EU Exit & trading after end of Transition Period – Animal By-products & derived products

Please see below some answers to the most common questions our members and their customers have at the moment relating to the trade and movement of animal by-products and derived products.

 NOTE: The answers provided are based on our current understanding only and are subject to change. They must not be relied upon as reflecting the official UK Gov position and FABRA UK takes no responsibility for the accuracy of this information. See terms, conditions & disclaimer.

Q1. What tariffs will apply to rendered products for export to the EU?

WTO tariffs will apply if no FTA is reached with the EU. All depends on what the product is called or categorised as. Refer to www.WTO.org

Q2. Can I export mixed processed animal protein (PAP) to the EU if there is no deal?

At the moment the UK will be a third country so the export health certificates for 3rd countries must be used. For ruminant PAP this requires manufacture using method 1 – pressure sterilisation. See certificate at annex XV, Chapter 1 of EU142/2011 and the Border Protocol Delivery Group Border Operating Model

Q3. Can I export category 3 tallow to the EU for technical uses such as biodiesel manufacturing feedstock?

Yes but the export health certificates for 3rd countries must be used. This requires GTH marker to be added to Category 3 tallow before export. See certificate at annex XV, Chapter 10B of EU142/2011 and the Border Protocol Delivery Group Border Operating Model

Q4. Can meat & bonemeal (MBM) from the EU be sent to the UK for incineration?

At the moment it is illegal under EU law for MBM to be exported from the EU to 3rd countries for incineration.

The EU is considering amending their Regulations to allow the export of MBM outside the EU for combustion but this has not been approved yet.

If approved then the UK sites currently incinerating EU derived MBM would need to be approved / permitted under the ABP Regs and Environmental Permitting Regs for combustion of MBM.

The UK has not yet confirmed its position on whether MBM is a waste or can be considered as a fuel. See also the Border Protocol Delivery Group Border Operating Model

Q5. Can animal by-products (ABPs) be moved from Northern Ireland to GB?

ABPs would need to come from an NI registered or approved ABP premises and the consignment must be physically dispatched from those premises.

Consignments and commercial documents would be required as per current traceability systems.

Category 3 raw ABPs from NI slaughterhouses can be transported to GB directly from slaughterhouse in line with existing listing requirements for slaughterhouses..

Products of animal origin (POAO) – must have UK/NI health or ID marks where required in accordance with legislation in NI/GB.

Q6. How will the movement of Category 3 ABPs raw material from Republic of Ireland to UK be affected?

If animals raised in and transported from ROI to NI for slaughter then the animal by-products arising are deemed to be of NI origin and can be processed in NI or GB rendering facilities.

We are still awaiting confirmation of rules on movement of ABPs from ROI slaughterhouses north to NI and GB. See also the Border Protocol Delivery Group Border Operating Model

Q7. Can I move Category 3 animal by-products and feathers from NI to south?

We are still awaiting confirmation of rules on movement of ABPs from NI slaughterhouses south from NI to ROI. See also the Border Protocol Delivery Group Border Operating Model