Importing SPS goods. What have we learned?

The DEFRA element is invoiced to us (where we are the responsible party on the IPAFFS/CHED declaration). Whereas the APH element is deducted from our prepaid account balance as there are no credit terms offered by APH.

Since the introduction of these charges we have paid over £½million in fees on behalf of our clients and continue to incur these charges from DEFRA and APH as part of the import process as required.

So, what have we learned?

1. Nobody likes the fees!
2. The fees are unavoidable and form part of the GB import process.
3. Many blame us for the fees when in fact we are purely the messenger here – we incur these costs on your behalf for your goods to keep moving.
4. DEFRA have issued their first invoices, which we have paid. What happens if a trader or agent does not pay for any reason? – DEFRA may have to restrict ongoing access to the IPAFFS portal for ‘bad debts’.
5. Some agents are avoiding the charges by completing the IPAFFS/CHED declaration in a way that forces the DEFRA charges to be raised directly to the trader, often without the trader’s authority. In such cases, the trader may also find they are being charged for movements that are not theirs.
6. Some agents are side-stepping the charges by deliberately entering an incorrect port of arrival (ie not Dover or Eurotunnel) – this is both non-compliant and very dangerous – the fees will find you eventually and may come as a rather large shock later in the day.
7. The number of lines on an IPAFFS/CHED is not as simple as taking the number of different commodity codes. Where, for example, there is the same commodity code but two different species (think cow’s milk cheese and goat’s milk cheese) this will be two separate lines on an IPAFFS/CHED (so 2x£10 for LOW risk as an example).
8. The minimum charges, particularly for MEDIUM risk categories, are misleading and easy to misunderstand, see below.

Minimum charges

For LOW risk categories, we are able to ‘bunch’ the products onto one IPAFFS/CHED declaration.   This is NOT possible for MEDIUM risk if there are multiple Export Health Certificates (EHC’s) involved.   This is where the misunderstanding starts. There is not one type of EHC, there are multiple versions, depending on the nature of the goods. A full list of the EHC model templates can be found here: https://www.gov.uk/government/collections/health-certificates-for-animal-and-animal-product-imports-to-great-britain

We are required to submit a separate IPAFFS/CHED for each EHC.

Not a separate line on the same IPAFFS/CHED but a separate declaration altogether. So, where the CUC clearly states that the DEFRA element is £29 (subject to a max of 5 CHED lines) and the APH is a minimum of £66 (up to 6 tonnes) – this is per IPAFFS/CHED and NOT per shipment/consignment. For example, one shipment of say 100kilos containing two different EHC’s will attract the DEFRA charge of £29 and an APH charge of £66 (totalling £95)…twice! Once for each EHC requiring a separate IPAFFS/CHED.   Many traders have been caught out by this charging mechanism and incorrectly assessed their expected costs.

The ‘up to 6 tonnes’ is per IPAFFS/CHED and NOT per consignment.

We continue to make representation to the Government and have already suggested several ways that the process could be improved. For now, like you, we have to live with it and we continue to act in your best interests so that imports can be completed correctly and, above all else, compliantly.