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PHEATS FAQs

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PHEATS FAQs

Contents

 

Eligibility and Registration

 

If there are multiple sites across England and Wales for one company, will they require individual PHEATS applications? 

Yes, the Biosecurity Control Management Plan (BCMP) is specific to each individual site and therefore each site will require an individual application.

Why doesn’t the scheme cover plants for planting? 

Plants for planting presents a higher risk than produce for the potential movement of pests as any pest will arrive with host and does not necessarily need to transfer to a suitable host, making introduction (this is entry and establishment) more likely.

The European and Mediterranean Plant Protection Organisation for example, cited in a report on the risk of imports of plants for planting that they, and in particular ornamentals, are regularly described as hosts for a large number of introduced pests. The trade of ornamentals is often identified as a major contributor to introductions, with characteristics such as huge volumes, rapid changes in the plant species traded and their origins, rapid transport allowing survival of pests and hitch-hikers, together with the occurrence of suitable habitats at destination.

The Plant Health Exports Audited Trader Scheme (PHEATS) allows for the delegation of the inspection action for produce and cut flowers as these present a lower risk, however even at this level of risk there is still considerable requirements expected to be met through the BCMP.

How long will it take to become registered?

This will be dependent on whether application eligibility requirements are met or if further information is required. It is generally expected that successful applicants may take 3-6 weeks to complete the approval process from the submission of the initial application.

Is there a template for a BCMP?

The requirements for the BCMP are stated in Annex I of the External User Guide. The items stated in parts A-B must be provided electronically to the PHEATS mailbox. Items stated in part C must be demonstrated at the initial site inspection.

Is the scheme open to all of the UK?

At present the scheme is only available for exports of fresh produce and cut flowers from England and Wales.

 

Training

 

What if the Authorised Person(s) or the Person Responsible (PR) doesn’t pass the training/assessment?

The training is designed to slowly build up your expertise in plant health by starting with fundamental plant health principles and then focusing on the more technical aspects of phytosanitary requirements. Each module will have a knowledge test to ensure that the information presented has been understood by the individual. A knowledge test can be taken multiple times, but each test will be recorded on the system. This will help inspectors identify any areas where there may need to be some reinforcement in a particular subject area.

You may access the training multiple times, however, if an individual is unsuccessful you can opt to remove them as Authorised Person(s) or the PR, but an alternative should be found.

Can a PR give training to other PRs?

Only the PR and Authorised Person(s) who have passed the APHA training modules and initial site inspection assessments are authorised to act under PHEATS.

New Authorised Person(s) must complete the APHA training in full to be authorised; internal training by the PR or Authorised Person(s) will not count as official training which will allow an individual to undertake inspections as part of PHEATS.

How long will the online training take?

There are several modules to read in the online training, covering international obligations, export procedures, pests and diseases and impartiality and conflict of interest. The PR and all Authorised Person(s) must read each module and complete each knowledge test. It is anticipated this would take 2-4 hours to complete.

What if questions are answered incorrectly on the online knowledge test?

The correct answer to each question will be confirmed as the applicant progresses through the knowledge test. The responses will be reviewed and further training provided in relevant areas at the initial site inspection.

 

Initial Site Inspection

 

How long will the initial site inspection take?

The time on site will vary depending on whether action needs to be taken to being the site in line with the BCMP. This may also require repeat visits. At this visit, inspection training will also be provided and repeat visits may be required if the PR or all Authorised Persons are not able to be present. It is anticipated the initial site inspection would take 2 hours to complete.

 

Export Process

 

How do I obtain a phytosanitary certificate for export to the EU?

You should contact your local plant health inspector to determine the plant health requirements for the goods that you are exporting. For regulated plants and plant products, you will need to have registered via the IT system PHES.

How do I register for PHES?

Information can be found on the GOV.UK on how to register for PHES.

What documentation will be required for export applications?

Any documents that help an inspector to identify a consignment will be required, such as the commercial invoices containing commodity codes, and packing lists. Where applicable there may be the requirement to provide documents such as fumigation certificates as evidence to show consignments have been treated appropriately. Furthermore, although not applicable to EU trade, exporters may have to provide import permits that detail the requirements of the importing country.

How do I make an export application?

There is some information available within the User Guide. Further to this information related as to how to make an export application on PHES can be found here: Apply for plant export certificates and inspections - GOV.UK (www.gov.uk).

How will exports of goods that are not of GB origin be certified?

De-regulated produce imported into GB does not need to be accompanied by a PC. However, if such goods are then re-exported back to the EU or NI (and they are regulated in the EU), a GB PC will be required to accompany the consignment.

In order for the GB plant health services to issue the PC:

  • If the goods originate from a non-EU country and there are special import requirements which can only be attested to by the plant health service in the country of origin, the GB plant health service will require a PC from the non-EU country of origin confirming the EU special import requirements have been met. E.g. Citrus, mangoes, cherries and other Prunus.
  • In all other cases, e.g. if there are no such special import requirements or the goods originate from the EU, then the GB plant health service will not require a PC from the country of origin. 

