Could Leaked Requirements for Movement of Goods to Northern Ireland Provide Basis for Special Arrangements for ACP Triangular Supply Chains

However, this would come up against the problem of the compatibility of EU and UK-only electronic trade documentation systems and the issue of continued UK recognition of EU trade documentation (including phytosanitary import controls) on ACP goods imported to the UK via the EU27.

It would in addition require a clear and early political commitment from the UK and EU authorities to such special arrangements for goods entering the UK market along triangular supply chains. This is necessary so infrastructure and logistical arrangements can be set in place to allow ACP/LDC goods which have been subjected to phytosanitary inspections upon entry to the territory of the EU and which enjoy duty-free/quota-free access to both the EU27 and UK  can be subject to only ‘light touch’ border controls.

This would help minimise any delays in the delivery of ACP goods to final UK customers arising from new border clearance requirements (including phytosanitary import controls). This is particularly important for short shelf life products such as cut flowers, where a 1-day delay in the delivery of goods to the final customers can strip away 30% of the exporters’ profits.

The view at the civil service level in the UK appears to be that an initiative aimed at establishing special channels for border clearance for goods from developing countries which avoided disruption of the functioning of triangular supply chains would meet with general approval at the level of both officials and Ministers. However, given the Covid-19 crisis and the fraught nature of UK/EU negotiations no one in the UK government has the band width at the present time to take up and address these issues.

However, while the launching of such an initiative to address the practical concerns of developing country exporters (mainly but not exclusively in sub-Saharan Africa) is not seen as politically contentious, it would appear to be necessary to delink such an initiative from the fraught bilateral process of EU/UK negotiations.

Against this background there would appear to be a need for the most directly affected ACP governments (with the support of the most seriously affected  private sector bodies) to launch a political initiative for the establishment of special arrangements for the handling of imports to the UK which enter via initial ports of landing in the EU, which addresses both the UK and EU dimensions of this triangular supply chain issue.

In terms of the most affected government and private sector businesses this would appear to require a political initiative from Kenyan and other East African governments with the support of those floriculture and horticulture exporters who make the most extensive use of triangular supply chains in serving the UK market.

These exports have already been seriously affected by the impact of the Covid-19 pandemic on passenger-based air freight services (see epamonitoring.net articles ‘What Future Air Passenger Flight Based Cargo Services?’, 16 June 2020 and ‘Covid-19 Related Cancellation of Commercial Flights Beginning to Bite for ACP Horticulture Exports’, 7 April 2020),  with the impact of a poorly managed UK departure  from the EU customs union being likely to considerably delay the recovery of these vitally important export sectors.

While East African floriculture and horticultural exporters are the most obvious triangular supply chains which will be affected, other ACP exporters could also be affected. These range from West African, Southern African and even Caribbean horticulture exporters, as well as exporters of products as diverse as Caribbean rum and Pacific canned tuna and even ACP exporters of chilled and frozen fish. In all of these areas some onward trade via the EU27 to the UK market currently takes place. All of these existing triangular supply chains could potentially face serious unintended disruptions, if special arrangements, designed to promote the continued smooth functioning of these triangular supply chains are not set in place in a timely fashion, before the UK leaves the EU customs union and single market on 1^st January 2021.

Smaller countries with limited freight options in serving European markets are likely to be most seriously affected by any disruption of triangular supply chains. This would then involve returning to patterns of freight arrangements in serving the UK market which existed prior to the creation of the EU single internal market. Unfortunately, for many of the most seriously affected supply chains, the development of a substantial export trade only occurred after the creation of the EU single internal market.

While larger exporters are likely to have more commercial scope for restructuring their freight arrangements in serving the UK market, thereby side-stepping the potential disruptions of triangular supply chains, this will require time and careful planning, suggesting that at a minimum special arrangements are likely to be required for an extended transitional period (e.g. up to 2 years after the UK’s  formal departure from the EU customs union and single market).

In the absence of such special arrangement the profoundly damaging economic impact of Covid-19 related disruptions to passenger flight-based air freight services, on which many ACP horticulture and floriculture exporters depend, is likely to be severely exacerbated.