HRFNAO - Country of Origin Declaration FSA Clarification

As you may be aware, it is the combination of the product and the country of origin that determines whether a product is a HRFNAO and subject to controls. Please refer to the relevant legislation e.g. Assimilated Regulation 2019/1793. Further information on restricted commodities can be found on the FSA website.

Indirect imports of HRFNAO to GB via European Union (EU) / European Economic Area (EEA) countries
The Border Target Operating Model is now introducing checks on goods entering GB from or via the EU/EEA in a staged approach. From 31 January 2024, importers have been required to declare HRFNAO entering GB via the EU/EEA by completing a CHED-D on the IPAFFS database.

If HRFNAO has been imported into the EU and ‘processed’ (as defined in Assimilated Regulation 852/2004) into a new product, the new product would be of EU origin and would not usually be classified as HRFNAO. In these circumstances, a CHED-D would not be required. (There are some exceptions for compound products - see Assimilated Regulation 2019/1793, Annex II, Table 2.) It should be noted that there is currently no HRFNAO that originates within the EU/EEA.

If the HRFNAO has not undergone further processing before being exported to GB, the country of origin remains unchanged, and the product would still be classified as HRFNAO and a CHED-D required.
The IPAFFS declaration should therefore include the following:

• Country of origin: the Rest of World country where the goods originated (i.e. outside of the EU, for example, Brazil).
• Country from where consigned: The EU member state / EEA country from where the goods are exported to GB (e.g. France).

You need a laboratory report and a health certificate if you import the following HRFNAO:

• rice products from China listed in Annex 1 of 2011/844

• products listed in Annex 2 of 2019/1793

• Chernobyl affected products listed in Annex 2 of 2020/1158

All HRFNAO imports must be accompanied by commercial documents. an invoice

• the packing list

• the bill of lading or airway bill

Direct imports of HRFNAO to GB and transiting consignments of HRFNAO through the EU to GB

Please be advised that direct imports of HRFNAO into GB as well as consignments of HRFNAO that only transit through the EU to GB (i.e. that are not first placed on the EU market) remain unaffected by these changes – these should continue to be notified in the same way on IPAFFS.

Further guidance can be found as follows:

Gov.uk website: Import high-risk food and feed not of animal origin from the EU to Great Britain.