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CP Guidance

 

Introduction 

 

Control Points (CP) are inland inspection facilities where SPS checks of plants and plant products can take place, which operate under customs supervision. CPs have the same function as a Border Control Post (BCP), providing the first line of control in maintaining UK biosecurity. CPs are designated by Competent Authorities -- any local or national government department or agency that oversees the legislative and legal requirements to ensure they are fulfilled. This is the responsibility of Defra and APHA. 

Border Control Posts (BCPs) for EU goods will be operational from 1 July 2022, they are purpose-built facilities to enable effective plant health (and other SPS) checks to be performed by specially trained inspectors, helping to maintain UK biosecurity. They will facilitate the efficient and timely flow of SPS goods across the border and service most of GB’s SPS check requirements. 

 

A CP needs to provide the same biosecurity safeguards as a BCP and enable movements away from the border under customs control. Consequently, they must be customs authorised as a temporary storage facility and meet the same minimum requirements as a BCP in terms of facilities and resource to facilitate inspections.  

Prospective applicants are advised to familiarise themselves with the process and conditions for customs authorisation.  

 

This document covers the requirements a facility must meet to be designated as a CP. It includes key information on facilities, application and designation process, as well as other useful information. 

 

Minimum requirements 

There are certain minimum requirements in place that must be met for a premise to be designated as a CP. These requirements are more stringent than for a Place of Destination (PoD), which are a temporary arrangement whilst permanent infrastructure (BCPs) are put in place. Because CPs perform the same function as a BCP, enabling checks before goods enter into free circulation, they must be customs authorised as a temporary storage facility and comply with the conditions for this type of customs authorisation. Consignments that are transported to a CP must enter via a port with a BCP designated to handle plants. 

 

CPs must ensure Plant Health and Seed Inspectors (PHSI) can perform the necessary official controls in a safe and bio-secure manner and that the goods remain under customs supervision until  plant health checks have been completed.  

 

To be designated as a CP, the facility must meet the same minimum requirements as a BCP. These minimum requirements include: 

 

  • a sufficient number of suitably qualified staff to oversee operations 

  • premises and facilities appropriate to the nature of volume of consignments 

  • equipment to enable the performance of checks, including access to WIFI and import IT systems. 

  • arrangements in place to prevent risks of cross contamination and compliance with biosecurity standards 

 

There is not a set number or definition for each requirement, it is based on what is reasonable and required for each site depending on import volumes and commodity types. For example, “sufficient number of staff” will not have a number limit, the definition is based on what is necessary to meet operational and inspection requirements 

 

The requirements ensure that facilities are appropriate for the volume of goods handled so that biosecurity is maintained during storage and inspection, including provision of areas where goods can be detained where there is a suspicion or confirmation of its non-compliance with GB import requirements, such as the presence of a quarantine pest/disease. 

 

The full requirements are set out in Article 64(3) of Regulation (EU) 2017/625 on official controls (OCR) legislation.  

 

Please view our BCP page for more information.  

 

To ensure appropriate biosecurity standards are met, CPs must also provide for: 

  • area for unloading with appropriate cover 

  • inspection rooms/areas 

  • storage rooms/areas 

  • washing facilities e.g. toilets/sinks 

 

These requirements are set out in Commission Implementing Regulation (EU)2019/1014. 

 

For more information, please visit gov.uk.  

 

Also, please visit the BCP page on the Plant Health Portal for further information. 

 

CONTROL POINTS Q&A GUIDE 

Sections: 

 

Who carries out the controls at CPs? 

Plant health controls will be carried out by the Animal and Plant Health Agency (APHA) in England and Wales.  

Scottish Government’s Science and Advice for Scottish Agriculture (SASA) will undertake controls in Scotland.  

The Forestry Commission (FC) is responsible for controls of wood, wood products and isolated bark in England. The devolved administrations in Wales and Scotland request FC support when designating CPs for wood, wood products and isolated bark. 

 

Who can become a CP? 

The movement of goods from the border to a CP will operate under customs supervision, CPs must therefore be approved by Customs for this purpose. Site operators need to follow the process and conditions for customs authorisation as a temporary storage facility which specifies the conditions that must be met. 

