The CHED-PP and prior notification: how a Kenyan consignment is announced to an EU border control post, and what happens if it fails

The document, and who fills it in

For every consignment of plants and plant products that must enter the Union through a border control post, the operator responsible for the consignment completes the relevant part of the Common Health Entry Document — the CHED — with the information needed to identify the consignment and its destination immediately and completely. Cut flowers are in that category: they are plants, plant products and other objects on the lists made under the plant health regulation, which is point (c) of the list of goods subject to official controls at border control posts. The CHED is used by the operator to give prior notification of arrival, and by the border control post to record the outcome of its controls and any decision, including a rejection, and to communicate it through the Union's information system. The format for plants is the CHED-PP, drawn up to the template in the IMSOC regulation's annex; an electronic CHED and a paper one are the same document in law.

Where it is filed: TRACES, or a national system that feeds it

The operator gives prior notification by completing and submitting the relevant part of the CHED into the Union's information management system for official controls — the IMSOC, whose component for this purpose is TRACES — for transmission to the border control post before the consignment physically arrives in the Union. The implementing regulation allows an electronic CHED to be made either in TRACES, signed by the operator and the certifying officer and sealed by TRACES, or in a member state's national system, provided it carries the same signatures and is transmitted to TRACES by the time the decision is taken. That is why the Netherlands' importers file in CLIENT-import while Germany's and France's file in TRACES-NT: one national system, two direct uses of the Union's, and one legal document. The Dutch execution → Germany → France →

When: at least one working day, or four hours where logistics allow no more

Prior notification must reach the border control post of first arrival at least one working day before the expected arrival of the consignment. Where logistical constraints prevent compliance with that limit, the competent authorities of the border control post may apply a period of at least four hours. Both are set by Implementing Regulation (EU) 2019/1013, applying from 14 December 2019. Which of the two a given post applies is that post's decision, not the importer's — the four-hour period is a derogation the authority may grant, and a Kenyan consignment on an overnight flight depends on it. Great Britain, by comparison, writes its own minimum of at least four working hours for air freight into its guidance, with no one-working-day default. IPAFFS, the British notification →

What the post then does: three checks, one officer, one decision

On arrival the border control post performs documentary, identity and physical checks. For plants, plant products and other objects the physical check is performed by an official plant health officer, and the decision on the consignment — whether it complies, and where relevant under which customs procedure — is taken by an official plant health officer as well. The frequency of the identity and physical checks is the Union's table by genus and origin: Kenyan roses at 25%, carnations at 5%, gypsophila at 3%, unlisted genera at 100%. The table, origin by origin →

The CHED is finalised only when all required controls have been performed, the results of any physical check are available, and the decision has been recorded on it. Until then the customs authorities may not place the consignment under a customs procedure: the regulation makes presentation of a finalised CHED a condition of customs handling, including entry into a customs warehouse or free zone. The document that announced the consignment is the document that releases it.

If it fails: detention, refusal, and three orders

A consignment that does not comply is placed under official detention and refused entry. The competent authority then orders the operator, without delay, to do one of three things: destroy the consignment; re-dispatch it outside the Union; or subject it to special treatment or another measure that brings it into compliance, and where appropriate re-allocate it to a purpose other than the one intended. For plants, plant products and other objects the order may be applied to the consignment or to lots of it — a failure need not condemn the whole shipment. The authority hears the operator before ordering, unless immediate action is needed against a risk to plant health. The Netherlands' refusal on an incorrect additional declaration is this rule applied at the documentary stage. What actually stops Kenyan consignments, on the border that publishes it →

Moving the checks inland: control points

Identity and physical checks on plants may be performed at a control point instead of the border control post, under a delegated regulation of 2019 that supplements the official controls regulation. Either the operator asks and the border control post authorises the transfer, or the post decides and the operator does not object. Either way the control point must be designated for that category of goods. If the post does not authorise the transfer, or the operator objects to it, the checks stay at the post.

The documentary check still happens first, and it must be satisfactory before the consignment moves. The conditions for the transfer are cumulative:

• The control point is named in the CHED, by the operator in the prior notification or by the border control post.
• The border control post records its authorisation to transfer in the CHED.
• Before the consignment leaves the post, the operator notifies the control point of the expected arrival time and the means of transport, by submitting a separate CHED linked to the first.
• The consignment travels under customs supervision without being unloaded, with a copy of the CHED and an authenticated copy of the phytosanitary certificate. The copy is not needed where the certificate is already in the Union's system and the post has checked it against the original.
• For plants, the packaging or the vehicle is closed or sealed so that the consignment cannot infest anything else on the way.
• The CHED reference goes into the customs declaration for the transfer.

At the control point the process closes. The control point confirms arrival in the system and finalises the separate CHED with the result of the checks and the decision. The operator may not present the consignment at a different control point unless the post authorises it. If the post hears nothing within 15 days of authorising a transfer, it must find out whether the consignment arrived and, if it did not, alert customs. The documentary check itself may also be done at a distance from the post, by authorities in the same member state. A derogation for member states running their own national system lapsed on 13 December 2023.

The Netherlands is where this matters most for Kenyan flowers. The Dutch authority's register lists hundreds of control points for plants, most of them in the flower and horticulture districts rather than at the airport. The Dutch list, and how a location is recognised → Great Britain has its own control points and its own route to designating premises. Great Britain →

What it costs, and what this page does not reproduce

Fees for these controls are mandatory — the competent authorities collect them either at their calculated cost or at the amounts in the regulation's annex. The Annex IV minimums, and the Dutch per-minute execution → This page does not reproduce the CHED-PP template's fields, which sit in the annex of the IMSOC regulation and are filled in the system.

What to ask

• Who is the operator responsible for the consignment, and in which system do they file? TRACES-NT, or the national system of the member state of entry.
• Does the border control post apply the one-working-day period or the four-hour derogation? A question for that post, before the first flight.
• Which lots would be affected if part of a mixed consignment failed? The order can attach to lots, and the box list decides which.
• Would a control point near your premises save time? Only if the border control post authorises the transfer, and the documentary check at the post comes first either way.