Transport, documents and records
Contents
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Background
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Has much changed?
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Have the identification requirements changed?
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What are the conditions for transport?
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Are there changes to commercial documents?
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What about intra-community trade?
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When are health certificates required?
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What about electronic documents?
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When is temperature control required?
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What records do I have to keep?
Background
The relevant EU legislation is:
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
Regulation 1069/2009 hereafter referred to as the “Control Regulation”.
Implementing Regulation 142/2011 hereafter referred to as the “Implementing
Regulation”.
The EU Control Regulation, EU Implementing Regulation and domestic enforcement
regulations replaced the previous legislation on the 4 March 2011. This guidance note explains
the requirements concerning the transportation, documentary and record keeping requirements
for animal by-products and point out where these have changed.
Has much changed?
In relation to identification, collection, transport, documentation and record keeping, the
requirements are broadly as before. There is clarification that these requirements do not apply
when the legal controls on compound feed apply or where milk and milk products are from a
plant approved under Regulation (EC) No. 853/2004 – including “returns”.
Registration of transporters of ABP is now required.
Have the identification requirements changed?
Article 4 of the EU Control Regulation is much clearer than the previous legislation in stating
that all animal by-product operations have a defined “starting point” and that all operators from
the starting point, through all subsequent stages, must comply with their legal obligations in
relation to animal by-products.
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For example, in an abattoir, lungs may have been produced and inspected so as to be fit for
human consumption. However, if the decision is taken that they will be used for petfood, rather
than human consumption, that is the starting point. They must thereafter be identified and
handled as category 3 by-products. Similarly, the removal of specified risk material (SRM) from
a carcase is the starting point for the category 1 operation and the moment when a carcase is
condemned would be the starting point for the category 2 operation (of course, the operator
may chose to dispose of category 2 by-product as category 1 either at that stage or later).
Consequently, the abattoir operator is responsible for correctly identifying, handling and storing
the 3 streams of by-product (or fewer if a stream is downgraded to a higher risk category) such
that there is no risk to meat for human consumption or of cross contamination from a higher risk
category of by-product to a lower risk category. The operator should ensure these streams are
correctly presented for collection after which the collector becomes responsible for carrying out
his stage correctly and so on.
Different categories of animal by-products will normally be transported in separate vehicles.
However, mixed loads can be permissible in certain circumstance, provided that identification is
maintained and there is no risk of cross contamination. For example, a vehicle could collect
category 1, 2 and 3 by-products from small abattoirs in screw top, labeled barrels, with the
barrels of different categories stored separately on the vehicle – front, middle, back.
Colour coding is still only required for intra-community trade. The vehicle/container or a label
attached to it must be colour coded as black for category 1, yellow for category 2 and green for
category 3.
The labeling requirements are as before. During transport and storage, the vehicle, container or
packaging must have a label attached stating the category and the appropriate wording
category 1 material. For disposal only
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category 2 material. Not for animal consumption
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category 3 material. Not for human consumption.
In some cases additional wording may be required. For example with feed for a pack of hounds
registered as a final user:
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category 2 material. For feeding to pack of hounds.
This is the same as was required under the previous legislation. A full list of labeling
requirements can be found at Annex VIII, chapter II of the EU Regulation (EU) No. 142/2011.
What are the conditions for transport?
The main change is for transporters to be registered:
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if you are transporting animal by-products solely in connection with an approved or
registered premises, you do not require a separate transporter registration
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if you are a livestock keeper transporting carcases of your own animals, you do not need
to register
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you must register if transporting animal by-products for any other reason.
In order to register you must first complete an application form, This form is available online or
can be obtained by contacting Veterinary Service on 028 9052 5275,
applications.aiabp@dardni.gov.uk or:
Department of Agriculture & Rural Development
Room 922
Dundonald House,
Upper Newtownards Road,
Belfast
BT4 3SB
More details on how to register are explained in our registration of ABP operators,
establishments or plants guidance note available here. .
Animal by-products and derived products (previously known as processed products) must be
transported in vehicles or containers which are:
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covered, leak proof and maintained in a clean condition. These should be 1) cleaned,
washed and/or disinfected after each use to the extent required to prevent cross
contamination and 2) cleaned and dried before re-use
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alternatively, if appropriate, sealed new packaging may be used. After use the packaging
material must be disposed of in accordance with relevant waste management legislation
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the vehicles/containers must be dedicated to the carriage of a particular product, in a way
which avoids cross contamination. This is most likely to apply in the case of processed
products.
Transporters of processed animal protein must use dedicated vehicles and require a separate
registration under the TSE Regulations. You can register by contacting DARD Veterinary
Service using the details above.
The general requirement for vehicles to be covered, clean and leak proof cannot be
emphasised too strongly. The public will be appalled to see a bit of a dead animal poking out of
a container.
Leaking can never be tolerated. Leaks from vehicles carrying livestock carcases constitute a
serious risk to animal health and public health. The public will rightly complain and enforcement
authorities will take action.
Take care to check that your vehicles/containers are leak proof. For bulker type trailers, you
should inspect the seals round the tailgate, close the tailgate, put some water in the trailer then
tip it to check that no water leaks out. If you are collecting carcases from farms, check that the
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internal fabric of the vehicle is sound, with no cracks or gaps. Normally, a lip at the back of the
vehicle and a sump are required to prevent leaks. In addition to visual checks, you should throw
several buckets of water into the vehicle and check that none leaks out.
Are there changes to commercial documents?
