Summary
The shortage of UK veterinarians required to sign off on Export Health Certificates could seriously constrain UK exports of livestock products destined for the EU market. While Export Health Certification issues should impact on exports to all destinations, if the UK government adopts the BMPA proposals to use supervised Certification Support Officers instead of fully qualified veterinarians to sign off on Export Heath Certificates this could facilitate exports of UK livestock products. However, the EU is unlikely to accept such a downgrading of export health certification controls, without a thorough assessment of the phytosanitary and food safety implications. This could create a situation where in 2021 the new supervised Certification Support Officers were able to sign off on exports to non-EU destinations but not exports to the EU. This would lay the basis for an expansion of displaced UK livestock product exports to ACP markets rather than the EU markets currently served. In the poultry sector, this needs to be seen in a context where over half of all UK extra-EU poultry meat exports were destined for ACP market in 2019.
Against the background of its earlier concerns about the customs and trade documentation challenges which any outcome to the Brexit process would generate, the British Meat Processors Association (BMPA) has called on the UK governments to modernise and digitise its customs and product certification systems. The BMPA argued the current paper-based system is simply not designed for the operation of modern ‘just-in-time supply’ chains when serving neighbouring markets across newly established regulatory and customs borders (2).
This needs to be seen in a context where the EU is the UK largest overseas market for livestock products by a ‘large margin.’ The BMPA highlighted how the ‘vast majority’ of UK meat exports to the EU (between 75-80%) ‘involves small, grouped consignments of different goods that originate from a variety of meat plants… bound for several different delivery points in Europe’. Since 1 January 2021, each individual consignment now needs ‘a separate Export Health Certificate (EHC) signed by a vet’, with the ‘more pick-up and drop-off points that are involved in the supply chain, the more EHCs are needed’ (2).
According to the BMPA there are simply not enough veterinarians ‘in the right place at the right time to inspect the loads, verify traceability paperwork and sign the Export Health Certificates.’ The government claims this issue is being addressed. However, while the UK governments’ Department for Environment, Farming and Rural Affairs (DEFRA) estimates an additional 300,000 Export Health Certificates will be needed each year, the BMPA believes this seriously underestimates new Export Health Certificate requirements. The BMPA points out how this ‘total could be surpassed easily by just four companies in beef and lamb consignments alone’, factoring in smaller producers, as well as the dairy and poultry sector exports it is maintained the number of new Export Health Certificates required ‘will run into millions per year’. With it taking 20-40 minutes to complete each Export Heath Certificate, given the number of qualified veterinarians currently available, it is argued the new demands will simply swamp the system for export certification (2).
The situation is further compounded by the IT system currently in use for issuing Export Health Certificates itself. While the UK government is establishing a new on-line portal for applications, this system has ‘not been stress tested to see if it will cope with the huge flood of extra applications.’ Even before 1 January and the surge of new demands, BMPA members were reporting ‘applications are taking longer to process’ (2).
What is more, given the increased paperwork required and danger of road haulage delays generated by any shortcomings in the paperwork submitted at the UK/EU border, many road haulage operators are refusing to handle ‘groupage’ cargoes (that is cargoes consisting of consignments from more than one origin destined for more than one drop of point). This is a matter of some concern since around 40% of all UK meat industry exports to the EU market make use of ‘groupage’ road haulage services. (1).
Against this background the BMPA has proposed the UK government take three specific actions:
- ‘Instruct, and financially support, all Official Veterinarians employed (directly or indirectly) by the Food Standards Agency or other government agency to play a direct role in supporting the export certification process for products of animal origin’.
- Ensure the Animal and Plant Health Agency significantly simplifies its guidance on how official veterinarians at the last point of departure should utilise previous controls to expedite the export certification process.
- ‘Revise the rules on what inspection and verification must be done by an Official Veterinarian’, to allow ‘appropriately trained and supervised Certification Support Officer’ to issue Export Health Certificates (3).
