Thread by @pmdfoster

🚨🇪🇺🇬🇧🚛🍫🥧🍕🍪🚛🇪🇺🇬🇧🚨From April 21 the EU is introducing new rules on composite foods (pizza, chocolate, crisps etc) that are going to pile new red tape on U.K. food manufacturers/1

My latest for @FinancialTimes with @mroliverbarnes @jimbrunsden

on.ft.com/38u6VeO

@FinancialTimes @mroliverbarnes @jimbrunsden So what fresh hell is this? Well, the EU has a new regulation coming into force on composite foods - 2020/2235 - which will require 'third countries' (which the UK now is, after #Brexit) to do a lot more form-filling at £m's to industry /2

publications.europa.eu/resource/cella…

@FinancialTimes @mroliverbarnes @jimbrunsden The new rules mean that so-called "shelf-stable" products that contain meat (a pepperoni pizza) or pasteurised milk (a choc bar or a curry sauce with yoghurt in it) will require a vet-stamped Export Health Certificate.../3

@FinancialTimes @mroliverbarnes @jimbrunsden Other 'composite' products will require "attestations" from industry saying where the plant/animal products contained therein come from...so a maker of cheese in onion crisps will, per @Foodanddrinkfed wonks, need to 'attest' where the cheese in the cheese powder came from /4

@FinancialTimes @mroliverbarnes @jimbrunsden @Foodanddrinkfed Of course cheese might have come from multiple dairies and different batches of powder will be used in different batches of crisps....but they'll need have the "attestations" to show provenance/traceability /5

@FinancialTimes @mroliverbarnes @jimbrunsden @Foodanddrinkfed There is quite a lot of murkiness about how much this will 'capture' but @Foodanddrinkfed says a member that had 60% of products needing EHCs is now closer to 90%; another that had no need of EHCs now has 30% of products captured /6

@FinancialTimes @mroliverbarnes @jimbrunsden @Foodanddrinkfed This will land heavily on:

- Vets who've only just got to grip with old EHC regime, now need to add bunch more, per @BritishVets president @uttoxeterjames

- The chilled food trade with Ireland per @ChilledFood @KaarinGoodburn

- And, when grace periods expire, GB-NI trade/7

Taking each in turn, the vets is both a cost and a capacity issue.

For now feared shortages haven't arisen since lot of trade has stopped, though "pinch-points have" but these new checks will test capacity - and have potential knock on impacts for other parts of industry/8

Foz biz it's cost. As one snack company tells @Foodanddrinkfed:“We will need a vet on site for 10 hours per day, five days a week at a cost of £300,000 per annum. Multiply this across our sites where we export and we are looking at a potential cost running into the millions."/9

@Foodanddrinkfed For the £13.5bn chilled food industry, that employs 80,000 people about 5%-8%, per @ChilledFood Assoc is Ireland-related and a lot of that trade is unviable with this level of paperwork, per @KaarinGoodburn - the margins, the delays at border pre-notifying etc /10

@Foodanddrinkfed @ChilledFood @KaarinGoodburn And when UK grace periods expire on NI Protocol, all this will apply to goods shipped GB-NI.

an Wright of @Foodanddrinkfed warns, unless checks are "proportionate" a lot of his members will find shipping to NI uneconomic /11

@Foodanddrinkfed @ChilledFood @KaarinGoodburn If you want to get a sense of an 'attestation form'...take a look at this. Page 402 onwards gives you a sense of what's needed. It's a bit of a head-scrambler and needless to say other 'third countries' aren't relishing the prospects /12

publications.europa.eu/resource/cella…

@Foodanddrinkfed @ChilledFood @KaarinGoodburn One big help *might* be to try and get pasteurised milk included in the list of 'shelf stable' product input that would NOT require a full EHC (stamped by a vet) but just an attestation. This would slim down the volumes of new EHCS.../13

@Foodanddrinkfed @ChilledFood @KaarinGoodburn At the moment the regs seem to say that only dairy products that have undergone specific 'risk mitigating' treatments escape need for EHCs - see note 10 , (Annex V, p405) here: /14

publications.europa.eu/resource/cella…

@Foodanddrinkfed @ChilledFood @KaarinGoodburn The rubric that notes refers to is here (this is what the policy wonks at @Foodanddrinkfed now have to get into) and it doesn't appear to include pasteurised milk. So every chocolate bar with a 'glass n a half' etc is captured /15

legislation.gov.uk/eur/2020/692/a…

@Foodanddrinkfed @ChilledFood @KaarinGoodburn I understand that the government is trying to get clarity on this, since it would help smooth thinks along, but worth noting that none of the EU-UK trade deal (TCA) supervisory committees are operating, so not clear how much help anyone's going to get/16

@Foodanddrinkfed @ChilledFood @KaarinGoodburn Of course, these new regs will fall on all third countries, but the reality is they are not doing the kind of intense, just-in-time trade that the UK does with the EU. So we're mapping processes designed for long-sea trade onto fast-flowing pipe of UK-EU trade/17

@Foodanddrinkfed @ChilledFood @KaarinGoodburn One other unanswered question is whether the UK will put similar requirements on EU exports into the UK (tit for tat) and even whether the UK has the will/capacity to enforce such rules.

Of course masses of this could be alleviated by SPS alignment/Vet agreements etc /18

@Foodanddrinkfed @ChilledFood @KaarinGoodburn For now, it may well just be that some parts of some businesses for some UK food producers are just collateral damage in the #Brexit process, which is bad luck for them. Whether it creates localised job losses/pinch-points in certain areas tbc /19

@Foodanddrinkfed @ChilledFood @KaarinGoodburn It does seem kind of self-defeating on both sides, and perhaps in time things will calm down a bit - but for now, sharpen your pencils, break out the wet stamps, there's more #Brexit bureaucracy on the way. ENDS