Key Takeaways
- High-risk food and feed of non-animal origin (HRFNAO) must enter GB through designated Border Control Posts only
- IPAFFS pre-notification is mandatory before importing HRFNAO — failure to notify results in consignment rejection
- Mycotoxin limits apply to specified foods whether imported or produced domestically in the UK
- The Official Controls Regulations 2025 updated high-risk food lists and special conditions from 1 January 2026
- Triangular trade rules mean GB restrictions apply even if goods transit through third countries without processing
What Makes Food High-Risk?
The Food Standards Agency (FSA) classifies certain foods and feed as high-risk based on their potential to contain hazardous contaminants. High-risk food and feed of non-animal origin (HRFNAO) faces enhanced controls at GB borders to protect public health.
Food is classified as high-risk when testing reveals non-compliant levels of specific contaminants. The three primary hazard categories are mycotoxins and aflatoxins, pesticide residues, and pathogenic microorganisms such as Salmonella and Listeria.
Mycotoxins are toxic compounds produced by moulds that can contaminate crops during growth, harvest, storage or transport. Aflatoxins, produced by Aspergillus fungi, are particularly concerning due to their carcinogenic properties. The FSA maintains maximum levels for different mycotoxins across various food categories.
Pesticide residues exceeding Maximum Residue Levels (MRLs) trigger high-risk classification. The UK monitors imported produce for pesticide compliance, with certain countries and commodity combinations subject to increased testing frequencies based on historical non-compliance rates.
Pathogenic microorganisms present acute food safety risks. Salmonella contamination in spices, sesame seeds, and certain nuts has prompted specific import controls. Listeria monocytogenes in ready-to-eat products similarly triggers enhanced border controls.
The high-risk designation applies regardless of whether the food is imported or produced domestically. However, import controls provide a critical checkpoint before contaminated products enter the UK supply chain. Importers must understand which products face HRFNAO restrictions and plan accordingly. Those importing food products should also review guidance on UK import duty on food for complete cost planning.
Border Control Post Requirements
All HRFNAO consignments must enter Great Britain through designated Border Control Posts (BCPs). Not every port or airport operates a BCP, and not all BCPs accept HRFNAO — importers must verify their chosen entry point is authorised for high-risk food handling.
Border Control Posts are staffed by port health authorities with specialist facilities for documentary, identity and physical checks. Documentary checks verify certificates, lab results, and pre-notification documentation. Identity checks confirm the consignment matches accompanying paperwork. Physical checks involve sampling and laboratory analysis.
Designated BCPs for HRFNAO include:
- Port of Felixstowe (Suffolk)
- Port of Southampton (Hampshire)
- Port of Tilbury (Essex)
- Port of Liverpool (Merseyside)
- Heathrow Airport (London)
- East Midlands Airport
- Dover Eastern Docks (Kent)
- Port of Hull (East Yorkshire)
This list is not exhaustive and changes periodically. Before shipping, verify your chosen BCP accepts your specific commodity using the FSA’s BCP finder tool. Some BCPs specialise in certain product categories — a port handling nuts may not accept spices. Understanding the full customs clearance process helps coordinate BCP inspections with customs declarations.
When a consignment arrives at a BCP, it undergoes risk-based checks. The frequency of physical checks depends on the product category and country of origin. High-risk products from countries with poor compliance histories face near-universal physical inspection. Products with good compliance records may be checked at lower frequencies.
If sampling is required, the consignment cannot be released until laboratory results confirm compliance. Importers can request onward transportation to a customs-controlled warehouse or ETSF (Examination and Temporary Storage Facility) while awaiting results. This requires port health authority agreement and ensures the consignment remains under customs control.
Pre-Notification and IPAFFS System
The Import of Products, Animals, Food and Feed System (IPAFFS) is the mandatory pre-notification platform for HRFNAO imports. Importers must submit notification before the consignment arrives in GB — failure to pre-notify results in automatic rejection at the border.
