Health certificate and free sale. 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 have timescales that don't depend on how urgently you need them.

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

The template, to download

Your ASL publishes the official application form, and it must be filled in on theirs: a sheet of ours sent instead of theirs isn't accepted. This one is for before, to collect in one go the data and attachments that form will ask for, because an incomplete application isn't rejected: it comes back, and meanwhile the days of notice are used up. The sheet is in Italian, like the forms it prepares for.

The files are free. There is no form in front of them, we don't ask for an address and we receive no notification when someone downloads them. The three things to find on your ASL's website are in step zero of the sheet, and that is where it pays to start.

Two different documents, two different bodies

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

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

The Italian Ministry of Health writes it with no room for interpretation: certifications «can only be signed by the official veterinarian or the SIAN officer (Food Hygiene and Nutrition Service) of the local health authority competent for the area», which proceeds in compliance with Ministry of Health Decree No 303 of 19 June 2000. Consequently, again according to the Ministry, «companies wishing to activate export procedures should turn primarily to the local health authorities competent for the area».

The templates aren't just one. They are published on the Ministry's portal and divided by product type and destination country: those born of a bilateral agreement between Italy and a third country can be consulted directly, those agreed at European level are in the TRACES system.

The case that causes most delays is the third, and it is also the most frequent for new markets: when no agreed template exists for that combination of product and country. The Ministry then indicates a precise route: the company obtains from its commercial contacts the information on the health requirements of the third country's authorities, and submits it to the ASL for verification, which issues the certification using a generic template «whose part II can be modified as the case requires».

That modification isn't a field to fill in. It is a text to agree, and every round between buyer, company and ASL is time that adds up.

The free sale certificate: what it really attests

The Turin Chamber of Commerce defines it like this: it is a document «required by some non-EU countries» that «attests that the goods exported by an Italian firm 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 reserved for export.

From this follow two practical consequences that surprise those asking for it the first time.

• You have to show you already sell. The Chamber asks for copies of sales invoices in Italy or the European Union from the last three months for the products to be certified, as well as the list of EU customers. A product created specifically for that foreign market, and never sold here, puts the company in an awkward position.
• It doesn't replace health certifications. The same source specifies that the certificate «is not a substitute for the certifications issued by the Ministry of Health» for categories under medical-health or phytosanitary jurisdiction: for those, the Chamber merely endorses the company's declaration. Which of the two paths concerns 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 side the timescales are published. The Lecce Chamber of Commerce states issue of the free sale certificate «within three working days of the date of submission», with €3 in secretarial fees, and of the certificate of origin «within two working days», at €10 with copy. These are that Chamber's fees and timescales: yours may have different numbers, and it pays to read them on its website instead of taking them for granted.

On the health side there is no single national time, because the procedure goes through the competent ASL and requires goods inspectable at a plant within that health authority's area. There is, however, a constraint that always applies, and it is the hardest of all. Azienda ULSS 2 Marca Trevigiana writes it in its own procedure: «No certificate according to the Ministerial standard can be issued if the departure date of the goods is earlier than the certification date».

How much notice is needed, where the application goes, what to attach and what it costs to ask late (the decree provides a 30 per cent surcharge under twenty-four hours) are in how to request the health certificate.

Read in passing it looks like a bureaucratic formality. Read properly, it is why this page exists: the certificate can't be recovered afterwards. If the goods have left, that document for that consignment will never arrive, and the remaining options are all expensive.

On cost, the same ULSS states the criterion instead of a fixed figure: the service requires «payment of the fee on an hourly basis calculated under Articles 9 and 10 of Legislative Decree 32/2021», invoiced monthly. Here too, your ASL may apply different amounts.

The question to ask on day one

Everything above comes down to a single operating rule: the list of documents required by the destination country is requested at the start of the negotiation, when there is still no shipping date to meet. It is one of the questions worth putting in the first reply to a buyer, together 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 matters more than the first four questions. It tells the buyer, without dramatising, that a last-minute request shifts the shipment, and in practice it considerably reduces the chance of that request arriving late. The same logic of acting early applies to samples, which may require the same documents even though they are free.

When the list stops living in someone's head

With one country and two products the list of documents can be remembered. With five countries, four products and certifications that expire, the problem stops being knowing it and becomes remembering it at the right moment, that is, weeks before loading, while doing something else.

The thing that can be fixed straight away, without buying anything: a table with one row per combination of product and country, and four columns (documents required, body that issues them, stated issuing time, last useful date to request them). It is filled in once and updated when something changes.

When those rows become dozens, the table should be put where someone watches it on your behalf: an alert that arrives when it is time to request a document, not when it is time to have it. With the constraint written in Ethics: the system prepares and flags, but no request goes out to an authority or a buyer without a person having read and approved it.

Questions and answers