Any business can apply to become a CP, but there are eligibility criteria which must be met. CPs must meet the same minimum requirements as BCPs to ensure that they afford the same biosecurity safeguards and enable effective Sanitary and Phytosanitary (SPS) checks to be performed.  

It is also necessary that there is sufficient service demand at a prospective CP to make them operationally viable. This will be assessed based on factors including the likely number of checks which are to be performed at the prospective facility and of which commodities. It is not possible to set precise thresholds given the range of different factors which will be taken into consideration. 

Operators are also required to provide information about their site, such as plans for the layout of the facilities with flow lines detailing the movement of people and goods. Operating procedures will also need to be documented and supplied by the applicant. 

It is expected that the applicant demonstrates that they have robust quality processes in place to manage the inspection process effectively. third-party accredited quality management system that is relevant to the applicant’s business activities will fulfil this requirement. The type of system is not prescribed but examples include ISO standards and industry or trade association specific schemes.  

If the site meets all the minimum requirements, a site audit will be conducted by the Competent Authority to confirm this so the Appropriate Authority can officially designate the site as a CP. The Appropriate Authority is Defra in England, the Scottish Government in Scotland, and the Welsh Government in Wales. 

 

What material can be inspected at a CP? 

Plants or plant products, including high-priority plants and products may be inspected at CPs which are designated for these commodities. 

 

Are there limits to the volumes CP can handle? 

In the OCR legislation, there is no limit to the maximum volumes a CP can handle. However, CPs must have the appropriate facilities to manage the volumes of goods they are forecasting. 

 

Will CP operators be responsible for the same fees as BCPs? For example, stevedore and handling fees. 

The operating costs of BCPs are borne by the operators of those facilities and recovered through commercial fees for their use and provision. Defra play no role in setting those fees.  

Likewise, there will be costs associated with the operation of CPs, and indeed investment to achieve designation. These costs are also borne by the operators of those facilities.  

 

Can a CP operate seasonally?  

Yes, and this is considered in the designation process. 

 

CPs, PoDs and BCPs key information 

 

How do CPs differ from BCPs and PoDs? 

BCPs:  

To qualify as either a CP or BCP, a facility must meet the minimum requirements for a BCP under the Official Controls Regulation (OCR)The main difference between CPs and BCPs are their locations. CPs are often located away from the border and goods are moved to them from the original point of entry (PoE) under customs supervision 

BCPs have the resources, facilities and specialist staff to ensure reliable SPS checks can be performed efficiently and ensure the timely flow of goods through the facility.  

BCPs have long-since been used to manage import inspections of goods from non-EU countries and are an essential component of the UK’s biosecurity regime.  

For more information on BCPs, please visit gov.uk. 

PoDs: 

PoDs were only designed as a temporary arrangement until BCPs were put in place to manage EU imports. Consequently, they are not customs approved; do not need to meet the same standards as BCPs and there is no requirement for them to handle a minimum number of consignments (which we convert to checks) as there is for Control Points.  

The minimum requirements to qualify as a CP are more extensive than for the PoD scheme. A CP needs to provide the same biosecurity safeguards as a BCP. 

 

Why can’t businesses continue to use the PoD scheme? 

The PoD scheme was introduced as a temporary measure to enable the performance of checks on EU imports of high-priority plants and plant products from 1 January 2021 until 30 June 2022. After this date, new BCP facilities will be functioning for all third country trade and will be used to undertake inspections of goods arriving form the EU. 

From 1 July 2022, plant health import checks of EU regulated plants and products must be performed at designated BCPs or CPs. This is to ensure GBhigh standards of biosecurity are maintained and that trade will continue to flow smoothly. 

 

When will the PoD scheme no longer be operational? 

The PoD scheme has been introduced in conjunction with the phased EU>GB plant health import regime and will apply until midnight of 30 June 2022. 

After this date, in general PoDs will no longer be permitted to facilitate plant health import inspections. From 1 January 2022, high-priority plants and plant products will need to be presented for inspection at a BCP or CP. 

 

Facilities and inspections

 

Does the facility have to be fenced or just demarcated from the rest of the premises? 

