Health certificate and free sale certificate. The buyer asks for them out of the blue; the timescales don't get shorter.

An email arrives: “for customs clearance we need the health certificate and the free sale certificate”. The goods are ready, the lorry is booked, and the two documents take as long as they take, however urgently you need them.

This piece is part of the guide to export operations for small food producers and looks more closely at one of the documents that go with a shipment beyond the customs basics: the certificates the destination country requires to let the goods in.

The template, to download

The official request form is published by your ASL, and has to be filled in on their form: a sheet of ours sent instead of theirs won't be accepted. This one is for beforehand, to gather in one go the details and attachments that form will ask for, because an incomplete request isn't rejected: it comes back, and meanwhile the days of notice run out.

The files are free. There's no form in the way, we don't ask for an email address, and we don't get notified when anyone downloads them. The three things to find on your ASL's website are in step zero of the sheet, and that's the place to start.

Two different documents, two different bodies

The confusion between the two comes from translation. The buyer writes health certificate and free sale certificate on the same line, and they look like two versions of the same thing. In Italy they follow two separate routes, with two bodies, two procedures and two timescales.

The health certificate: who signs it, and where the template comes from

Italy's Ministry of Health leaves no room for interpretation: certificates can be signed only by the official veterinarian or the SIAN officer (Food Hygiene and Nutrition Service) of the local health authority for the area, who follows Ministry of Health Decree no. 303 of 19 June 2000. It follows, again according to the Ministry, that businesses wanting to start export procedures should go first of all to the local health authority for their area.

There isn't just one template. They're published on the Ministry's portal and organised by product type and destination country: those resulting from a bilateral agreement between Italy and a non-EU country can be consulted directly, while those agreed at European level are in the TRACES system.

The case that causes most delays is the third, and it's also the most common for new markets: when no agreed template exists for that combination of product and country. The Ministry then sets out a specific route: the business obtains from its trading partners the information on the health requirements set by the non-EU country's authorities, and submits it to the ASL for checking, which issues the certificate using a generic template whose part II can be amended as the case requires.

That amendment isn't a field to fill in. It's a text to agree, and every round between buyer, business and ASL adds time.

The free sale certificate: what it actually certifies

The Turin Chamber of Commerce defines it as a document required by some non-EU countries that certifies that goods exported by an Italian company circulate freely in the countries of the European Union. The buyer needs it to convince their own authority that the product isn't experimental or made only for export.

Two practical consequences follow, and they surprise people asking for it for the first time.

• You have to prove you're already selling. The Chamber asks for copies of sales invoices in Italy or the EU from the last three months for the products to be certified, as well as a list of EU customers. A product created specifically for that foreign market, and never sold here, puts the business in an awkward position.
• It doesn't replace health certificates. The same source states that the certificate does not replace the certificates issued by the Ministry of Health for categories under medical, health or plant health jurisdiction: for those, the Chamber simply endorses the business's own declaration. Which of the two routes applies to your product should be confirmed with your Chamber of Commerce before promising the buyer a date.

The timescales, and the date that can't be moved

On the Chamber of Commerce side, the timescales are published. The Lecce Chamber of Commerce states that the free sale certificate is issued within three working days of submission, with €3 in administrative fees, and the certificate of origin within two working days, at €10 with a copy. Those are that Chamber's fees and timescales: yours may have different figures, and it's worth reading them on its website rather than taking them for granted.

On the health side there's no single national timescale, because the procedure goes through the relevant ASL and requires the goods to be available for inspection at a site within that health authority's area. There is, however, one constraint that always applies, and it's the toughest of all. Azienda ULSS 2 Marca Trevigiana sets it out in its own procedure: no certificate to the Ministry standard can be issued if the goods' departure date is earlier than the certification date.

How much notice you need, who to send the request to, what to attach and what it costs to ask late (the decree provides for a 30 per cent surcharge under twenty-four hours) are covered in how to request the health certificate.

Read quickly, it looks like a bureaucratic formality. Read properly, it's the reason this page exists: the certificate can't be obtained afterwards. If the goods have left, that document won't arrive for that consignment, and the options left are all expensive.

On cost, the same ULSS states the method rather than a fixed figure: the service involves payment of an hourly rate calculated under Articles 9 and 10 of Legislative Decree 32/2021, invoiced monthly. Here too, your ASL may charge different amounts.

The question to ask on day one

Everything above comes down to a single working rule: ask for the list of documents the destination country requires at the start of negotiations, when there's no shipping date to meet yet. It's one of the questions worth putting in your first reply to a buyer, along with the country and the final destination.

Subject: [product] - import documents required on your side

Dear [name],

Before we quote and plan production, could you confirm
which documents your customs authority requires for this
product in [country]?

In particular:
1. Do you need a health certificate issued by the Italian
   health authority? If yes, please send the exact model or
   wording your authority accepts.
2. Do you need a free sale certificate?
3. Any product certification (origin, organic, halal,
   kosher, laboratory analysis) required at import?
4. Who is the importer of record, and which entity places
   the product on the market in [country]?

Some of these documents have fixed issuing times on our
side and cannot be obtained retroactively, so we prefer to
start early.

Kind regards,
[name] - [company]

The last sentence does more work than the four questions before it. It tells the buyer, without making a drama of it, that a last-minute request moves the shipment, and in practice it makes it much less likely that the request will come late. The same logic of acting early applies to samples, which can need the same documents even though they're free.

When the list stops living in someone's head

With one country and two products, you can remember the list of documents. With five countries, four products and certificates that expire, the problem stops being knowing it and becomes remembering it at the right moment, weeks before loading, while you're busy with something else.

The thing you can sort out straight away, without buying anything: a table with one row per combination of product and country, and four columns (documents required, issuing body, stated issuing time, last date to request them). You fill it in once and update it when something changes.

When those rows run into dozens, the table needs to go somewhere that someone watches it for you: an alert that arrives when it's time to request a document, not when it's time to have it. With the rule set out in Ethics: the system prepares and flags, but no request goes to an authority or a buyer until a person has read and approved it.

Questions and answers