Summary
UK trade related veterinary inspection and certification services are facing serious problems of recruitment and retention as demand sours. There are calls for both a greater government role in the organisation and conduct of trade related veterinary inspection services and the establishment of para-professional veterinary support staff for the conduct of trade related inspection and certification activities. However, unless changes designed to address staffing constraints are introduced in close consultation with trade partners such changes could disrupt trade, creating a dual system of EU and non-EU accepted health certification. While there are also calls for new UK electronic EHC systems which are compatible with EU systems and for the UK to negotiate a veterinarian equivalency agreement with the EU, the current political atmosphere and evolving situation on the ground are not conducive to early progress in these areas. This could potentially give rise to UK export surges of livestock products to ACP countries and even EU export surges to ACP countries, if the UK enforces equivalent controls on imports from the EU, to avoid undermining the competitive position of UK livestock product producers.
The British Veterinary Association (BVA) has highlighted how the basis on which the UK left the EU single market did not adequately address SPS issues in EU/UK trade. This means export health certification (EHC), involving veterinary inspections and approval, is now needed for the transport of animal and animal products from Great Britain to the EU and Northern Ireland. The BVA highlights how if there are not ‘enough veterinary surgeons to meet the additional demands for export and import certification and controls’, this could come to constitute a ‘significant barrier to trade’ (1). This comes on top of other factors which are already undermining UK livestock exports to the EU (see companion epamonitoring.net article, ‘Post Brexit Problems in UK Meat Exports to the EU and Implications for UK Poultry Meat exports to ACP Countries’, 13 April 2021).
The BVA points out how since 1 January ‘there has been an increased demand for veterinary certification’, involving additional veterinary checks. While the BVA believes veterinary capacity has not yet become a constraint on trade, this is attributed largely to the depressed level of UK livestock product exports (half of normal levels) and travel restrictions which means pets are not being moved across EU/UK borders. Once travel restrictions are lifted, the increased demand and constraints on the availability of vets for trade related purposes could become a serious constraint on UK exports (1).
The BVA suggests it is difficult to calculate the number of additional official veterinarians (OVs) required to support a restoration of UK livestock product export volumes to pre-Brexit levels. The difficulty faced in making this calculation of the number of OVs required is attributable in part to the specialist training requirements for the conduct of border control functions for different livestock products and the logistics of ensuring OVs are in the right place at the right time. This is compounded by the generalised reluctance of vets with UK nationality to carry out trade-related and public health functions as opposed to engaging in private veterinary practice (1).
This needs to be seen against a more generalised background where ‘95% of the veterinary workforce in abattoirs graduated overseas – with the clear majority of these coming from the EU.’ The BVA notes ‘losing these veterinary surgeons from slaughterhouses would increase the risk of food fraud, provide the potential for animal welfare breaches, and remove a level of public health reassurance to consumers at home and overseas that could jeopardise trade’ (1).
Between 2015 and 2019 only 42% of vets qualifying in the UK were UK nationals, while 49% were EU nationals. However, the registration of EU nationals as vets in the UK declined 35% in 2020, in part linked to Covid-19 travel restrictions. This gave rise to a 7% decline in the total number of new vets registered, despite a 9% increase in UK nationals registering as vets.
This situation has been compounded by the ending of ‘automatic registration of EEA qualified vets by the Royal College of Veterinary Surgeons’, following the lapsing of arrangements for the ‘Mutual Recognition of Professional Qualifications (MRPQ).’ What is more, the UK’s new immigration system is not seen as conducive to filling the growing gap in vet registration in the UK, resulting from the ending of the free movement of labour previously applicable while the UK was a member of the EU. This needs to be seen in a context where the UK is ‘already struggling to recruit and retain vets’ (1).
While UK government initiatives have been launched to expand recruitment of veterinarians the BVA highlights how ‘it will take 5 years for these new routes to produce new vets’ to come on stream. In addition, it will require a ‘significant cultural change and incentivisation’ if the ‘the existing reliance on overseas-qualified veterinary surgeons’ for the provision of trade related veterinary services for livestock products is to be reduced (1).
In the short-term the option of deploying phytosanitary support staff (para-professional) under veterinarian supervision is being explored, with the UK government looking to introduce a Certification Support Officer (CSO) role, for which 400 staff have already been trained. However, as the BVA highlights how the creation of CSOs ‘does not remove the requirement for an OV to sign the EHC’ it will merely reduce the routine workload falling on OVs (1).
