Bracing for no-deal impact: UK government issues guidance on animal trade ahead of Brexit

25 Sep 2019 --- Importers and exporters of animals and animal products are being urged by the UK government to prepare for Brexit on October 31, as these will be subject to new requirements if the nation leaves the EU without a deal. This would include foodstuffs ranging from cuts of meat to cheese, as well as fish and fishery products. The rules would also apply to the import and export of live animals and other consignments such as germplasm and animal by-products.

Government guidance outlines steps businesses will need to take to import or export these goods. Government has also stated it is communicating directly with these businesses and individuals to help make sure they are Brexit ready.

“While the government is seeking a deal with energy and determination, we have stepped up our preparations and we will be fully ready to leave the EU on October 31, whatever the circumstances,” asserts Minister of State for Agriculture, Fisheries and Food, George Eustice. “If you or your business import or export animals or animal products such as meat, eggs or dairy, we want to help make sure you are ready for Brexit. Our guidance is designed to clearly set out the steps you need to take to ensure you are ready to trade after we leave the EU.”

Guidance for exporters
The UK government outlines the following recommendations for exporters in no-deal preparations:

• If the UK is granted listed status for third country exports of animals and animal products, food exporters, in addition to meeting customs requirements, will need to ensure:
  • All consignments are accompanied by Export Health Certificate (EHC) signed by a certifier such as an Official Veterinarian or a Local Authority Environmental Health Officer.
  • All consignments travel via a Border Inspection Post (BIP). A list of current BIPs have been published online by the European Commission under its veterinary border control guidance.
  • All consignments comply with food labeling requirements which are detailed on the UK government’s Brexit food labeling webpage.
  • Additional paperwork is required for exporters of fishery products to ensure fish has been caught legally.
• Flowcharts for import and export processes following Brexit have been published, outlining the steps exporters will need to take.
• The UK Animal and Plant Health Agency (APHA) has also issued technical guidance to local government Certifying Officers for a new risk-based approach for EHC inspections for fish. This will help reduce the amount of time involved per EHC application for fish exports.

Guidance for importers
While imports of animals and animal products can continue after Brexit, the UK government notes that the way that notifications are raised is also changing. Businesses importing certain goods from outside the EU will need to use a new system called the Import of Products, Animals, Food and Feed System (IPAFFS) to notify the authorities of their imports.

The IPAFFS system will replace the EU’s Trade Control and Expert System (TRACES) currently used by businesses. UK government notes that 977 registered users have already signed up for IPAFFS, which have undergone a series of improvements during 2019. Users are encouraged to register for IPAFFS starting from September 30, when guidance and user support will be available.

The UK has asked the EU for continued access to TRACES for imports from the EU for a limited time, but importers would still need to notify the UK Animal Plant and Health Agency (APHA). However, should that not be granted, businesses importing these consignments from the EU will need to notify authorities using a different process. Details on the import process are available online on the UK government’s website.

Industry impact
With Brexit looming and free-trade deals in development, legal experts have cautioned that Britain faces the prospect of watered-down food regulations after Brexit, with Parliament having little say. Chlorinated chicken, as part of a post-Brexit free trade deal with the US, could be the “thin end of the wedge” that may impact public health and threaten thousands of jobs in the UK food processing industry, according to Unite, Britain and Ireland’s largest union.

Meanwhile, the UK retail industry has rejected government claims that there will be no shortages of fresh food under a no-deal Brexit scenario. MP Michael Gove was questioned about food supplies on the BBC's Andrew Marr Show earlier this month, insisting that “everyone will have the food they need” if Britain leaves the EU without a deal. But retailers – who have been warning for years a no-deal would be “catastrophic” on food supply – have hit back. “It is categorically untrue that the supply of fresh food will be unaffected under a no-deal Brexit.

By Benjamin Ferrer