The Control Point facility must comply with a range of conditions including signage and security as part of the Temporary Storage customs authorisation. The conditions are outlined in Apply to operate a temporary storage facility Temporary Storage area(s) must be marked internally and externally so your goods can be easily identified and located. All other goods arriving, leaving or being stored at the facility which are not subject to Temporary Storage controls should also be easily identified. You will have to adapt your site so it complies with the conditions. 

 

Are there enough inspectors to carry out physical checks at CPs? 

GB plant health services have significantly increased the number of plant health inspection staff to service the demand for import checks in England and Wales of EU plants and plant products. Inspector levels are being monitored to ensure these meet demand and deliver checks in line with set Service Level Agreements (SLA) and ensure minimal trade disruption. 

 

Who can I call to check when the PHSI is likely to arrive at my CP? 

When submitting your pre-notification(s), your application status will indicate whether your consignment has been selected for physical inspectionIf your goods are selected for inspection, they should be moved to the inspection area within the CP. 

Please ensure the inspection details you supply in your pre-notification are accurate, so that delivery teams can manage checks efficiently 

If you have any questions regarding the import of your goods: 

  • For plants and products inspected by APHA, please call the dedicated imports helpdesk at 0300 100 0313 (available between 07.00 until 23.59), or you can email the PHSI Importers helpdesk mailbox: phsi-importers@apha.gov.uk  

  • For wood, wood products and isolated bark inspected by the Forestry Commission, please call the Cross Border Plant Health Service on 0300 067 5155, or alternatively email: plant.health@forestrycommission.gov.uk 

 

Do my goods have to stay in the lorry at CP until they have been physically inspected? 

No, you may unload your plant consignment from the lorry at the CP and store it in a safe and bio-secure manner in a pre-designated and approved location. These requirements are in place to minimise the potential risk of pest escape and transfer 

 

At a CP can a consignment (for example a lorry load of plants on pallets) be unloaded from a lorry and watered if necessary? 

It is fine to water plants to keep them healthy and prevent damage, provided the below points regarding the consignments are fulfilled: 

The operator should make sure that during transport to, and storage at the CP, the consignment is not tampered with or subject to any alteration or change of packaging and closed and sealed properly to reduce the risk of pest infestation and contamination. 

 

When stock is held in isolation at a CP, does it need to be isolated from other imported consignments?  

Yes, you must keep consignments separate to reduce the risk of cross-contamination, such as a quarantine pest spreading to other material. The provision of secure areas for storage of detained goods is a requirement for CP site designation. 

 

What biosecurity measures will CP operators be responsible for? 

Designated plant specific CP facilities must provide temperature-controlled zones, dedicated inspection and bio-secure detention areas and cleaning protocols to avoid the spread of harmful pests and diseases. 

Each facility needs to be outfitted with quality sealed floors, bio-secure seals, and drainage systems that allow inspectors to wash down handling points and stations. If any bio-security concerns are detected on the consignment, PHSIs will immediately isolate a sample and request that the consignment is quarantined until it can be destroyed. 

CPs will also need to be managed under the “separate, isolate, contain, clean” framework. This procedure means that consignments are inspected separately; infected goods are quickly isolated; pests and diseases are contained to prevent spreading; and there are extensive cleaning procedures in place. This framework prevents cross-contamination and ensures the safety of each consignment. 

 

If consignments are flagged for inspection, does a member of staff have to wait with the goods before the inspector arrives?   

A member of staff does not need to wait with the consignment before the inspector arrives. However, a staff member must be available when the inspector arrives to facilitate inspection and to accompany the inspector to the inspection point. 

The composition of the consignment must be maintained until an inspector contacts you and confirms whether the whole consignment needs to be made available for inspection, or if they only need access to certain parts of the consignment. 

In circumstances where an inspector is not available, we may ask for the consignment(s) to be held securely overnight for inspection the next day. 

 

Can businesses work on the plants while waiting for inspectors such as labelling? 

The composition of the consignment on arrival must be maintained until the plant health inspection has been completed. Goods can only be unpacked under the supervision of the inspector. You can move the consignment to the inspection area if requested to do so by the inspector. 

 

Can other businesses use my CP?  

If your business obtains CP status and another business requests to have goods delivered to your CP for inspection, it is at your business’s discretion to grant approval to anyone wishing to use your facility. Defra will not be involved in this process, including overseeing contracts -- it is a commercial arrangement. Businesses must first consider and ensure their CP is able to cope with the additional volume if they authorise the use of their facilities to other businesses. 