IPAFFS pre-notification requirements:
- Submit notification at least one working day before expected arrival
- Provide commodity code, country of origin, and consignment details
- Upload laboratory test certificates where required
- Pay applicable inspection fees
- Receive unique notification reference number for customs documentation
The one-working-day minimum is a legal requirement. In practice, submit notification earlier — ideally when goods are shipped — to allow time for corrections if the system flags errors. Last-minute notifications risk delays if documentation requires amendment.
Laboratory test certificates must accompany pre-notification for products subject to special conditions. These certificates must be issued by accredited laboratories in the country of origin and confirm compliance with UK maximum levels for relevant contaminants. Certificates older than the product’s shelf life or issued before harvest are invalid.
Each IPAFFS notification generates a unique reference number. This reference must appear on customs declarations and commercial documentation. Border Force officers use this reference to link your customs entry with the FSA pre-notification — mismatched or missing references cause clearance delays.
After submission, monitor your IPAFFS dashboard for status updates. The system will indicate whether your consignment is selected for documentary, identity, or physical checks. If selected for physical inspection, coordinate with the BCP to arrange sampling and laboratory analysis.
Specific Product Restrictions and Limits
The FSA maintains detailed restrictions on specific products known to present elevated contamination risks. These restrictions apply regardless of the country of origin and are enforced through border controls and domestic surveillance.
Soy sauce and hydrolysed vegetable protein: 3-MCPD (3-monochloropropane-1,2-diol) is a processing contaminant found in some soy sauces and hydrolysed vegetable proteins. The UK limit is 0.02mg/kg for liquid products and 0.05mg/kg for dry matter. Consignments exceeding these levels are destroyed or re-exported.
Jelly sweets and confectionery: E425 (konjac gum) is prohibited in jelly sweets due to choking hazards. Products containing konjac in jelly form cannot be imported or sold in the UK. This restriction stems from documented choking incidents involving children.
Kava-kava: Import of kava-kava (Piper methysticum) is banned in the UK due to hepatotoxicity concerns. Products containing kava-kava as an ingredient are subject to seizure and destruction. This ban applies to herbal supplements, beverages, and traditional medicinal products.
Spices and palm oil: Illegal dyes, particularly Sudan dyes, have been detected in some spice imports and palm oil consignments. Any detectable level of unauthorised colourants (>0.5ppm) renders the consignment non-compliant. Testing for Sudan dyes is routine for high-risk origin countries.
Aflatoxins in nuts and dried fruit: Maximum levels vary by product category. For aflatoxin B1 in ready-to-eat nuts, the limit is 2 micrograms per kilogram. Total aflatoxins (B1, B2, G1, G2 combined) must not exceed 4 micrograms per kilogram. Brazil nuts face particularly stringent testing due to historical contamination patterns.
Cereals and cereal products: Deoxynivalenol (DON), ochratoxin A, and zearalenone have established maximum levels in cereals. Wheat, maize, and barley imports are routinely sampled for these mycotoxins. Organic cereals face enhanced testing due to higher contamination risk without fungicide treatment.
These restrictions are updated periodically based on surveillance data and emerging risks. Importers should subscribe to FSA alerts to receive notifications of new restrictions or changed limits affecting their product categories.
2025/2026 Regulatory Updates
The Official Controls (Import of High-Risk Food and Feed of Non-Animal Origin) Regulations 2025 came into force on 1 January 2026, updating the regulatory framework for HRFNAO imports. These regulations implement changes to Annex II of Regulation 2019/1793, expanding the list of high-risk foods and modifying special conditions.
Key changes introduced in 2025:
- Additional product categories added to the high-risk list based on 2024 surveillance data
- Revised sampling frequencies for certain commodity-country combinations
- Updated laboratory testing requirements for mycotoxin analysis
- Enhanced documentary check requirements for triangular trade shipments
- New special conditions for products from specific third countries
The 2025 regulations respond to emerging contamination patterns identified through the Rapid Alert System for Food and Feed (RASFF). Products added to the high-risk list typically show repeated non-compliance across multiple member states, prompting EU-wide (and consequently UK) controls.
