1. MEETING REGULATORY REQUIREMENTS IN FOOD SAFETY
Background
All products imported into the UK must comply with EU law on contaminants. Laws are put in place to protect public health. When the UK leaves the EU, this legislation will be adopted into UK law.
There are certain types of food and feed that are considered as high-risk and are therefore subject to increased import requirements, including import controls as they pose increased risks to public health. It is the responsibility of the importer or their agent to establish whether any of their imported food and feed products are high-risk and subject to controls.
If imported products fail to meet the required standards, they are not allowed to enter the UK. Products that are high-risk can only enter through ports with the required facilities to undertake the relevant controls – Border Inspection Posts (BIPs) for products of animal origin (POAO) and Designated Points of Entry (DPEs) for high-risk food and feed not of animal origin (FNAO).
High-risk products include:
All products of animal origin, for example, meat, dairy and honey;
Specific food and feed products not of animal origin from specific non-EU countries, where a specific hazard has been identified. These products and the import requirements for them, are specified in legislation. Further information on the FSA’s website:
The UK will not impose any new checks or controls on food or feed products originating from the EU. This is because from Day 1, the risks will remain the same.
John Furzer
Head of Imports Delivery
Food Standards Agency

2. Food safety controls in
Official controls
Food safety controls in
the United Kingdom

3. Legislation Food Standards Act 1999 & Food Safety Act 1990
Key EU legislation from food safety and incident management perspective includes: EC Reg No 178/2002 – lays down the general principles and requirements of food law EC Reg No 882/2004 – details official controls performed to ensure verification of compliance with feed and food law

4. Enforcement of food law
The FSA acts as the central competent authority for food in the UK
Enforcement is undertaken at a local level by port health and inland local authorities
The FSA audits the performance of local authorities

5. Food Standards Agency International
FSA represents all of the United Kingdom internationally
International relations is a ‘reserved’ matter it has not been ‘devolved’
The stance adopted by FSA in international discussion is the policy position of UK Ministers
When working internationally FSA ensures there are clear key negotiating and voting positions agreed with our devolved administrations and Department of Health Ministers

6. Safety regulations and control system / management of
Imported food
Safety regulations and control system / management of
imported food

7. Working across wider Government at the border
26 separate Government Departments and Agencies operating at the UK border, including:
Food and Environment Research Agency (FERA)
Foreign and Commonwealth Office (FCO)
Plant Health and Seeds Inspectorate (PHSI)
Her Majesty’s Revenue and Customs (HMRC)
Border Force
Defra / Animal and Plant Health Agency (APHA)
Port Health Authorities

8. Responsibility for undertaking import controls
The Department of Environment Food and Rural Affairs (Defra) are the UK Central Competent Authority for undertaking official controls of imported products of animal origin (POAO). This is undertaken by official veterinarians at border inspection posts (BIPS).
The Food Standards Agency are the UK Central Competent Authority for undertaking official controls of imported food not of animal origin (FNAO). This is undertaken by local authority Port Health Officers (PHOs) at the designated entry points.

9. THE FSA’s IMPORTS TEAM - WHAT WE DO:
We protect UK consumers’ health from the hazards associated with ‘high-risk’ food and feed imported into the UK from 3rd countries

10. WHAT WE DON’T WANT TO DO:
TRADE

11. A REGULATORY APPROACH

12. EFFECTIVE CONTROLS What ? Where ? How ? Risk based checks
Random physical checks

13. Food Not of Animal Origin (FNAO)

14. Import controls for new / emerging high-risk foods not of animal origin (FNAO)
Commission Regulation (EC) No. 669/2009 (as amended) provides enhanced official controls on import for specific products posing specific risks from specific countries. These must:
be imported through a Designated Point of Entry (DPE)
Undergo 100% documentary checks and a % of identity and physical checks (as specified in Annex I of Regulation 669/2009)
be pre-notified to the DPE by completing Part I of the Common Entry Document (CED). In the UK, this must be done via EU’s TRACES system.

