THE UK government has begun to introduce post-Brexit border controls on poultrymeat and egg products imported from the EU.
From the 31 January, new border controls were introduced for EU traders wishing to export a range of produce into the UK – here, we consider how it could impact the poultry sector.
The so-called Border Target Operating Model (BTOM) has finally been instigated following five delays from the UK government fearing disruption to the supply chain and food price inflation.
It will in some ways address a significant imbalance for the UK’s poultrymeat sector – controls on those exporting produce to Europe have been in place since January 2021.
The British Poultry Council estimates this has cost the UK sector £55m in additional costs each year since, with no equivalent burden on EU exporters to the UK, who, until the end of January, were able to trade produce as they did before Brexit.
That aside, it is a legal requirement to introduce controls, as under World Trade Organization rules, the EU cannot effectively have a trade advantage when compared with the rest of the world.
What does the new regime look like in practice?
The British government is introducing the BTOM in phases, with this first one requiring Export Health Certificates (EHCs) for consignments for certain products, including poultrymeat and eggs.
EHCs are a seven-page document that, for livestock produce, must be signed off by a veterinarian in the country of export. They are designed to ensure products entering the UK are free from diseases that could threaten UK agriculture.
Arguably the most significant stage comes on 30 April 2024, when physical inspection of medium- (i.e. poultrymeat and eggs) and high-risk produce begins.
These will take place predominantly at existing border control posts, many of which have been extended in anticipation of higher inspection rates.
From October, the government will also require safety and security declarations for medium- and high-risk imports.
How might it impact the poultrymeat and egg sectors?
The new regime will add complexity to those wishing to export poultrymeat or eggs from Europe into the UK.
Imports of both have increased significantly in recent years, with some of the major UK poultrymeat integrators having supply chains that stretch across Europe and European egg product being an important ingredient for British food manufacturers.
Trade associations are both questioning the borders’ readiness to deal with the assumed additional inspection volume and in particular the risks to food fraud.
There are also practical questions, according to a letter written by 30 trade associations – including the BPC – to Defra secretary raising concerns over the new regime.
One point in the letter is as follows:
3) Export Health Certificates (EHCs) & Phytosanitary Certificates
(a) GB EHCs for EU-GB trade do not always match industry’s requirements for ingredient/component supply, e.g. pasteurised liquid egg products – plain egg yolks and egg yolks with sugar are not mentioned in the GB EHC and therefore no longer possible to import to UK. There is no flexibility in the GB EHC for alternative equivalent thermal processes to be used.
Scale of the issue: e.g. liquid egg imports from the EU-UK were approx 41.3 million kg in 2022.
Impact: GB food businesses producing e.g. desserts, mayonnaise, sauces, baked goods, will have insufficient supply to continue to produce these and other foods using them, impacting on GB food security and product availability.
Solution: EHCs need to be amended now for GB supply to continue and the myriad of foods using them to continue to be produced in GB.
Another major concern raised is the effectiveness of the checks being carried out. A new border control point serving Dover is at Sevington, 22 miles from the port. “Detail is needed now on the precise measures UKG will be putting in place to ensure security/prevent offloading of uninspected/illegal food en route to Sevington, in addition to clandestines[sic].”
The British Poultry Council said establishing efficient, fair trading with Europe was a priority, and with the full controls only introduced in April, “we’re still some time away from seeing a truly reciprocal approach to trade with our biggest and most important trading partner”.
It added a “mutually beneficial” veterinary agreement recognising the equivalence of standards – something the Labour Party has said it would negotiate if in power – could help smooth the flow of goods each way.