Triangular trade provisions received particular attention. Under the updated rules, if HRFNAO is exported from its country of origin to a third country without processing, then shipped to GB, the original high-risk restrictions still apply. This prevents circumvention of controls by routing goods through intermediate countries.
For example, groundnuts from a high-risk country shipped to Turkey for repackaging (without processing) then exported to GB remain subject to the original high-risk controls. The FSA considers the country of origin, not the country of export, when determining applicable restrictions.
Importers should review the updated Annex II list to confirm whether their products face new or modified requirements. The FSA publishes guidance summarising regulatory changes — consult this before shipping consignments affected by the 2025 regulations.
Practical Compliance Checklist for UK Food Importers
Importing food into the UK requires systematic compliance planning. Use this checklist to ensure your imports meet FSA requirements.
Before ordering:
- Confirm your product is not on the HRFNAO high-risk list, or if it is, identify applicable special conditions
- Verify your supplier can provide valid laboratory test certificates from accredited laboratories
- Check that your chosen BCP accepts your product category
- Confirm laboratory testing capacity at the destination BCP — some ports have longer turnaround times than others
Before shipping:
- Request pre-shipment laboratory analysis for products subject to mycotoxin or contaminant limits
- Ensure certificates specify the exact batch being shipped — generic certificates are invalid
- Confirm packaging and labelling comply with UK food information regulations
- Prepare IPAFFS pre-notification with all required documentation
On arrival:
- Monitor IPAFFS dashboard for inspection notifications
- Coordinate with BCP for physical inspection scheduling if required
- Arrange onward transportation to customs warehouse if laboratory analysis is needed
- Maintain communication with your customs broker throughout the clearance process
After clearance:
- Retain all documentation for at least two years (longer for organic products)
- Record any non-compliance issues and corrective actions taken
- Review supplier performance — repeated testing failures may indicate systemic problems
- Subscribe to FSA alerts for updates affecting your product categories
For high-volume importers, consider establishing relationships with multiple BCPs to provide flexibility if one port experiences delays. Diversifying entry points reduces supply chain disruption risk during peak periods or when specific BCPs face capacity constraints. Importers working with Asian suppliers should also consult guidance on importing from China to the UK for country-specific considerations.
Frequently Asked Questions
How do I know if my product is classified as HRFNAO? Check the FSA’s high-risk food list published under Regulation 2019/1793 Annex II. The list specifies product categories, CN codes, and countries of origin subject to enhanced controls. If your product appears on this list, it is HRFNAO and must follow the full pre-notification and BCP process.
What happens if my consignment fails testing at the BCP? Failed consignments cannot enter the UK market. You must either re-export the goods to a non-UK destination or arrange destruction under customs supervision. Costs for destruction or re-export are borne by the importer. Repeated failures may result in increased inspection frequencies for future shipments.
Can I import HRFNAO through Northern Ireland? Northern Ireland follows EU regulations under the Windsor Framework. HRFNAO entering Northern Ireland must comply with EU import controls at designated EU Border Control Posts. Goods moving from Northern Ireland to GB may face additional controls depending on the product category.
How long does laboratory testing take at BCPs? Turnaround times vary by port and test complexity. Mycotoxin analysis typically takes 3-5 working days. Microbiological testing for pathogens can take 5-7 days. Plan your supply chain with this lead time in mind — goods cannot be released until results confirm compliance.
Do I need separate IPAFFS notifications for multiple containers in one shipment? Yes. Each consignment requires its own IPAFFS notification. A consignment is defined by a single customs declaration reference. If your shipment spans multiple containers under one customs entry, one notification suffices. Multiple customs entries require multiple notifications.