15. SAFEGUARD MEASURES Regulation 884/2014 – Aflatoxins
Provides additional guarantees for importing specific products from specific countries identified at risk from aflatoxins:
All consignments must be accompanied by a health certificate and the results of sampling analysis completed by the authorities in the exporting country

16. SAFEGUARD MEASURES (cont.)
Regulation 885/2014 – Pesticide residues
Provides additional guarantees for importing specific products from specific countries identified at risk from pesticide residues:
All consignments must be accompanied by a health certificate and the results of sampling analysis completed by the authorities in the exporting country

17. Random Physical Checks
ADDITIONAL CONTROLS
Random Physical Checks
National Monitoring Plan

18. RASFF- Rapid Alert System for Food and Feed
EU system for sharing vital information between members on non-compliant foods, including border rejections for imported food.
Operates 24-7
Used for product recalls
RASFF data contributes to informing decisions on additional import controls.

19. FSA’S IMPORTED FOOD EARLY WARNING SYSTEM: What is it?
An emerging risk detection tool with three key aims:
To predict hazards for specific food and feed from specific 3rd countries for inclusion in legislation (e.g. Annex I of Reg.669/2009);
To identify new issues and alert PHAs / LAs to facilitate targeted enforcement;
To address concerns from industry on imported food and feed

20. The EWS Successes! Early detection of:
Chloramphenicol (prohibited substance) in enzyme preparation from India – effective from 1 April 2014
Salmonella in Sesame Seeds from India effective from 1 October 2014 under 669/2009
Pesticide residues in Dragon fruit from Vietnam – effective from 1 October 2014 under 669/2009
Positive feedback from UK ports – EWS has enabled better targeted enforcement

21. The Official Control Regulations 2017/625

22. ‘The OCR’ - Regulation 2017/625
Negotiated over a number of years – published in April 2017
Will apply across the European Union from 14 December 2019
Has extended scope and attempts to harmonise rules across sectors
Repeals Regulation 882/2004, Regulation 854/2004, Directive 96/23/EC and Directive 97/78/EC

23. Major changes in the OCR
A lot of the OCR is about controls and conditions for food imported into the European Union – focus on integration and harmonisation
The basic act itself sets out a few major changes:
BIPs, DPEs and DPIs will all become BCPs (Border Control Posts)
Creation of the ‘Common Health Entry Document’
The establishment of the Information Management System for Official Controls
Much of the detailed changes take the form of tertiary legislation

24. What is the IMSOC?

25. Tertiary Legislation
Big Regulations like the OCR create empowerments for the European Commission to create implementing and delegated regulations (‘tertiary legislation’)
This tertiary legislation creates the detailed rules on how legislation should be delivered
The OCR had a lot of empowerments for tertiary legislation about imports.

26. UK Import requirements post EU departure
Exiting the EU
UK Import requirements post EU departure

27. Goods from Rest of World (3rd Country)
INDIA
HEATHROW (DPE)
UK DESTINATION
Now
TRACES
Importer notifies UK (BIP/DPE), using TRACES, of any high risk category product prior to it arriving at the UK. Specified checks are carried out before it can proceed and be placed on the UK market.
Post Brexit
IPAFFS
As before Exit but Importer will be required to use the TRACES replacement system, IPAFFS, in the event of a non negotiated exit.

28. Now Post Brexit Goods from EU to UK (e.g. Poland) FELIXSTOWE
UK DESTINATION
Now
Product enters into UK freely and is placed on the UK market
Post Brexit
Importer notifies UK (FSA) in advance (from June 2019), of intention to import High-Risk food and feed. Product enters into UK freely and is place on the UK market.

29. Rest of World high-risk food and feed moving through the EU to the UK
RoW to UK via the EU
RoW ORIGIN
Through the EU
UK SEA/AIR PORT (BIP/DPE)
UK DESTINATION
For RoW high-risk food and feed consignments, the importer will be required to send those products to a UK BIP/DPE for checks to be carried out (as 3rd country process).
*Note: If the goods are imported directly into the EU where the relevant import controls are undertaken, there will be no requirement to enter the UK via a UK BIP/DPE. This means the consignments will be able to enter the UK via any entry point.

30. Pre-notification of EU high-risk food and feed
Imports 4/4
Pre-notification of EU high-risk food and feed
What
EU originated high-risk food or feed
RoW high-risk food/feed imported directly into the EU but destined for UK
Why
Due to loss of access to EU systems
Ensure the continued protection to UK consumers from imported food
When
Requirement will come into effect from June using a new UK system
For surveillance purposes only and there will be no controls on such products
More information: Food and feed products not of animal origin that are considered as high-risk:

31. Imported Food Web pages: www. food. gov
Imported Food Web pages:

32. THANK YOU ANY QUESTIONS?