to third countries. You need to:

• check whether a PC is required by contacting the plant health authority or a plant health inspector in the destination country
• if you will require export PCs for wood or wood products please use the phytosanitary certificate application form.
• applications for PCs need to be made at least five working days before material is due to be exported. There is a charge for this service.

Arrangements related to movement of material from the Pest Free Area (PFA) in Scotland are now:

• For movements out of the Pest Free Area (PFA) in Scotland, to Northern Ireland or the Republic of Ireland, PCs have replaced EU or UK plant passports.  
• Coupe inspections continue to be carried out by inspectors to confirm freedom from quarantine bark beetles before the issuance of PCs are authorised.
• PCs and conveyance notes accompany shipments to Ireland as the means to trace roundwood back to the authorised felling coupes.
• For movements within and out of the PFA in Scotland to locations within GB a UK plant passport must be used.

The process for the conifer export trade from the west Scotland PFA is as follows:

• The professional operator requests a felling coupe inspection from the Forestry Commission.
• After a successful inspection, the professional operator will receive a letter from the Forestry Commission stating that no regulated pests were found during the inspection.
• The professional operator then applies to the Forestry Commission for a phytosanitary certificate. The application would be supported by the Forestry Commission inspection letter.
• A fee will be charged for the felling coupe inspection and the issue of an export PC.
• You should allow at least 5 days for your application to be processed.

If you have any questions about the contents of this newsletter you can contact the Forestry Commission Plant Health Service: plant.health@forestrycommission.gov.uk

Imported goods originating from outside of the EU

There have been some change to requirements for goods originating outside of the EU as noted above. However, the controls on direct imports and goods in transit through EU countries, without prior clearance, are very close to what they were previously.

Slightly different arrangements apply to non-EU goods that were previously landed and cleared for entry into the EU (before 1 January 2021). The phytosanitary risk associated with this material is being treated as the same as when the goods entered the EU, and:

• A forwarding export phytosanitary certificate may be required to accompany third country material from the EU, for example, high-risk conifer retaining bark.
• Any additional declarations on the EU export PC must meet GB requirements, rather than EU requirements, although in many cases these declarations will be similar.
• Copy EU import entry documents, such as import PCs, will be required in support of these additional declarations.
• The procedure for customs entries will be different to direct imports or to goods in transit.

The arrangement for the export of non-GB origin goods from GB to the EU is also different:

• A forwarding export phytosanitary certificate may be required to move goods from GB to the EU.
• Any additional declarations on the GB export PC must meet EU entry requirements, rather than GB entry requirements, although in many cases these will be similar.
• Copy GB import entry documents, such as import PCs, will be required in support of these additional declarations.
• There is a slightly different procedure for customs entries from GB origin exports.

We recognise that in some cases the previous import entry documents or PCs might not be available or may no longer apply where wood is re-processed. Where necessary, we will seek to find a pragmatic way to facilitate trade without compromising biosecurity:

• It will not be necessary for original PCs to accompany re-processed timber.
• PCs will not be required for re-processed bark-free sawn conifer timber that originates in European countries which are free from pinewood nematode.

Customs entry guidance – ex-heading procedure

There are situations where the import tariff codes for timber, wood products and bark don’t fully describe the relevance of material under phytosanitary controls. So called ‘ex-headed goods’ are goods identified within an import commodity (CN) code where a PC (or licence) may or may not be required to import them.

A regular example encountered is sawn conifer timber, as described under the relevant CN codes for 4403 or 4407. If this material originates in parts of Europe (EU and European third countries) that are free from pinewood nematode (PWN) then it may or may not be subject to phytosanitary controls. Conifer timber which is bark-free is treated as if it has no phytosanitary relevance, it does not require a PC, nor does it need quarantine release checks from the countries where PWN is not present.

Alternatively, all conifer timber with residual bark must be accompanied by a PC and must be routed for quarantine release checks on entry into GB.

The ex-heading procedure is not available to sawn conifer timber originating in Spain and Portugal where PWN is present as all timber, wood products and bark requires PCs and must be routed for quarantine release checks on entry.

For more details on the ex-heading procedure please consult your clearance agent or refer to HMRC entry procedures.

COVID easement

Commission Implementing Regulation 2020/466, which provides for specific easements of official controls in response to the COVID 19 outbreak, is retained as part of UK law and has been extended until 1 July 2021. For plant health, this has the following impacts:

• For plants and plant products imported from third countries, GB may accept electronic copies of original phytosanitary certificates from exporting counties where issuing originals is an issue. This measure is conditional on the original certificate being provided as soon as technically feasible.
• GB will also allow officials to carry out remote documentary and identity checks using available technology where appropriate.
• GB will consider the use of remote and virtual meetings with operators where physical meetings are not feasible.

Commission Implementing Regulation (EU) 2021/83 has been published by the European Commission confirming that the extension of the reciprocal COVID measures until 1 July 2021 will be at the discretion of Member States.

7. Please address any queries relating to the above information to:

Forestry Commission
Plant Health Service
Silvan House
231 Corstorphine Road
Edinburgh
EH12 7AT

Telephone: 0300 067 5155 Fax: 0131 316 4344 Email: plant.health@forestrycommission.gov.uk