Defra has a legal obligation to list all designated CPs online. The lists are published on gov.uk. 

 

Who is responsible for the consignment at CPs and what are the disposal mechanisms if it fails checks? 

Where cases of non-compliance are found, it is the responsibility of the person in control/custody of the consignment to organise disposal or re-export of the goods. APHA and other Competent Authorities will advise you on how to make your consignment compliant or specify the method and date of disposalConsignments may need to be disposed of by specific means, such as deep burial or incineration, to mitigate any potential threat to GB biosecurity 

The CP will be responsible for organising and paying for the disposalThe CP must provide evidence to the Competent Authority that the disposal has taken place. It is a requirement of CP designation that procedures for organising the correct disposal are in place. 

 

Application and designation process 

 

How do I apply to become a CP? 

CP operators must complete a designation Expression of Interest (EOI) sharing their intent to become an operator, details of their facilities and the quantities of the commodities they wish to bring through a CP. CP operators can apply for multiple commodity types including  plants, plant products and high risk food and feed of non-animal origin (HRFNAO). 

Applications for CPs handling plant and plant products: 

Email the below address to obtain the documents at DEFRA-OCR@defra.gov.uk for England and Wales. For Scotlandemail: BCPScotland@gov.scot 

 

What level of activity is needed to be considered for CP designation? 

The first step in the designation process is the submission of an EOI. At this point you will be asked to provide information about the anticipated volume of imports at your site. Based on this the expected inspection level will be assessed and considered along with all the other requirements. You will be informed if your application can progress after this initial assessment. 

    

What is the CP designation process for plant and plant products? 

  1. Submit an EOI application to Defra for CPs in England and Wales or to Scottish Government for CPs in Scotland 
  2. Application is considered by Defra/Scottish Government and Competent Authorities 
  3. If application is accepted, the Competent Authority allocates an inspector to provide advice and support with the application 
  4. Operator submits building plans and supporting documents to the Competent Authority who, in conjunction with Defra, assesses plans for compliance with minimum requirements 
  5. Competent Authorities will inform the operator of a favourable assessment so any necessary construction can start 
  6. Competent Authorities arrange and conduct site visits throughout build to verify compliance 
  7. Competent Authorities provide Appropriate Authority with evidence of compliance after a final site visit and recommends CP designation or, where compliance hasn’t been demonstrated, outlines remedial actions 
  8. Where compliance has been demonstrated, the Appropriate Authority reviews evidence and designates the control point 
  9. The Appropriate Authority will notify operator that the CP has formally been designated for the requested commodities 
  10. Defra lists control point on gov.uk and updates the relevant IT systems 

 

My EOI was accepted, does that mean I’m guaranteed to be designated a CP? 

Compliance can’t be confirmed until the final site visit has been conducted, so having an EOI accepted or plans favourably assessed does not guarantee designation. 

Am I able to appeal my decision if my application has been rejected or if I’ve had an unsuccessful audit? 

There isn’t an appeals process if an application is rejected, however Defra will advise why it was rejected and an operator can resubmit a revised application form if they wish to do so. This will restart the designation process and the new application will be considered by the Appropriate and Competent Authorities. 

If the final audit indicates that the facility is not compliant with legal requirementsthe Appropriate Authority will not be able to designate the CP. In these cases, the Competent and Appropriate Authorities will advise what remedial work is required in order to make the facility compliant with legislation. Operators are responsible for meeting the costs of any remedial work. A new audit to assess compliance will be conducted following the completion of remedial work. 

  

How long does it take to get designated? 

Defra coordinates directly with HMRCBorder Force and other relevant agencies in order to assess applications. The application review depends on several factors and the total time for designations varies depending on the nature of the application. 

Operators also need to allow for time to adapt their facilities to meet the CP infrastructure requirements such as inspection and chilled storage areas. 

For businesses intending to be designated as a CP before 1 July 2022, Defra recommends you complete and email an EOI as soon as possible. 

 

Is there a deadline to apply? 

To ensure your business can be a fully operational CP by 1 July 2022, you should apply as soon as possible. However, Defra will be accepting applications on a rolling basis. 

