Category: customs clearance

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Global factors keep pushing up UK food prices

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Over the past two years, climate change and rising energy costs have been the two biggest sources of food price rises. Analysis by The Energy and Climate Intelligence Unit (ECIU) suggests that even if energy costs ease, climate change will carry on pushing up food prices in years to come. With hundreds of acres of UK farmland covered with floodwater as I write, the water levels will lead to lost crops, forcing farmers to write off produce that would otherwise have counted towards the UK’s economic activity. Replacements will be required for the lost stock, which may need to be imported,

Climate change cost UK consumers an extra GBP 171 in 2022, rising to GBP 192 this year. While the ECIU expects energy price rise to ease in years to come, the think tank still reckons that households have had to find just over GBP 600 for environment-related price drivers in 2022 and 2023. Dr Tim Lloyd, at Bournemouth University, argues that energy pricing is behind 59% of all UK food price rises. All over the world, drought and heatwaves are affecting basic commodities such as olive oil, canned tomatoes, sugar and rice. Food prices are rising everywhere: this is inevitable, given the way food is traded.

Fast forward to 2024 and UK voters go to the polls. Next year, six years later than promised, the UK government is promising to phase in the plant and animal checks that were a part of the EU border control infrastructure. This inspection activity does not come cheap and will be added on to the cost of importing food. Just when consumers thought things were settling down, they can look forward to an unexpected surge in the cost of imported food.

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Late, random and arbitrary

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One of the most frequent arguments trotted out for Brexit was that it was time to take back control of international borders. The ‘take back control’ mantra was somehow an irrefutable justification when all else fails. It remains more of a fig leaf than a reasoned argument.

Having regained third country status to make this dream come true, the UK has obtusely dragged its feet over implementing the veterinary aspects of border control. The simple truth is that the commitments which come with international borders were not in fact a top priority for British politicians. There has been little political appetite to ensure full compliance with post-Brexit structures from day one, possibly because the necessary skill sets are in short supply.

The declaration of a 10km Temporary Control Area for blue tongue around a dairy farm in Kent came as a wake-up call the UK government. It was as if Westminster was caught out taking a calculated risk that there might not be any significant animal health issues. There may not be a serious risk of the notifiable disease spreading, the real problem is the political fallout from gaps in the UK’s veterinary provision under international animal health treaties.

This autumn has seen the implem entation of the first phase of the UK government’s Target Operating Model (TOM), marking greater reliance on digitised documentation and a move away from visual inspections. If all goes according to plan, the next twelve months will see the implementation of sanitary inspections by customs staff. The laboratory and testing fees will be charged to the owners of the goods concerned,. The additional costs will be significant but randomised. The testing will have an inflationary effect, but this will neither be directly attruibutable nor constant. It will b e impossible to predict reliably, but will generate resentment.

Customs checks to cost importers 330m gbp

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After putting off the implementation of full customs checks five times for imported goods arriving in the UK, Westminster will start enforcing its post-Brexit customs regime for all imported goods in 2024. Cabinet Office minister of state, Lucy Neville-Rolfe, told MPs that the fully operational customs system would cost UK businesses an additional GBP330 million a year. About half this increase will be absorbed by veterinary paperwork, which was not demanded on day one of Brexit. The full cost of becoming a third country has effectively been concealed from the British public for five years and was only revealed on the eve of the Conservative party conference with a full and controversial agenda. https://www.theguardian.com/business/2023/oct/01/uk-admits-extra-330m-a-year-charges-post-brexit-food-imports

Is digital documentation secure?

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There is something to be said in defence of human-readable documentation. It’s not perfect, but you don’t need to open the file on a machine to get sight of it.

This summer, the European Union published its plans for an integrated digitised customs system to cover the entire single market. A single EU Data Hub will be phased in around 2028, providing a single unified portal for third country exporters to document shipments to the EU. Compliance, repeat orders, along with such customs documentation as will be retained by the new system, will all be locked up in this portal. The official line is that customs compliance will be enforced uniformly and centrally, giving customs officers “…a 360-degree overview of individual supply chains…” and freeing up resources to ensure that a centralised European Union customs agency will run like clockwork.

There are plans to abolish the 150-dollar duty-free allowance, a routinely exploited weak point in e-commerce. Consumers will no longer face unexpected charges on e-commerce transactions. This happy state of affairs will come about thanks to e-commerce platforms taking on the administration of tax and customs procedures. Sounds too good to be true.

Milestone or millstone?

