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What do we mean by ‘Channelling’

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Article 8.4 of Directive 97/78• Control of products which are to be

monitored pursuant to Community legislation from the border inspection post of arrival to the establishment at the place of destination

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• What procedures have to be followed for channelling?

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• Dispatched from the border inspection post of arrival to the establishment at the place of destination under the supervision of the competent authority in leakproof vehicles or containers sealed by the competent authorities.

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• Under customs supervision until they reach the place of destination in accordance with procedure T5 as laid down in Commission Regulation 2454/93 implementing Council Regulation (EEC) No 2913/92 establishing the Community Customs

Code, in conjunction with the ……CVED

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• The official veterinarian (OV) at the border inspection post concerned shall inform the veterinary authority (LVU) in charge of the establishment at the place of destination of the consignment of the place of origin and the place of destination of the product via the (TRACES) network

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• The products shall undergo, in the establishment at the place of destination, the treatment defined in the relevant Community legislation

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• The official veterinarian at the place of destination (LVU) or in the case of raw material for manufacture of pet food, pharmaceutical or technical products the official veterinarian responsible

for an intermediate warehouse, shall be informed by the management of the establishment of destination or of the intermediate warehouse of the arrival of the product at its destination

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• The official veterinarian at the place of destination (LVU) shall within 15 days notify the official veterinarian at the border inspection post (OV) that the consignment arrived.

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• He (LVU) shall carry out regular checks to ensure that the products have arrived at the establishment of destination, in particular by checking the entry records.

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Summary of requirements• Transported in leak-proof containers

• Containers sealed by competent authority

• Under T5 control

• BIP vet to inform destination vet via TRACES

• Products to undergo required treatment

• Destination establishment to confirm arrival to their vet

• Destination vet to inform BIP vet within 15 days

• Destination vet to check establishment ‘s records to see consignments have arrived

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What products for human consumption are subject to

channelling?

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• Head-on, ungutted tuna

• Directive 97/78 article 17 allows for checks to be done by BIP staff at the factory if located within 75km of BIP and goods are channelled.

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What products not for human consumption are subject to

channelling?

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Channelled Animal By-products• Bones and bone products for technical use• Hooves and hoof products for technical use (includes

hoof and horn grist)• Horns and horn products for technical use (includes

horns for walking stick handles)• Raw (unprocessed) material for petfood manufacture

(inc. NZ)• Raw (unprocessed) material for pharmaceutical use

(not NZ)• Raw (unprocessed) material for technical use

(not NZ)

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• Category 2 rendered fats for oleochemical purposes• Fat derivatives NFHC• Gelatine for photographic use if contains Category 1

material (ref. Commission Decision 2004/407) • Untreated whole blood for petfood, pharmaceutical or

technical use (i.e. raw material for petfood / technical use)

• Some untreated blood products

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• Blood products NFHC not channelled:• All treated blood products• All avian blood products – treated and untreated• Serum of equidae• Certain untreated blood products of Artiodactyla ,

Perissodactyla and Proboscidea exc equidae

• Blood products NFHC that are channelled• Untreated whole blood for petfood / technical use • Certain untreated blood products of Artiodactyla ,

Perissodactyla and Proboscidea exc equidae

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Treated blood products for technical use from Artiodactyla, Perissodactyla and Proboscidea, including their crossbreeds - not channelled.

(Reg 2008/523 amending Reg 1774/2002)

Treated means:• (i) heat treatment at a temperature of 65 °C for at least three

hours, followed by an effectiveness check,• (ii) irradiation at 25 kGy by gamma rays, followed by an

effectiveness check,• (iii) heat treatment of at least 80 °C throughout their substance,

followed by an effectiveness check,• (iv) animals other than Suidae and Tayassuidae : change in pH

to pH 5 for two hours, followed by an effectiveness check;

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Untreated blood products of Artiodactyla , Perissodactyla and Proboscidea exc equidae

Foot and mouth disease, swine vesicular disease,

classical swine fever, african swine fever

Must be from country or region where no cases (as relevant to the species concerned) have been recorded for 12 months

