Brexit Paperwork Headache for Short Shelf Life Composite Products

Given that the vast majority of foods represented by CFA comprise ingredients from animal origin (e.g. meat, dairy, fish) and plant materials, they are categorised as Composite Products in international trade, requiring Export Health Certificates (EHCs) signed off by Official Veterinarians (OVs).

Last autumn, CFA secured a member’s involvement in live trials of exporting a composite food, which confirmed critical issues previously highlighted by CFA to Defra.

With the end of the Transition Period at 2301h on 31 December 2020 came the introduction of extensive Third Country veterinary certification requirements for export of foods containing animal origin ingredients, from Great Britain to the EU. The same requirements were due to have been required for GB-Northern Ireland goods movements from 1 April but have been paused by the UK Government to 1 October at the earliest, with composite products being phased in last. The chilled food sector primarily exports to the island of Ireland so although exports to the Continent have virtually ceased, impacts of the new paperwork, certification and administrative systems requirements have so far been limited to Ireland in practice.

Capacity issues

A CFA survey of chilled and frozen composite products estimated that some 30,000 EHCs would be required where none were before. According to Animal and Plant Health (APHA) data provided to the industry, there was 126-fold increase in the total number of EHCs for EU export issued in January/February 2021 compared with the same period last year – from 491 in that period in 2020 to 61,802 in 2021. Each composite product EHC needs to be supported by detailed supplementary information for each animal origin ingredient including the Approved source, processing details and dates of production, by batch being exported, and to be signed by an OV. This represents a huge new administrative burden – introducing new costs and delays in what was a highly efficient system facilitating rapid flow of chilled short shelf life complex foods made to order on the day of despatch. It also raises concerns over whether there are sufficient number of OVs to sign the certificates.

CFA has been working with the British Veterinary Association (BVA), the professional body for OVs, to identify such issues and find solutions. This CFA engagement with BVA, the UK’s Chief Veterinary Officer, and the relevant Government department in Ireland (DAFM), has already simplified aspects of composites’ EHC completion for exports to Ireland.

However, new EU Animal Health Law (2016/429) published in March 2016 when the UK was still an EU Member State, will on 21 April, according to CFA data, bring an estimated one third more chilled composite foods within its scope, so requiring EHCs where they currently exempt. Even those composite foods which are exempt from EHCs will require Private Attestations running to several pages of required detailed information for them to be exportable to the EU, and at an unspecified date post 1 October, to Northern Ireland. The question is whether all this new administrative cost can be borne, given existing profit margins.

CFA not only alerted wider industry to these issues but has set up an EHCs Associations Group for food trade associations and the BVA, as a forum to engage with Government veterinary officials, identify and resolve problems.

Solutions to keep the nation fed

The Association has also developed a checklist with the BVA to assist food businesses in ensuring that OVs have appropriate professional status, the required specific training and adequate insurance cover for their food certification work for export, e.g. EHCs. Links are included to supporting information on specific Royal College of Veterinary Surgeons, APHA and Improve-OV requirements.

CFA is working with Defra on the development of its ambitious Digital Assistance Scheme (DAS) to facilitate the continued supply of food to Northern Ireland from 1 October through the digitisation of paperwork and its submission to existing export systems, e.g. TRACES NT, TSS. It is critical that any such system is easy to use, with the information requirement limited to only what is needed by law, and, importantly, be compatible with companies’ existing systems.

CFA Director Karin Goodburn explains: “Leaving the EU has had a profound effect on the day to day working lives of vets, the free movement of our workforce, and of course on the exportation of Just in Time short shelf life food. When the UK from 1 October implements its own controls on imported foods we will open another chapter, with uncertainty about its impact on the flow of foods and ingredients from the Continent and Ireland at a time when the UK crops season has ended and we are most dependent on imports. CFA shall continue to work to find solutions to protect industry so it can export and import for the benefit of our economy and of course to keep the nation fed.”

15 April 2021