If the client has sourced commodities via a third party, how can they proceed with an export if they do not have access to the original PC or the IPAFFS application number?

It is the exporter’s responsibility to provide the relevant documentation to demonstrate how the consignment meets the requirements of the importing country. If the exporter cannot obtain this information, the export will not be able to proceed. This is also the case for non-PHEATS exports.

Are goods originating from Great Britain (GB) subject to a lower inspection rate?

The inspection rate is the same regardless of the origin of the commodity. However, you can inspect more than the specified rate. All commodities will need to be free from Union Quarantine Pests (UQP).

Can applications be entered in advance of the inspection?

Applications may only be entered on to PHES after the inspection has taken place by the Authorised Person. 

A completed export application via PHEATS, submitted on PHES is confirmation by the authorised person(s) that the commodities that have passed the inspection and so cannot be entered in advance.

How should the PR or Authorised Person(s) record the inspections?

The details required to be recorded are stated in Annex I of the External User Guide.

This can be in any format suited to the business, for example Excel. If notebooks are used these must be retained once completed. You can record more information than is stipulated in Annex I of the External User Guide.

All records of inspection should be made available upon request to an inspector.

When should the export inspection be carried out?

The phytosanitary certificate is valid for 14 days from the date of issue to the export of the consignment. The inspection should be carried out as close to the point of export as possible, and the plant health status of the consignment must be maintained following this inspection.

This may include inspections on the packing line, if the above criteria have been met.  

Are individual phytosanitary certificates required for each commodity I want to export?

No, a single phytosanitary certificate can be issued for multiple product lines and indeed multiple commodities in a single consignment, provided the goods meet the import requirements of the destination country.

Will every export have to have copies of all import PCs from the original imports?

Yes, if your goods are not of GB origin and are subject to special requirements. You will also need to make sure that the original PCs contain any of the additional declarations (AD) (special requirements) needed for certain commodities. This additional information will need to be included on the PC and must confirm that the goods meet the EU’s import requirements.

 

Phytosanitary Certificates (PC)

 

Can traders issue their own phytosanitary certificates? 

No, traders cannot issue their own phytosanitary certificates. Phytosanitary certificates can only be issued by the country’s National Plant Protection Organisation (NPPO). For England & Wales this is APHA, as an Executive Agency of Defra..

Who can apply for phytosanitary certificates under the scheme?

Any traders authorised under the PHEATS scheme may apply for PCs. If you are not authorised to export under the PHEATS scheme you will be able to export under the normal export procedures. Further information on this can be found on gov.uk.

How will phytosanitary certificates be issued?

Phytosanitary certificates issued under the PHEATS scheme will be issued centrally by the Centre for International Trade (CIT) for England and Wales. An electronic, scanned copy of the PC will be emailed to you. This electronic copy of the PC can then be provided to the importer in the EU or Northern Ireland to be uploaded as part of their pre-.

The original phytosanitary certificate will then be mailed out to you within 24 hours. This will need to be provided to the NPPO as soon as technically feasible thereafter.

This process is currently in place due to the current COVID 19 easement and is legislated for by the EU. Should the requirements change you will be notified prior to this happening.

Are there any fruits, vegetables or cut flowers that can’t be exported?

Only fruits of Momordica L. originating from third countries or areas of third countries where Thrips palmi Karny is known to occur, and where effective mitigation measures for that pest are lacking. This will be checked by CIT before exporting to ensure that your consignment complies.

Are there any fruit or vegetables that don’t require a PC for export to the EU?

Some fruits do not require a PC (pineapple, coconut, durian, bananas and dates) are already exempt from the specific phytosanitary controls outlined for most imports. These consignments will continue to not be subject to any border requirements.

Where can I find out further information related to pests and diseases?

There are several sources highlighted during the training that can be used, but can include, the Plant Health Risk Register, Plant Health Portal, or the EPPO database.

 

Audits

 

Why is the audit process based on a timescale e.g. monthly rather than the number of consignments being exported?

The Authorised Person(s) are authorised to carry out the official phytosanitary inspection function; whether that is for one consignment or many. Audits may come in the form of announced or unannounced and AP's will be expected to demonstrate that they are still competent in conducting a plant health inspection.

How long will the audit take?

The time on site will vary depending on whether non-conformities are identified, and what action is required. A demonstration of an export inspection must also be provided by the PR or Authorised Person(s) at the audit and a short assessment completed. It is anticipated an audit would take 1 hour to complete.

 

Fees

 

If a Head Office wants to submit the export application, but the inspection is carried out at a depot, which site will be invoiced?

The applicant will submit their application using their PHES account, stating the site address of the inspection using the Post Code search function, this must be an approved site as stated in the biosecurity control management plan. There is a procedure for invoices to be sent to a different address than that of the applicant clients, if required. Please contact CIT for further information if required.

I export seasonally, will I still have to be audited even though I’m not exporting?

You can pause your participation in the PHEATS scheme, if you no longer intend to export. This may be due to seasonal trades.

You can still continue to export, should you have any ad hoc exports by submitting applications for inspections by PHSI. Any plant health service provided will be subject to the relevant inspections, fees and service level agreements.