It is feared that if these issues are not addressed, these non-tariff issues could lead to UK suppliers of livestock products largely being driven off EU27 markets. This would then leave UK livestock product exporters looking for alternative export markets for these displaced UK products.
| Comment and Analysis The new challenges faced for the entry of UK livestock products to the EU market and the impact of new customs and regulatory paperwork on ‘groupage’ road haulage practices could see large volumes of UK dairy, lamb, beef and poultry exports displaced from EU markets to third country markets. This issue is of greatest concern in the poultry sector. In 2019 the UK exported a total of 340,289 tonnes of poultry meat to the EU27 (and 197,458 tonnes up to July 2020) (4), while exporting in the whole of 2019 only 119,978 tonnes of poultry meat to non-EU27 countries (see companion epamonitoring.net article, ‘EU Figure Highlights Importance of UK Market to EU27 Poultry Sector’, 7 July 2020). Even considering the fact that Northern Ireland (which accounts for a 1/3 of UK poultry meat production), remains within the EU customs union and single market, UK poultry meat exports to non-EU markets could more than double, if problems in accessing EU27 markets are faced by poultry meat producers in the mainland UK. Given UK poultry meat exports to the EU27 mainly consist of poultry parts destined for eastern European markets, sub-Saharan Africa, which to date has been the major market for European produced poultry parts, is likely to become an important market for the export of displaced UK poultry meat exports. In 2019 the UK exported poultry meat to 19 sub-Saharan African, 1 Pacific and 10 Caribbean ACP countries, out of a total of 70 non-EU27 destinations. Sub-Saharan African countries took 42.3% of extra EU27 exports and the Caribbean 12.5%. All in all, in 2019 well over ½ of total UK extra EU poultry meat exports were destined for ACP markets. Against this background, any displacement of UK poultry parts from the EU27 to 3rd country markets would be likely to see a sudden surge of UK poultry meat exports to ACP markets. Of course, it can be argued the Export Health Certificate constraint will impact on UK poultry meat exports to all destinations, with this reducing the likelihood of an export surge to ACP countries. This would be particularly the case, since with limited access to services issuing Export Health Certificates UK exporters would be likely to prioritise the higher value EU markets rather than low priced ACP markets. Problems however would arise of the UK government took up the BMPA recommendation to move over to a system whereby ‘appropriately trained and supervised Certification Support Officer’ could issue Export Health Certificates rather than fully qualified Veterinarians.
EC, Market Access Data Base, Such a move would not be immediately acceptable to the EU, given the strict phytosanitary import controls it maintains and the non-discrimination commitments it has made in its dealing s with third countries. In this context the UK government could then non-EU countries to accept health certification by appropriately trained and supervised Certification Support Officers, thereby freeing up fully qualified veterinarians to certify exports bound for EU markets. The use of Certification Support Officers would partially remove the Export Health Certificate constrain on UK exports to non-EU markets, with this fuelling an expansion of exports to ACP countries. This would then pose an uncomfortable challenge to ACP governments in their dealings with the UK, namely: should they accept or reject any UK’s proposals for the use of Certification Support Officer in the export health certification of livestock products? It should be noted that similar, if less pronounced challenges, could be faced by ACP governments in dealing with UK beef and dairy sector exports. Indeed, given the sudden dramatic multiplication of export health certification needs, it could also impact on the exports of livestock products from those EU member states with a high dependence on the UK market, most notable those in the Republic of Ireland, with Irish beef, poultry and, to a lesser extent, dairy products, all being displaced to some degree to third country non-EU markets. |
Sources:
(1) The Grocer, ‘Meat sector warns long-term export trade could end amid ongoing border chaos’, 19 January 2021
https://www.thegrocer.co.uk/brexit/meat-sector-warns-long-term-export-trade-could-end-amid-ongoing-border-chaos/652245.article
(2) thepoultrysite.com, ‘British meat industry calls for an orientation phase after Brexit transition period ends’, 17 December 2020
https://www.thepoultrysite.com/news/2020/12/british-meat-industry-calls-for-an-orientation-phase-after-brexit-transition-period-ends
(3) thedairysite.com, ‘UK meat companies raise concerns about customs certifications ahead of Brexit deadline’, 10 December 2020
http://www.thedairysite.com/news/56243/uk-meat-companies-raise-concerns-about-customs-certifications-ahead-of-brexit-deadline/
(4) EC, ‘EU Market Situation for Poultry Committee for the Common Organisation of the Agricultural Markets’, 18 June 2020
https://circabc.europa.eu/sd/a/cdd4ea97-73c6-4dce-9b01-ec4fdf4027f9/24.08.2017-Poultry.pptfinal.pdf
(5) EC, Market Access Data Base
https://trade.ec.europa.eu/access-to-markets/en/statistics?includeUK=true