SA = Supporting Attestation
GEFS = Groupage Exporting Facilitation Scheme.
SUPPLIER GUIDANCE
The GEFS System: why you, as a supplier, need to supply back up information in the way of a Supporting Attestation (SA) to help get your goods exported.
When you are supplying goods to an exporter which are then being exported as part of a bigger load, it is important that you provide us with background information that we require in order to help us to be able to sign the Export Health Certificate (EHC) for the Exporter. As the veterinary surgeon responsible for signing the EHC, there are a number of conditions that I am needing to know are true about the source of the product you have sent for export, the way it has been sourced, the way in which it has been handled, processed and manufactured, before I can sign that EHC and send the product on its way. APHA have set up the GEFS system to enable this chain of assurance to be completed from the original source of the product right the way to the point it is sealed into the container for export.
As a result, we need you to obtain a Supporting Attestation (SA) from a vet, every 30 days as detailed below, in order to provide the assurances we require at the EHC end of the chain to be able to sign the EHC certificate. It is vital that any changes in processes are flagged up on the SA, ASAP. Also, I will be asking for specific details as appropriate, depending upon the actual product you are exporting.
If you have any questions, do not hesitate to ask our Vet on 07771 746734 or email david.coombes@cedarfarmvets.co.uk
Note: YOU need to be approved under EU regulations as detailed below .
- GEFS members (ie: the end Exporter) may use time limited (30 calendar days) SAs to provide information from supplier/manufacturing establishments, who are currently approved under (Regulation (EU) 853/2004, or Regulation (EU) 852/2004 for Composite products), to COs at the exporting premises.
- The approval or registration number (as required) of the establishments of origin/manufacturer of the POAO will be part of the SA.
- This document may only be used to facilitate EU export certification of groupage consignments of specific categories of products (including as required under the Northern Ireland Protocol for GB to NI movements of goods)
- These categories are products of animal origin (POAO) for human consumption as listed below and processed pet food that is fully packaged for the final consumer (or purchase in the case of pet food), or to be re-packaged directly at the point of sale to the final consumer. They are products that are produced using only animal content from a traceable network of known suppliers.
Included: Composite products (a), meat products(b), meat preparations (c), processed milk/matured or processed dairy products, fish/fisheries products, eggs/egg products, processed pet food, honey, frogs’ legs, snails and live bivalve molluscs.
Excluded: Live animals, germinal products, fresh meat, raw milk, animal by-products (including raw pet food but excluding processed pet food). Some of these products may be included within a groupage consignment, but they must have been separately certified without the use of a 30 day SA.
(a) See GOV.UK guidance: Export composite food products to the EU from 1 January 2021 . Note that not all composite products require Export Health Certification.
(b) ‘Meat products’ means processed products resulting from the processing of meat or from the further processing of such processed products, so that the cut surface shows that the product no longer has the characteristics of fresh meat. This includes products such as a gelatine which are meat products but require a different EU export certificate to the “meat product” certificate.
( c) Meat preparations’ means fresh meat (including meat that has been reduced to fragments) which has had foodstuffs, seasonings or additives added to it or which has undergone processes insufficient to modify the internal muscle fibre structure of the meat and thus to eliminate the characteristics of fresh meat.
SAs must be fully completed and signed by a suitable representative of the supplying company (see below) and a registered vet (or a CSO acting under the direction of the CO).
Guidance for the person you are choosing to provide the Supporting Attestation (SA)
- The SA must be signed by an individual who has both sufficient knowledge of and responsibility for the relevant parts of the production, transport and storage processes and who has been authorised in writing by the Managing Director (or equivalent) of the supplying company to sign on behalf of the supplying company.
- A registered vet must also sign the relevant section of the SA following a review of the appropriate evidence. When doing so, they will do so in their private capacity as a registered vet and not in their official capacity as an Official Veterinarian (if they also have this authorisation). Official Veterinary stamps should not be used on SAs as these are private documents rather than official documents. This also helps avoid any risk of confusion between SAs and export health certificates.
- Suitable forms of evidence which registered vets may check before signing SAs could include:
- Contractual agreements
- Invoices
- HACCP plans/records
- Standard Operating Procedures (SOPs)
- Traceability records
4. Suppliers should put Standard Operating Procedures in place to define processes and responsibilities required for stable production of the commodity for export, specifying verification of these processes and then the subsequent issuing of SAs and notification of any relevant changes to COs, inspecting vets and exporters if these occur during the period of validity of the SA.
5. Suppliers will be required to gather together relevant evidence to present to the inspecting vet (or CSO working under OV direction). It cannot be signed until this evidence has been inspected and suppliers will need to plan ahead to agree what information will be required by the Certifying Officer and to collate this information before inspections. Suppliers should factor the time required to complete this process into their planning.
6. At the initial inspection suppliers must also be able to demonstrate (to the satisfaction of the registered vet or of the CO directing CSO to perform checks):
• That the relevant health/traceability and processing records for the products included are correct
• That there have been no relevant changes (with exception of changes made specifically to meet new EU-exit dependent requirements or in response to COVID19) within the preceding 30 calendar days
• There have been no such changes in at least four of the preceding six months.
- Registered vets or CSO must also physically inspect at least a representative sample of the products included to verify that their description matches that declared by the supplier, that they are fully packaged for the final consumer, or to be re-packaged directly at the point of sale. Any available identification marking on such products must match that declared in the SA.
- A unique reference number must be given to each original SA used. The number will be generated automatically by the Foodlynx GEFS online system, found in the Export Portal of the website.