Not channelled: • Where vaccination against these diseases (as relevant to the

species concerned) has not been carried out for at least 12 months,

Channelled:• Where vaccination against these diseases (as relevant to the

species concerned) is being officially carried out.(All untreated blood products must also be from countries free of rinderpest, peste de

petits ruminants and rift valley fever for >12 months and no vaccination carried out)

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Untreated blood products of Artiodactyla , Perissodactyla and Proboscidea exc equidae

Vesicular stomatis and Bluetongue (where relevant to species concerned)

Not channelled: • If from country or region where no cases of

vesicular stomatitis and bluetongue (including the presence of seropositive animals) have been recorded for 12 months, and

• vaccination has not been carried out at least 12 months,

Channelled:• If vesicular stomatitis or bluetongue are present or • Vaccination has been carried out in last 12 months

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Untreated blood products of Artiodactyla , Perissodactyla and Proboscidea exc equidae - Summary

In principle, if vaccination being used to control

certain diseases such as FMD, ASF, CSF, Bluetongue or Vesicular stomatitis

then channelling is required to control the risk.

See Reg1774/2002 as amended by Reg 2008/523 for detailed import requirements

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How is CVED completed for channelled consignments?

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Reverse of CVED

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How do you keep track of channelled consignments?

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• Keep RegisterExample of register of channelled consignments

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BIP receives email alert from TRACES

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Inland LVU has confirmed arrival of goods by completing the ‘Control’ tab on TRACES.

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What is the T5

procedure?

(Example T5)

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T5 Procedure1. Importer/agent completes T5 in duplicate, filling in all relevant

boxes. • Original is to accompany goods to place of destination• Copy is to be retained by Customs (customs control copy)

2.    Importer/agent submits the original and copy to Customs

at the port who authenticate the T5 by: • confirming the details match those on the Customs entry• checking it has been fully completed• stamping both the original & the copy T5• Original is returned to importer/agent• Copy is sent to Customs central clearance

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T5 Procedure3. Importer/agent submits original T5 (or faxed copy) to Border

Inspection Post

 4.    Border Inspection Post will:• Check that the goods do require a T5• Match the T5 with the CVED • On the CVED complete Box 33 (Channelled goods) and Box

37 (Details of controlled destinations)• Enter the T5 number in Box 42 of CVED • Return the original of T5 to the importer/agent to accompany

the goods to their approved destination

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6. Importer/agent forwards original T5 and CVED to destination establishment.

7. On arrival of goods at destination establishment, consignee /operator of establishment sends T5 to Customs who:

• Match original T5 with copy• Check goods listed on T5 have arrived according to available evidence

(Examples of suitable evidence include cleared Customs import entry and a delivery note or copy of the written arrival notification which is sent by operator of destination establishment to the veterinary officer)

• Complete T5 to confirm goods arrived. File

If check unsatisfactory or if original T5 not received, Customs notified.

If Customs cannot verify arrival of the goods they will notify BIP

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T5 Procedure8. Destination Customs office: •  visits or makes other checks to verify arrival of goods

at destination establishment

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• What problems are there with the channelling procedure?

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Example of fax to inland

LVU

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Example of letter to person responsible for the load detailing action required

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Returned consignments – limitations of TRACES

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EU returns – POAOs of EU origin returned from third countries.Article 15 of Directive 97/78

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1. A Member State shall authorise the re-importation of a consignment of products of Community origin which was refused by a third country, if:

(a) the products are accompanied:

• (i) either by the original certificate or a copy authenticated by the competent authority which issued the certificate accompanying the products, together with

• details of the reasons for refusal

• a guarantee that the conditions governing the storage and transport of products have been observed, stating that the products concerned have not undergone any handling; or

• in the case of sealed containers, by a certificate from the carrier stating that the content has not been handled or unloaded;

EU returns – Article 15 Directive 97/78

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Would you request any commercial documents?

If so, which ones?