Will there be any fees for movements to Northern Ireland?

Under PHEATS for movements to NI, there will be no fees. This is due to the Movement Assistance Scheme (MAS) that is currently due to run until 2025. Fees associated with PHEATS, excluding the issuance of the PC fee, were introduced as part of MAS from the 1st  July 2021, this includes the initial registration fee and the fee associated with ongoing audits.

 

I move goods to both the EU and NI under PHEATS, which fees are defrayed?

If you export to the EU and NI under PHEATS, only the cost of PCs for NI movement will be defrayed.  You will be charged the full fee for the initial site visit, audits and phytosanitary certificates for movement to the EU.

Will there be any fees for exports to the EU?

Yes. Plant Health services operate on a basis of full cost recovery. Fees will be charged as they currently are for exports to third countries.

 

Non-compliance

If a company operates from multiple sites under PHEATS, if a critical non-compliance is identified at one site, will action be taken at all the sites?

All the sites authorised under PHEATS will be operating in accordance with their own BCMP, with associated PR and Authorised Person(s) carrying out inspections there. Audits are carried out on this basis, and so any non-compliance identified at a site will be subject to action at this site only.

If during investigation into a non-conformity another site is implicated, for example a trace-back for a pest identifies another site, action will be taken in accordance with usual Plant Health procedures, but such action may be taken into consideration at the audit of that site as well.

 

Appeals

 

Is there a charge to appeal a decision?

There is no fee associated with submitting or the consideration of an appeal.

How do I appeal a decision?

Further information related to appeals can be found within the External User Guide.

 

Miscellaneous

 

Have other countries got similar schemes?

Yes, the IPPC allows the delegation of certain phytosanitary actions, and this option has been implemented for a number of trades moving around the world, for example the movement of seed to New Zealand from the UK, and the movement of timber from Canada to the EU. Similar schemes are also in operation in the EU.

If the scheme is successful for produce and cut flowers, are there plans to roll PHEATS out to other export sectors?

From Monday 9th September 2024 ware potatoes are eligible for export under PHEATS.

What if the PR leaves the company?

An Authorised Person may take on the role of the PR but must sign a new application form to agree to the Terms and Conditions of the scheme.

A person not previously associated with the scheme may also take on the role of the PR if they successfully complete all the necessary training and assessments provided by APHA , in addition to signing the Terms and Conditions.

Can a client opt for a blended approach of using PHEATS for some produce exports and PHSI for others?

Acceptance on to the scheme does not preclude the option of submitting applications for inspections by PHSI. Any plant health service provided will be subject to the relevant inspections, fees and service level agreements.

Full records must be kept of inspections carried out under PHEATS.

Can a company that is not PHEATS registered use a PHEATS registered site for exports?

A BCMP is required for each PHEATS site, and associated Authorised Person(s) / PR are authorised to complete inspections on eligible commodities under the PHEATS scheme. Other businesses operating out of a PHEATS registered site may use the PHEATS site and Authorised Person(s) / PR for exports with prior approval. The BCMP for the PHEATS registered site must be updated to reflect this change and emailed to pheats@apha.gov.uk for England and Wales.

Only the PHEATS approved Authorised Person(s) / PR may carry out inspections under PHEATS, which must be done in accordance with the accepted BCMP at the approved site and before applications for PCs are submitted. The PHEATS business remains responsible for APHA invoices. If a non-PHEATS approved business wishes to use their own employees to carry out inspections, they must complete the full registration process for the scheme. Eligible

Does my Wood Packaging Material (WPM) need to be ISPM 15 compliant?

All wood packaging material (WPM) moving between GB and the EU and being exported to Northern Ireland must be treated and appropriately marked in compliance with international standards (ISPM 15). As long as the marks are legible, pallets are compliant and can be used multiple times. Contact your supplier or TIMCON if you need more advice. 

When will the UK move to using ePhyto? 

The UK is aiming to introduce the capability to exchange ePhytos during 2021.  Discussions between Defra and the IPPC ePhyto Solutions IT team are ongoing. 

Once connected to the ePhyto solution Defra will begin bilateral negotiations with the National Plant Protection Organisation of trading partners who are using the ePhyto solution to seek agreement for the exchange of ePhytos with the UK.  Until agreement has been reached paper PCs will continue to be required for exports and imports. 

For those countries not using the ePhyto solution paper PCs will continue to be required for exports and imports 

Will the scheme be audited by other countries?

Possibly, the importing country may choose to undertake an audit of out phytosanitary system, which may involve audits of registered sites as well as the authorised and responsible persons.

 

Ware Potatoes

 

Do I need to complete all of the produce modules if I only export ware potatoes?

If you only export ware potatoes through PHEATS you do not need to complete the modules for fresh produce and vegetables, or cut flowers

I am exporting potatoes directly from the field, can I use PHEATS?

Where potatoes are exported immediately after lifting, they must be brought to the designated inspection and quarantine area in line with the requirements of the BCMP for inspection.  Inspection in the field is not permitted.