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This week the UK delivered the world’s first fully digitally documented consignment of goods. Burnley engineering firm Fort Vale became the first UK exporter to put electronic documentation on an equal footing with paper forms. This was made possible by the Electronic Trade Documents Act (ETDA), which came into force on Wednesday. To be sure, the goods involved were not food products, but Urban Food Chains wanted to mark the occasion anyway. Here’s a link to the gov.uk statement.

Meursing numbers in practice

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Highly processed foods are a technical challenge for customs valuations, requiring standardisation and accuracy. In the EU the task of establishing a core element in the customs valuation is carried out by using a set of laboratory protocols to establish the precise proportions of dairy fats, dairy proteins and sugars.

The purpose of Meursing numbers is to provide a reliable way of calculating the duty on ingredients in highly-processed foods. The protocols cover the required procedures for measuring four ingredients: milk fat; milk protein; sucrose and invert sugars. These values are then read off a Meursing table, which has 32 rows for the possible combinations of the milk components and 19 columns for the sugars. The three figure codes in the tables are transferred to the customs documentation, preceded by a 7, flagging it as a special additional code.

Most third country exporters of biscuits and bakery goods face a lengthy documentation process. The UK, however, has not been required to use Meursing codes since April 2021. Not that this has stopped folk from feeling hard done by.

A work in progress?

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As the world’s most recent third country, UK food exports are at the receiving end of thorough checks on entry to the EU. All animal products are allocated risk levels and inspected accordingly; plant material undergo a parallel set of phytosanitary (plant health) checks. For UK exporters, the administrative overheads of complying with food safety standards were a known quantity long before the January 2021 transfer to third country status when UK shipments were routinely checked in Border Control Posts (BCPs).

The UK has yet to carry out its longstanding commitment to implement a mirror image system with the same inspection protocols for food shipments coming into the UK. Until that happens, Brexit is no more than a work in progress, not a done deal.

At the time of writing, the UK government is poised to kick border checks on into the long grass for the fifth time, delaying the full complement of checks until autumn 2024. This should come as no surprise, given the gaps in government resources.

Westminster is wrestling with a structural shortage of vets who are authorised to issue valid health declarations. This was a known issue in 2017 when a House of Lords select committee warned of a vet shortage, among other things, in its report Brexit: plant and animal biosecurity Over the past few years there have been a number infrastructure modifications at UK ports to house BCP facilities. The situation is complicated by the fact that around the UK not all ports are in public ownership and many have hybrid management frameworks. For some, the fabric of the port is its capital, meaning that a parliamentary bill may be required to underwrite loan capital for major infrastructure investments. This is only one factor among many that has cooled the government’s will and ability to act, however.

The UK food industry is caught up by its own reluctance to make the transition to full food safety checking at internal borders. This is not a public health issue so much as a tangle of red tape and knowledge gaps. At any given time of the day or night, there will be dozens of lorry movements up and down the country, heading for Northern Ireland. Leaving aside the unionist arguments against having a border check where none should be required, there is potentially a grittier problem to resolve.

There is a lack of old-fashioned stock control clerks with previous experience of customs documentation. The real problem is that the documentation travelling with a load is closer to a customs valuation than a handlist for whoever has to unpack the roll cage when it arrives instore. The stock in trade of an RDC (Regional Distribution Centre) is a loaded roll cage with dozens of SKUs, more or less stacked in the order they were picked. This is adequate for England and Wales, but is not a promising start for goods which may need to be inspected on a line by line basis in a customs shed.

The rules for calculating a customs valuation are clear and there are a number of ways in which a customs valuation may be arrived at, each with its own methodology. Think of the process as HMRC making a window into a retailer’s accounting system and then discovering anomalies with earlier figures. These could arise from the ways in which shelf money is managed or have an innocent explanation, but making a case to HMRC for a wide gap between a low customs valuation and a full retail price is not what people want to spend time on just now, if at all.

The additional cost of physical checks just adds to the awkwardness of the situation. The UK government is preparing to run documentation checks on inbound animal products for just over GBP 30, but is fighting shy of publishing a price list that would put physical checks into the six or seven hundred pound bracket. These inspection costs would feed directly into the import VAT calculations, pushing up the final figure.

The uncompromising attention to detail and the time these checks will add to operating costs — meaning that they should be blamed on a new incoming government in the wake of a general election. This morning’s BBC news carried an item to the effect that MPs standing down at the next election, or defeated at the ballot box should continue to be paid for four weeks instead of the current fortnight. Someone in Westminster is reading the writing on the wall.

