Wholesaler importing requirement changes
As of 1st January 2021, the UK will no longer be part of the EU
As such, we anticipate changes to the licensing scope for some businesses that import organic food, drink or feed products from the EU after this date
Understanding what your certification covers currently
- Processor licences usually have a prefix of DA or P in the licence number, and cover processing, labelling, importing or any activities where you make changes to products or their labelling
- Wholesaler licenses have the prefix WA in the licence number, and cover only the trading of pre-packaged products with no processing, repacking or labelling activities
- Processor licences are required to be inspected annually, whereas wholesaler licences are inspected initially, and every 3 years after that
- If you’re not sure if importing is within the scope of your licence already, check your most recently issued trading schedule
Processor clients who intend to import from the EU from 2021
Businesses currently issued a Processor licence who import ingredients from the EU, but do not currently have ‘importing’ within the current scope of their licence will need to complete a 'Description of Importing Activities Form.' This form should be completed and returned to your Certification Officer at the earliest opportunity. There will be no change in applicable fees for the addition of this enterprise.
Wholesaler clients who intend to import from the EU from 2021
Businesses currently issued a Wholesaler licence who intend to import ingredients from the EU will be required to either:
- Transfer their licence to a processor licence, or
- Where continuing both wholesaling of pre-packaged goods* purchased from the UK AND importing of products from the EU, set up an additional Processor licence to cover the imported products
- If a business already has a Wholesaler licence AND a Processor licence, ensure your Processor licence lists the imported products on the trading schedule
- You will need to complete a Description of Importing Activities Form to add the importing activity if it’s not already listed on your Processing licence trading schedule
If you require either a transfer of licence type, or an additional licence, to ensure sufficient time to make required changes before the end of the transition period, we recommend you contact the team before Tuesday 10th November.
We anticipate receiving a high volume of queries and requests to change certificate scope, as well as other Brexit related queries. Please be reassured we're putting the resource in place to respond to all of these; however, we ask you do not chase for a response – all enquiries will be processed and responded to as soon as is possible.
*Whether a product is pre-packaged is defined in EC no 2000/13 art 1.3 (b) - Pre-packaged is defined as any single item for presentation as such to the ultimate consumer, and to mass caterers, consisting of a foodstuff and the packaging into which it was put before being offered for sale, whether such packaging encloses the foodstuff completely, or only partially, but in any case, in such a way that the contents cannot be altered without opening or changing the packaging.
UK Certificates of Inspection for imported consignments
From 1st January 2021, all consignments of organic products imported from the EU will need to be accompanied by a UK certification of inspection (CoI) in order to be sold as organic in the UK. Please refer to our importing guidance for more details.
Changes to your fees
Transfer from Wholesaler to Processor
Where EU Wholesalers licensees have transferred their license to a full Processor licence, a pro rata invoice for the difference between the existing Wholesaler fee (£205 +VAT, plus cost of inspection every third year at £397 +VAT) and the new Processor fee (£750 +VAT) will be issued for the remainder of the current certificate period.
We recognise Brexit means changes that businesses may not have planned for, so we're pleased to offer those transferring to a Processor license the first full year of certification at our lowest available fee. A declaration of sales will be required at the end of your first full year as a Processor, and a levy fee - based on sale of products on your Processing license only - will be applied for future billing.
What if I want to add a Processor licence and retain a UK Wholesaling licence?
Fees would apply, as above, and a fixed Wholesaler licence fee would be added to the annual Processor fee.
What if I currently hold both licence types?
Please contact your Certification Officer to discuss how transfer of imported products to your Processor licence, or the closure of your Wholesaler licence (where all products are imported), would affect your fees.
For full details of our fees, please refer to our published fees document.