EU Health Certificates 2025: What Food and Animal Importers Must Correct

Key data

Operators who import or export animals and products for human consumption to or through the EU have a specific documentary obligation: the certificate models accompanying their consignments must be those corrected by Commission Implementing Regulation (EU) 2025/636, in force since 30 April 2025. This corrigendum corrects errors detected in the official forms that amended Annexes III and V of Regulation (EU) 2020/2235.

This is not a substantive change to sanitary requirements, but a technical correction to the forms themselves. However, the operational impact is real: a certificate using the incorrect model may be sufficient grounds for an EU border control post to detain or return the consignment.

What does this regulation establish?

Commission Implementing Regulation (EU) 2025/636 amended Annexes III and V of Regulation (EU) 2020/2235, which contain the official model documents for the entry or transit of animals and goods for human consumption into the EU from third countries. The corrigendum published under reference CELEX:32025R0636R(05) corrects errors detected in those forms.

The documents affected by the correction are as follows:

• Animal health certificate: certifies the health status of animals or products of animal origin.
• Official certificate: issued by the competent authority of the exporting country.
• Combined animal health/official certificate: a document that integrates both functions.
• Private attestation: declaration by the private operator accompanying certain consignments.

These are the models that must be physically presented at EU border control posts for consignments to be admitted. The correction affects the forms themselves, not the underlying sanitary requirements.

Economic and operational impact

The economic risk of failing to act is direct: the detention or return of goods at EU border control posts. For perishable products such as meat, fish or fresh animal products, a border detention can result in the total loss of the consignment, in addition to the associated logistics and storage costs.

The operational impact is concentrated in three areas:

• Documentary update: foreign trade and logistics departments must replace the certificate templates currently in use with the corrected models published in the Official Journal of the EU (OJ L, 2025/636, 30.4.2025).
• Coordination with authorities in the exporting country: official and animal health certificates are issued by the competent authority of the country of origin. The operator must ensure that this authority is also using the updated models.
• Review of internal procedures: operators in the meat, fishery and animal products sectors must update their documentary procedures to reflect the new models.

Who is affected?

• Importers of animals and products of animal origin from third countries destined for the EU.
• Exporters from third countries sending goods to the EU or in transit through it to another third country.
• Operators in the meat sector managing consignments of meat or meat products in the import chain.
• Operators in the fishery sector importing fish, seafood or derived products from outside the EU.
• Operators of other animal products intended for human consumption (dairy, eggs, honey, etc.) from third countries.
• Customs agents and freight forwarders managing the documentation for these consignments on behalf of their clients.
• Compliance and foreign trade departments of companies with food of animal origin import operations.

Practical example

A Spanish company importing salmon from Norway regularly manages consignments entering through an EU border control post. For each consignment, the competent Norwegian authority issues an official certificate and an animal health certificate based on the models from Regulation (EU) 2020/2235.

If the models used by the Norwegian authority correspond to the forms prior to the corrigendum of Regulation 2025/636, the certificate presented at the border may not match the current model. The inspector at the border control post may consider the document non-compliant and detain or return the consignment.

To avoid this, the importer must: (1) verify that the competent authority of the exporting country is aware of the correction and is using the updated models; (2) review the certificates before the consignment leaves the country of origin; and (3) update their own internal documentary verification templates.

What should companies do now?

1. Download the corrected models from EUR-Lex (CELEX:32025R0636R(05)) or from the Official Journal of the EU (OJ L, 2025/636, 30.4.2025) and replace the previous templates in all documentary systems.
2. Notify suppliers and authorities in the exporting country that the models have been corrected and that certificates issued must correspond to the version in force since 30 April 2025.
3. Review ongoing or upcoming consignments to verify that the accompanying certificates use the corrected models before they reach the EU border control post.
4. Update internal procedures in foreign trade, logistics and compliance departments to include verification of the certificate model as a mandatory step before each import.
5. Inform customs agents and freight forwarders managing consignment documentation about the change, so that they also apply the verification in their processes.

Official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, please consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32025R0636R(05)