 

Is there a charge to obtain control point status? 

There is no charge for control point designation. 

 

How can I maintain my control point status? 

Once you have been approved to operate as a CP in order to maintain your status you must adhere to the requirements.  

The Competent Authority will withdraw or suspend the CP designation when: 

  • the CP no longer complies with the minimum requirements 

  • its activities pose a risk to public, animal and plant health 

Yearly CP audits are conducted to confirm compliance. Where APHA detect non-compliances, audits will be conducted more frequently. 

You may also be subject to Border Force audits to confirm compliance to customs conditions. 

 

What happens if my business no longer meets the requirements? 

If your CP does not meet the full requirements after an audit is complete, you will be issued a warning by the Competent Authority. Once a warning has been issued, you must then fulfil the requirements that were identified in the audit within the documented timescale. If a second audit reveals that the facility still does not meet the requirements, the CP designation will be withdrawn. 

For further details, please contact: BCP.Enquires@apha.gov.uk for Wales and England. For Scotland, email: BCPScotland@gov.scot 

 

Customs authorisation  

 

Why does a CP need to be customs authorised? 

Because CPs perform the same function as a BCP and enable checks to be performed before goods enter into free circulation, they must be customs authorised as a temporary storage facility and comply with the conditions for this type of customs authorisation. 

 

How do I become Customs Authorised? 

For details on how to become customs authorised please visit gov.uk for more information from HMRC. 

 

 

 

 

USEFUL ONLINE GUIDANCE 

Please visit the post transition period guidance available on the Plant Health Portal. Please visit gov.uk for guidance on importing and exporting plants and plant products from 1 January 2021. 

Please visit gov.uk for guidance on registering as a CP.  

 

LEGISLATION 

  • The PHR is a set of laws designed to protect plant health throughout the EU. The aim is to prevent the spread of diseases and protect natural landscapes. 

  • It is a set of legal requirements for all EU countries, including GB when it was in the EU. Despite leaving the EU, it is enshrined in law, however, amendments and changes can be made in rare instances. 

 

 

  • The OCR sets out the legal requirements for official controls and official activities at the border to ensure plant health and plant protection of consignments. 

  • It is a set of legal requirements for all EU countries, including GB when it was in the EU. Despite leaving the EU, it is enshrined in law, however, amendments and changes can be made in rare instances. 

 

 

  • This legislation sets out the phytosanitary requirements for the EU, including which pests are risks, need to be monitored closely and which pests can enter the EU. 

  • It is a set of legal requirements for all EU countries, including GB when it was in the EU. Despite leaving the EU, it is enshrined in law, however, amendments and changes can be made in rare instances. 

 

Pests not known to occur in GB, Annex 2, Part A – page 7-15 

Pests known to occur in GB, Annex 2, Part B – page 16 

Provisional GB QPs and EPPO codes, Schedule 2A – page 16-17 

List of PFA QPs and GB PFAs, Annex 3 – page 17-19 

List of GB RNQPs and hosts, Annex 4 – page 19-42 

Measures to prevent RNQPs, Annex 5 – page 42-81 

Prohibited list, Annex 6, Part A – page 81-83 

Prohibited list pending risk assessment, Schedule 6, Part B – page 83-85 

Additional Declarations, Annex 7-10 – page 85-233 

Article 72 products, Annex 11, Part A – page 234-295 

Article 73 products, Annex 11, Part B – page 295-303 

Unregulated list, Annex 11, Part C – page 303-304 

 

ACRONYMS 

ADs – Additional Declarations 

APHA – Animal and Plant Health Agency 

BCP – Border Control Post 

CP- Control Point 

EOI – Expression of Interest 

FC – Forestry Commission 

FSA – Food Standards Agency 

FSS – Food Standards Scotland 

HRFNAO – High Risk Food and Feed of non-animal origin 

IPAFFS - Imports of Product Animals Food and Feed System 

OCR – Official Controls Regulation 

PC – Phytosanitary certificate 

PEACH - Procedure for Electronic Application for Certificates from the HMI 

PoD – Place of Destination 

PoE – Point of Entry 

POFA – Place of First Arrival 

SASA- Science and Advice for Scottish Agriculture 

SPS - Sanitary and Phytosanitary