In light of these initiatives the House of Lords European Union Committee has highlighted how any changes to the range of tasks undertaken by paraprofessional in the animal health and animal product sector will need to be carried out in close consultation with major trade partners if trade disruptions are to be avoided (2).
The BVA has called on the UK government to work closely with the livestock industry and the veterinary profession to understand the practical experience of meeting the demands of exporting SPS goods’ and ‘to work together to identify potential solutions’, so these can be put forward in the Trade Specialised Committee on Sanitary and Phytosanitary Measures’, established under the UK/EU Trade and Cooperation Agreement (1). Promoting professional dialogues between EU and UK vets and lowering the political temperature and finger pointing (3) around these technical issues would appear to offer greatest hope of progress. There is a shared recognition amongst EU and UK vets that ‘‘imports of both animals and animal products may carry pathogens that can represent a threat to public health and the health of animal populations’, and agreement that ‘veterinary certification and controls form a vital part of the biosecurity framework’ of any country or regional trading bloc (1).
Overall, the BVA takes a rather pessimistic view of the current situation given the likely evolution of demand for the services of veterinarians in support of the UK livestock trade, maintaining there are ‘simply not enough vets to process the volume of checks and paperwork needed to maintain the export volumes’ at pre-Brexit levels. What is more, from a commercial perspective the current private sector-based system of export health certification is generating a situation where increased demand in the context of a limited supply of vets is driving up certification costs, with lower value export products (e.g., poultry parts) struggling to carry these increased costs (1).
This has seen the BMPA has call for the creation of a government run SPS inspection service modelled on similar arrangements in the Netherlands, Germany, and Denmark. Indeed, the closer any future UK system of animal health inspections and export certification, is to EU member states systems, the easier it will be to secure acceptance of any innovations the UK may introduce.
However, the creation of a government run trade related veterinarian inspection service would constitute a radical change from the current private sector-based system and would be likely to face vocal criticism from current private sector providers of veterinarian and meat inspection services. The Managing Director of one of the UK’s leading providers of Official Veterinarians and Meat Hygiene Inspectors has already ‘strongly criticised the UK Government’s decision to further delay checks on goods entering Great Britain from the European Union’ (4).
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The Commercial Impact of the Veterinary Constraint on UK Export Health Certification According to the UK Secretary of State for the Department of Environment, Food & Rural Affairs (Defra) George Eustice, the Brexit process has ‘resulted in a 5% to 15% increase’ in the costs of trading with the EU for UK small and medium sized enterprises. Secretary of State Eustice considers the cost of export health certificates (EHC) as the ‘principal source of cost increases.’ It reportedly takes from ‘30 minutes to two hours to complete’ the process, ‘with an hourly charge rate of around £40’ (5) However, according to the BMPA while ‘the cost of an EHC is estimated at around £155; in reality it is probably closer to £200 given the processes needed to provide the information a vet requires in order to sign it’. The BMPA sees this as very burdensome for small scale consignments, particularly when other additional costs are taken into account (pre-export notification requirements, customs declarations, additional haulage costs). This is seen as particularly problematical in light of the tight profit margins in the livestock sector, given these additional costs cannot be passed on to customers, who would simply turn to suppliers within the EU, who do not face these costs. |
It was highlighted how private veterinary service providers had already recruited staff and made investments geared to the introduction of new controls on goods entering the UK from the EU from 1 April and 1 July 2021. With these controls now being deferred for 6 months, the concerned companies will need to carry the costs of the newly recruited staff, for a period of six months when their services will not be required and hence will not be generating any revenues (4).
Diederick Opperman, Managing Director of Hall Mark Veterinary and Compliance Services, describe the reality now faced as a ‘truly appalling situation’, which undermines the confidence of private sector veterinarian service providers in government policy pronouncements. This is not generating a conducive environment for a major shift in the basis on which UK trade related veterinary services are provided (4).
The BMPA has called for:
- The establishment of an electronic export health certificate (EHC) system, based on existing technology, which is compatible with EU systems.
