By John Dawes

There has been further confusion arising out of the new European Union health certificates, which came into force on July 1, this time arising from the different ways several EU member states have been interpreting the new legislation. As a result, exporters have faced uncertainties regarding the number and types of certificates that need to accompany a particular consignment, especially when it contains a variety of organisms, such as fish, crustaceans (shrimps, crabs, etc.) and molluscs (snails, clams, etc.), or when stocks arise from different sources.

Currently, each type of organism requires a separate certificate. However, the same model applies to fish, crustaceans or molluscs.

Molluscs (these are cock’s comb oysters, Lopha cristagalli) and crustaceans need separate EU certificates if they are being shipped together, or if either is being shipped in the same consignment as fish. Credit: John Dawes

This is to allow the EU authorities to monitor trade in the various types of organisms coming into its Member States. Since fish, crustacea and molluscs all have different codes and since each certificate is only valid for one particular code, it is necessary to submit separate documents for combined shipments.

While this clarifies the reasons for the separate certificates, it does nothing to resolve the matter of differential charging across the EU.

In several EU Member States, for example, a charge is made per certificate, meaning that inspection costs may triple.

There is also confusion regarding the types of certificates required for fish destined for open systems, such as lakes and rivers, or for closed systems, such as shops. Each requires its own type of certificate: Model IV-B is required for closed ornamental facilities, and Model IVA for open ones. Since the legislation is different for each of these types of facilities, it is essential to use the correct certificate model. Failure to do so can result in corresponding BIP (Border Inspection Post) holdups.

Yet another cause for confusion has arisen in connection with some organisms from separate sources. For instance, in most cases, shipments consisting exclusively of fish (both tropical and coldwater) can be included in a single certificate.

However, in the case of fish or invertebrates that are susceptible to certain diseases, things can be very different. For example, if a Kio consignment consists of fish arriving from a country with an appropriate (and officially recognized) surveillance control and monitoring program in operation, these fish cannot be combined in the same certificate with other fish, even after quarantine. The explanation centers on the need for a certificate to declare on what basis the fish in a shipment should be allowed into the EU. <HOME>