Clarification of first consignee requirements for Certificates of Inspection

A number of Port Health Authorities have raised issues with incorrect information on certificates of inspection, (COI), in relation to first consignees.

In these cases, the importer has been listed as first consignee, but the consignment is not being delivered to the importer but to another licensed operator and so the importer is being wrongly declared as the first consignee.

The organic regulation defines the first consignee as the natural or legal person to whom the imported consignment is delivered and who will receive it for further preparation and/or marketing.

The organic regulation also requires the first consignee to be licensed for handling organic product.

The operator where the consignment is delivered for further preparation or marketing must be identified on the COI as the first consignee and not the importer (unless the importer is also the first consignee). This includes if the consignment is split after leaving the port of entry. For example, if a consignment leaves port and goes to a distribution hub or warehouse, where the consignment is split and distributed to customers, in which case that distribution hub/warehouse is acting as the first consignee, (and must be licensed as a first consignee for handling organic product). This is necessary because the regulation requires the first consignee to check and record that the consignment:

a) arrives in appropriate packaging or containers which prevent substitution

b) identify the exporter

c) are marked to identify the lot

d) that the COI covers the product in the consignment

e) signs the COI to confirm this.

Note: it is possible for a consignment to be split before it leaves the port of entry under a under a suspensive customs procedure – refer to standard 6.8.9 of Soil Association standards for further details.

First consignees covered under the importers license as a subcontractor, (i.e. operator is acting as a subcontractor for the importer and is inspected as part of the importer organic license and not holding their own certification), will be listed on the importers trading schedule as an additional site and listed on the COI as the first consignee.

Action for importers

Please ensure that the correct company is listed as the first consignee on the COI. If the imported consignment is not delivered to you for further preparation or marketing, you should not list your address as first consignee. If you would like any further information please contact the certification team at food.drink@soilassociation.org