Transit & Trans-Shipment Procedures
42. The Council Regulation (Article 19) allows for the checks on products under a transit or trans-shipment procedure to be carried out in the Member State of destination. Therefore if a consignment arrives at a major European port such as Rotterdam, and trans-ships to a UK port, UK Port Health will need to undertake the checks on the catch certificates and accompanying documentation.
43. Goods arriving in the UK and moving to another Member State under a T1 procedure are not required to submit their catch certificates for checking in the UK. However, if CVED checks are being carried out in the UK, then the importer may choose to have the catch certificates checked at the same time. Customs authorities in the Member State of destination would then be responsible for checking the completed documentation when the goods are submitted for clearance.
Imports from EEA/EFTA Countries
44. Currently imports of fish and fish products from EEA/EFTA countries (including Norway, Iceland, and Faroe Islands) are not subject to the EC veterinary checks regime. However, IUU catch certificates will be required.
45. Some imports of fish from these countries will therefore not enter the UK through a Border Inspection Post. It is envisaged that such trade routes will continue to operate. However, in such cases the catch certificates should be submitted to the relevant local authority enforcement team at these ports i.e. Port Health or Environmental Health, for checking.
Approved Economic Operators (APEO)
46. In order to simplify the import procedure, the regulation allows for an Approved Economic Operator (APEO) system to be set up. Importers who have been granted this status will not need to provide the catch certificates on import. Instead they will need to advise Port Health of arrival of the products and keep the catch certificates and accompanying documentation for three years. As a result, APEOs will not need to pay Port Health charges for checking the catch certificates on entry to the UK. APEOs will, however, be required to provide catch certificates and other documentation for checking and verification by UK authorities as required.
47. The detailed rules for the operation of the Approved Economic Operator scheme are contained in Chapter II of Commission Regulation 1010/2009.
48. Applicants will need to meet a number of criteria in order to qualify for this status. These are:
(a) The applicant must hold an Authorised Economic Operator (AEO) certificate under the Community Customs Code. Applicants can apply to HM Revenue and Customs to obtain this certificate. It is suggested that applicants apply for the full AEO certificate.
(b) The applicant must be established in the UK
(c) The applicant must have a sufficient number of import operations. In the UK this threshold has been set at 50 consignments per year.
(d) The applicant must be able to demonstrate compliance with fisheries conservation and management measures under the Common Fisheries Policy and not be engaged in or support, directly or indirectly, IUU activity
(e) The applicant must be able to demonstrate it has a satisfactory system of managing catch certificates and where appropriate, processing records that will enable checks and verifications to be carried out if necessary
(f) The applicant must have appropriate facilities and security procedures. These will be deemed sufficient if the applicant holds a full AEO certificate.
49. Applications for APEO status are not yet open. Further information on the application procedure will be provided in early 2010.
50. As a first step, potential applicants may wish to find out more about the process for obtaining an AEO certificate from HM Revenue and Customs.