- the conclusion of a ‘close veterinary equivalency agreement with the EU’, preferably based on the Swiss model (5).
| Comment and Analysis The conclusion of a ‘close veterinary equivalency agreement with the EU’, is not likely in the short to medium term. This is in part a result of the more confrontational approach the UK has adopted in relations with the EU since 1 January 2021 (6), with this undermining the basis of trust on which the practical arrangement for the effective operation of the reciprocal duty-free/quota-free access agreed under the TCA will need to be made to work. However, it is also linked to the combined effects of the crisis in UK veterinarian recruitment and retention and the surge in demand for trade related veterinarian services, which are undermining the credibility of UK trade related phytosanitary control systems for livestock products.Given the five-years it will take for veterinary students participating in expanded training programmes to qualify and the difficulties faced in establishing a system of para-professional support staff which is acceptable to the EU, the current much lower levels of UK livestock product exports to the EU are likely to be a semi-permanent feature for years to come. Indeed, the pressures on UK trade related veterinarian services are likely to get substantially worse before they get better.This could leave UK livestock product traders seeking out new markets for frozen meat exports and dried milk. This could see surges in UK exports to ACP countries of products such as frozen poultry parts. If the UK moves ahead with plans for the expansion of tasks undertaken by para-professional to address the shortage of veterinarians engaged in trade related livestock product inspections, without securing the agreement of the EU to the changes, a two-tier system of export certification could emerge. The UK would then be likely to exert pressure on ACP governments to accept a UK certification process which the EU finds inadequate. Those ACP governments accepting the new UK export certification system would find their markets targeted by UK livestock product exporters.In other product areas the UK’s food deficit situation is likely to limit export diversion to ACP markets.However, were the UK government to act on calls from UK farmers organisations to impose equivalent controls on UK imports from the EU, so as to avoid unfair competition for UK producers from EU producers who do not have to cover the additional costs now facing UK producers (7), then given concerns over the capacity of EU vets to meet increased demand for export health certification and other pre-export checks (8), the scale of trade diversion to ACP markets could increase dramatically, as EU exporters also seek out alternative markets.The capacity constraints on UK trade related veterinary services is not only an issue for UK exports but also raises issues for UK imports of livestock products. The surge in demand and capacity constraints are likely to be such in the coming years serious questions are arising over the ability of the UK veterinary service to both restore export volumes for livestock products at anywhere near pre-Brexit levels, while at the same time maintaining the phytosanitary security of imported livestock products (1). The difficult choices facing UK veterinary inspection services in terms of the deployment of staff to either export trade related activities or import trade related activities, could give rise to both increased costs of UK phytosanitary border clearance processes and delays in the clearance of livestock product cargoes through UK border control process. These increased costs and delays are likely to fall particularly heavily on smaller scale exporters, given the ‘lumpy’ nature of the fees charged. This could compound problems already being faced by Namibian and Botswana exporters, who now need to serve UK and EU markets separately, if duty free access is not to be forfeit due to the new rules of origin complications faced along triangular supply chains requiring the movement of livestock products across EU/UK borders. |
Sources
(1) House of Lords European Union Committee inquiry, ‘Witten evidence BVA – EEH0027’,
https://committees.parliament.uk/writtenevidence/22436/pdf/
(2) House of Lords, European Union Committee report, ‘Beyond Brexit: food, environment, energy and health’, 23 March 2021
https://publications.parliament.uk/pa/ld5801/ldselect/ldeucom/247/247.pdf
(3) The Loadstar, ‘Defra says EU has changed the rules, forcing higher costs on UK SMEs’, 29 March 2021
https://theloadstar.com/defra-says-eu-has-changed-the-rules-forcing-higher-costs-on-uk-smes/
(4) thedairysite.com, ‘New UK border checks delay is a betrayal of vets and Brexit, says OV group’, 17 March 2021
https://www.thedairysite.com/news/56645/new-uk-border-checks-delay-is-a-betrayal-of-vets-and-brexit-says-ov-group/
(5) BMPA, ‘New Impact Report reveals the real cost of Brexit to the UK meat industry’, 24 March 2021
https://britishmeatindustry.org/industry-news/new-impact-report-reveals-the-real-cost-of-brexit-to-the-uk-meat-industry/
(6) The Economist, Charlemagne ‘How the British Become the new Turks’, 20 March 2021
https://www.economist.com/europe/2021/03/20/how-the-british-became-the-new-turks
(7) thedairysite.com, ‘The UK’s new Border Operating Model must deliver a level playing field, says NFU, 15 March 2021
https://www.thedairysite.com/news/56639/the-uks-new-border-operating-model-must-deliver-a-level-playing-field-says-nfu/
(8) The Grocer, ‘Brexit border check delay: are the extra months enough for food and drink?’, 19 March 2021
https://www.thegrocer.co.uk/brexit/brexit-border-check-delay-are-the-extra-months-enough-for-food-and-drink/654371.article