England has confirmed updates to import controls for high‑risk food and feed of non‑animal origin (HRFNAO). The instrument was made on 3 November 2025, laid before Parliament on 5 November 2025, and takes effect on 1 January 2026. It amends assimilated Commission Implementing Regulation (EU) 2019/1793 in relation to England, using powers in the General Food Law and the Official Controls Regulation and following statutory consultation requirements.
The core drafting change is terminological but operationally important: all references to EU CN codes and TARIC sub‑divisions are replaced with a single UK “commodity code” reference. A new definition cross‑refers to the customs tariff established under section 8 of the Taxation (Cross‑border Trade) Act 2018, aligning HRFNAO controls with the UK Integrated Online Tariff used for customs declarations.
Annex I to 2019/1793 is replaced for England. This Annex lists non‑animal products from specified countries that are subject to a temporary increase in official controls at border control posts and control points. The structure of the Annex remains familiar to importers: entries are listed by commodity code, country, hazard, and include prescribed frequencies for identity and physical checks determined by risk assessment.
Annex II is also substituted for England. This Annex sets special conditions for commodities with defined contamination risks, such as aflatoxins, pesticide residues, ethylene oxide and microbiological contamination, and requires consignments to be accompanied by an official certificate and recent laboratory analysis issued by a competent authority. The strengthened requirements for Listeria controls introduced in 2024 remain incorporated.
Annex IIa is updated in presentation: the “CN code” column is renamed “Commodity code” and the separate TARIC column is removed, reflecting the shift to UK tariff nomenclature. The change is intended to reduce classification ambiguity at the point of entry and to match how importers already declare goods in the UK customs system.
Footnotes in the substituted Annexes are rationalised to streamline references to sampling procedures and analytical methods. Where testing is required, sampling and analyses must follow the methods referenced in the Regulation (for example, multi‑residue GC‑MS/LC‑MS screening for certain pesticides and accredited laboratory reporting under ISO/IEC 17025).
For consignments within Annex II, model certificates and laboratory reports must travel with the goods, and importers should expect verification of documentary compliance at the border. Government guidance confirms that HRFNAO entries require pre‑notification and certification on a CHED‑D via IPAFFS before arrival at a designated point of entry.
Operationally, the move to UK commodity codes means trader systems should map HRFNAO risk controls to the codes used in customs and logistics software. Importers should review tariff classifications now, ensure the correct CHED‑D is raised in IPAFFS, and cross‑reference document codes in the Customs Declaration Service so that risk‑based controls can be applied without delay.
Compound foods containing listed Annex II ingredients may also fall in scope where thresholds are met; businesses should review recipes against the commodity‑specific entries and ensure any required certification and analyses are available at pre‑notification. Government guidance provides a practical route‑map for assembling certificates and laboratory reports.
These changes apply in relation to England. Consignments routed through English border control posts will be subject to the updated Annex I and II lists and to the commodity‑code presentation from 1 January 2026. Importers should also account for existing border processes, including pre‑notification timelines and any applicable common user charges at government‑run facilities such as Sevington.
Businesses should keep pesticide maximum residue level considerations in view when commissioning analyses. Great Britain applies MRLs under assimilated Regulation (EC) No 396/2005, with the GB statutory register used to set and amend national limits; documentary packs should demonstrate compliance against the relevant GB MRLs where required.