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Additional documents (good practice)

• A copy of the invoice, packing list and bill of lading that accompanied the consignment on export

• A copy of the invoice (if any), packing list (if any) and bill of lading accompanying the consignment on its return trip.

• A copy of any surveyors report, any rejection notice or other relevant document

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What examination would you do?

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Directive 97/78 – Checks required• (b) the products in question (shall) undergo a

documentary and identity check and, in the cases provided for in Article 20, a physical check.

[Article 20:

where it is suspected that veterinary legislation has not been

complied with or there is doubt as to:

• (a) the identity or actual destination of a product;

• (b) whether the product corresponds to the guarantees laid down in the legislation for that kind of product;

• (c) compliance with the animal or public health guarantees laid down in Community legislation;

(the vet shall) carry out any veterinary checks the veterinarian or authority deems appropriate in order to confirm or rule out suspicion.]

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How is CVED signed

off?

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Reverse of CVED

Box 33 completed Destination details in box 37T5 number in box 42

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Problem cases

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Example of returned consignment.

Canned fish sent to Ghana but returned for commercial reasons

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Statement from importer

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Export bill of ladingSeal = ML-GB1955628

Import bill of ladingSeal = ML-GB1955628

Seal check findingsSeal = ML-GH0246431

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What would you do?

Canned tuna rejected in Ghana for commercial reasons

Importer states seal is intact but on examination a different seal was found

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Explanation why seal changed

What would you do now?

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Date Product Returned from

Reason for return Cons. Notes

May 07 Hydrolysed collagen GB return USA

Excess stock at delivery address. Product returned to parent company in UK 1

 

Aug 07 Honey Canada Drums damaged during transport 1  

Sep 07 Whey protein concentrate Thailand Exported without health certificate 1 

Oct 07 Sheepskins & cattle hides China FMD in UK 22  

Oct 07 Greasy wool China FMD in UK 2 Rejected (not health marked)

Nov 07 Frozen pork bones for broth

Japan FMD in UK 1 Returned to NL

Dec 07 Dried fish heads Outside EU waters

Exported in error! 1  

Feb 08 Frozen duck feet China Avian flu 1 Rejected (not lot number certified)

Jul 08 Dutch cheese Syria Mouldy (wrapping problem) 1  

Jul 08 Beef, lamb, pork, fish, dairy products

Brunei Meat products destined for Spain loaded in wrong container

6 Saudi importer claimed goods not unloaded and seals not changed but different seals were found and product was in different containers to that certified

Sep 08 Milk powder India Claimed composition problems (“milk fat too low, acidity too high, solubility too low”)

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Dec-08 Hay for pets Korea Did not have required export certificate for Korea

1 

Nov-08 Frozen cheese Saudi Arabia

Non-compliance with commercial specification (poss didn't want to pay)

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Returned hides and skins22 consignments, 936 tonnes,

cattle hides & sheepskins returned from

China between 13 Sept and 19 Oct 2007

due to FMD outbreak in UK.

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Problems with Article 15• Should returned POAOs always be returned to

origin?– Manufacturer c.f. Store– Lack of space– Gone out of business– Wasted journeys– Health risk

• TRACES cannot be accurately completed

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Court judgement in Netherlands• A consignment of goat skins was exported from

Belgium to China. In China the importer didn't want to receive the consignment possibly for financial reasons and sent it back through Rotterdam.

• On arrival in Rotterdam the container was sealed with a different seal, because it was opened in China (said to be by Customs). Belgian colleagues agreed to accept the consignment back provided it met the requirements of article. 15. 1.a.i.

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Problem case• A non-manipulation declaration was received, but

it wasn't clear if it was issued by the official authorities. This was discussed with the Belgian colleagues who agreed the declaration wasn't acceptable. The consignment was rejected.

• The importer from Belgium went to court and the judge decided that this was not a consignment as covered by article 15 and should not be treated according to the procedures mentioned in Dir. 97/78. In other words: this consignment didn't have to be checked at all, because there was no rejection by the official authorities and it was not been unloaded from the original container.