The Illegal, Unreported and Unregulated Fishing Regulation- Clarification for Importers

12 January 2010

The introduction of the catch certificate regime this year has caused considerable confusion and uncertainty amongst importers.

Although most were aware of the introduction into force of the new regulation, the actual translation form the theoretical into practical was vague to say the least. In response to that, HMRC recently issued a paper aiming to clarify the situation and to highlight the requirements for importers as well as the different “phases” of implementation. This article offers a brief summary of the HMRC paper.

Which UK Authority is responsible for the implementation of the regulation?

The Department for Environment, Food and Rural Affairs (DEFRA) has taken the lead responsibility for the implementation of the new regulation. The necessary validation and checks will be delegated to Port Health and Local Authorities.

What are the arrangements for Customs Clearance?

For imports of fish (and fish product) imports that are covered by the new regulation, HMRC National Clearance Hub (NCH) will require authorisation for release by the relevant Port Health or local authority before customs clearance can be granted.

However, while importers will be required to obtain the necessary catch documentation for qualifying imports and present this to UK Port Health Authorities or equivalent local authorities from 1 January 2010, there will be a phased implementation of the new regulation.

The initial phase (from 25 January 2010)

HMRC National Clearance Hub will require authorisation before clearance for imports arriving by airfreight only to confirm that either IUU checks have been satisfactorily completed or that the import does not require a catch certificate.

Evidence for customs release from 25 January 2010 onwards

From 25 January, you will require one of the following three forms in order to release your products for import:

• A copy of the IUU catch certificate or multiple certificate summary document with a UK Port Health/Local Authority endorsement either faxed or emailed to NCH by the importer, his agent or the relevant Port Health or Local Authority.

• An electronic coded message generated through the port inventory system by Port Health at certain maritime ports.

• A standard Port Health document confirming that the consignment is IUU compliant or not within the scope of the regulation, either faxed or emailed to NCH by the importer or his agent or directly from Port Health.

The next phase (as yet date unknown)

The next phase is likely to be a full rollout covering consignments arriving by all other means of transport arriving at all points of entry in the UK.

Customs Declarations (SAD) requirements to be applied in Phase Two

Importers of fish products listed in Chapter Three and CN headings 1604 and 1605 will be required to declare in Box 44 either:

• An IUU catch certificate is present by entering document code C673 in Box 44 and the catch certificate number or;
• That the goods are exempt from IUU certificate requirements by entering document code Y927 in Box 44.

However, please note that until HMRC notifies the date for the beginning of Phase Two, that import declarations until then should be made as normal.

Approved Economic Operators

Importers that are granted Approved Economic Operator status (APEO) will not be required to present catch certificates at import (although they must still hold and file them). However, in order to achieve APEO status, importers must first hold a Customs AEO certificate. Seeing as applications for APEO status are not yet open in the UK it is advisable that importers start looking at the possibility of applying for AEO status.

How can ITS help?

If you believe that your imports are covered by the new regulation or if you are unsure about the requirements or you would like to discuss the process and requirements for applying for Authorised Economic Operator (AEO) status contact us on (01905) 619229 or alternatively email us at



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