The commercial document for movement within the same member State of the EU now requires
the signature of the responsible person. If the document is produced by the consignor, it should
be signed by the consignor. If the document is produced by the transporter, it should be signed
by the transporter. The requirement remains that each movement of animal by-products and
derived products must be accompanied by the top copy of the commercial document which has
to be left at the destination premises. The premises of origin and the transporter each retain a
copy.
An example for disposal of poultry carcases from a farm should look something like this:
Commercial document for movement of poultry carcases from farm for disposal
Name and address of origin:
Name and address of transporter
Name and address of destination
Approval/Registration number
Quantity and description
Date of transport
Category 2 By-Products. Not for animal consumption
Signature of responsible person___________________________
Print name __________________________
The following points should also be noted:
1.
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Quantity is usually closely related to the description and can be a weight, e.g. 20250kg of
category 1 meat and bone meal, produced by method 4 processing.
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2.
If the weight is approximate or estimated, you must say so.
If it is a number of containers, you must include the approximate weight of a full
container, if there are no weighing facilities. e.g. 10 dolav bins of fish processing
waste, estimated average weight 400kg
Or it can be a number, e.g. 85 tripes
Or it can be a volume, e.g. estimated 20000 litres of bovine blood
Description must be as full as possible.
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For livestock carcases removed from farms/smallholdings, the ear numbers must be
included.
Species must be stated.
For derived products for feed use and by-products which could be so used after
processing, the sub-category of category 3 must also be included. These are
described at Article 10 of the EU Regulation (EU) No. 1069/2009.
3.
Approval or registration number - In other cases, it would be necessary to also include an
approval or registration number for the premises of origin.
4.
Always bear in mind that the document must provide traceability. A statement like “4 bins
of butchery waste” is meaningless without knowing the average weight of a bin.
5.
Retention – All copies of commercial documents must be retained for 2 years.
6.
Exemptions – commercial documents are not required for:
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Derived products from category 3 material, organic fertilisers or soil improvers
supplied by retailers to final users (other than business operators) within the same
Member State. For example, sale of bone meal from a garden centre to a customer
for use in a private garden does not need a commercial document
Milk, etc and compound feed, as mentioned at the start of this guidance section.
What about intra-community trade?
The model commercial document for intra-community trade has been amended by Regulation
(EU) No 1097/2012
If you are sending category 1 or 2 animal by-products or derived products to another Member
State, it is still a requirement that the competent authority in the receiving country has agreed to
the trade. Further advice can be obtained from Veterinary Service Trade Section. When such
consignments are sent, and also when processed animal protein is sent to another Member
State of the EU, the competent authority in the member state of destination must be notified via
the traces system. This is an electronic system of communication between competent
authorities. In addition to the three copies normally required, a fourth copy of the commercial
document must be completed. The fourth copy must be signed by the receiver and sent back to
the premises of origin.
When are health certificates required?
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Health certificates are required for certain imports into the EU. If you wish to import animal byproducts or derived products from outside the EU, you should contact Veterinary Service Trade
Section 028 905 20989 or tradeadminpost@dardni.gov.uk.
First, you must establish whether the proposed import is allowed. Secondly, you need to find out
the requirements. If the import is allowed, the goods have to enter the EU through a Border
Inspection Post (BIP), where the necessary checks are made. If the checks are satisfactory, the
goods are released and a Common Veterinary Entry Document (CVED) is issued. Depending
on the product, the release may be for general movement within the EU or channeled, i.e.
moved directly to an approved premises.
Health certificates are generally only required for trade within the EU following outbreaks of
notifiable disease, such as Foot and Mouth Disease. During such outbreaks, up to date
information will be available on the DARD website.
If you wish to export outside the EU, you should contact Veterinary Service Trade Section
mentioned in the section above. The EU Control Regulation prohibits some exports. Otherwise,
it will depend on the rules in the particular country as to whether the movement is allowed at all,
or if so, what certification and other requirements will apply.
What about electronic documents?
The EU Implementing Regulation states that the competent authority may allow the use of
electronic documents within its own territory. There are a number of potential problems with
electronic documents. We are considering how an electronic system can be made as effective
as a paper based system, and further guidance may be issued in due course.
When is temperature control required?
The transport of animal by-products and derived products destined for the production of feed
material or pet food must take place at an appropriate temperature.
Animal by-products from meat and meat products no longer intended for human consumption
(i.e. former foodstuffs) destined for the production of pet food must be transported at a
maximum of 7°C.
Unprocessed category 3 material destined for the production of feed material or pet food must
be transported chilled, frozen or ensiled unless processed within 24 hours after collection or
after the end of storage in chilled or frozen form, if storage temperature maintained during
transport.
What records do I have to keep?
For despatch, transportation and receipt of animal by-products, the copy of the commercial
document can serve as your record. However, it is advisable to have additional records in book
form or on computer, as appropriate. For example, livestock keepers have to record deaths of
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livestock. It is very simple to add something like –“ sent to .................incineration plant
10.03.11” Depending on the nature of your business, you will probably need to record the
information in some other format anyway, e.g. for billing purposes.
Other types of record are required, largely as in the past. For example, incinerator operators
need to record the date, quantity and description of material incinerated, and the temperatures
in the secondary chamber of the incinerator. Additionally, there are different requirements for
identification, labeling, etc. in relation to certain specific by-products and derived products.
These requirements are dealt with in the guidance notes on specific topics.
More information on transport, identification, documentation and record keeping requirements
for specific situations is explained in the appropriate section of this guidance note.
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