Line for line

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The product descriptions that appear alongside customs codes in a schedule are set in stone. The whole point of the Harmonised System (HS) is that at any given time, specifications are the same from one trading bloc to the next. When classifying carcases, for example, there is no adjustment to be made for organic product over intensively-raised. The existence of additional input costs is of no concern when filling in customs declarations. Every market has its own mechanisms for assigning values and prices, which are separate from fiscal liability.

Westminster faces customs stalemate

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The Scottish parliament is accusing Westminster of intransigence over the halted building work at the Scottish car ferryport of Cairnryan. Work to build a Border Controls Post (BCP) started after getting a government green light last year. Since then, construction has ground to a halt, as Westminster has refused to give a binding commitment to fund the BCP in full.

Sailings from Stranraer were transferred to the nearby Dumfries and Galloway port of Craigryan back in 2012, for operational reasons. Wholly-owned by Larne Harbour Ltd, Craigryan is a part of the P&O landside portfolio. It can operate up to 16 sailings a day, serving destinations in Northern Ireland.

While Brexit negotiations were in progress, Westminster was committed to funding border infrastructure in full. The Scottish parliament is concerned that it may end up footing part of the bill for port infrastructure on a privately-owned facility. There are also political sensitivities about a requirement for customs facilities on what is currently an internal border.

The implementation of Sanitary and PhytoSanitary (SPS) checks that are the reason for building a BCP in the first place has not happened. Successive start dates in 2021 and 2022 were announced and cancelled: Westminster is currently planning to start SPS checks on livestock and animal products in July, although the BCP site at Cairnryan might not be operational by then.

From a commercial point of view, ferry traffic patterns have changed since Brexit, making the business case and the requirement for a BCP a moot point. The introduction of inbound SPS checks for the UK cannot be evaded forever.

Unfinished business

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Years after leaving the European Union, the United Kingdom is finally preparing to standardise sanitary and phytosanitary border controls for imports of animal products and plant material at the UK border. This long-running shortfall in customs procedures has been a recurring bone of contention.

Those of us with long memories will recall Boris Johnson assuring EU leaders that he had a workable solution for the Irish border. This ground-breaking declaration rapidly degenerated into despair and disillusion as it became increasingly clear that Boris had no intention of delivering any such thing.

Just in case this sounds overstated, listen to Boris Johnson’s biographer Anthony Seldon talking to Sky News about Johnson’s real Brexit agenda. https://www.facebook.com/watch/?v=1009898093714184

This failure has been the elephant in the room haunting European relations ever since. When the UK first announced its intention of becoming a third country, France moved swiftly and decisively to implement a range of Border Inspection Post (BIP) facilities at Calais to complement those available at Dunquerque and Boulogne sur Mer. The substantial investment and recruitment drive was a prerequisite for handling third country imports of animal products and plant material from the world’s newest third country, the UK. The French government was in a position to act in a timely manner, since the state owns all the country’s port facilities, the daily management of which is delegated to local chambers of commerce.

The English situation, on the other hand, is an arbitrary mix of publicly and privately owned ports, in which the larger ones are public assets while many smaller ports are privately-owned and/or run by trusts. These routinely require government legislation to authorise investment capital, often secured against the assets and fabric of the ports concerned. This less-than-satisfactory muddle means that the government could not require some ports to release land for goods inspection facilities without first checking the local management structure(s). The UK government intends to expand its existing provision of inspection facilities along the lines of EU system, seemingly more cheaply than what the EU would charge for inspecting goods travelling in the opposite direction.

The EU has round 400 Border Inspection Posts (BIPs), later renamed Border Control Posts (BCPs). These are equipped and authorised to inspect consignments of specific livestock species and/or products derived from them. Importers need to book an appointment and plan their journey accordingly. Likewise, shipments of fish and plant material will be directed to BCPs that are equipped to inspect them. EU checks on paperwork are capped at around 45 Euros per consignment. Randomised physical inspections cost around 450 Euros for a container and are charged to the owner of the goods concerned. Regardless of any duty payable on the goods, VAT is payable on the inspection fee, as a component of import VAT. The UK government is quite clear in presenting its plans for border checks that it will retain the principle of charging for inspecting paperwork, but charge a single one-size-fits-all fee for all traffic, regardless of whether or not goods are physically checked. (link)

“It is the UK Government’s intention that there will be charging at Inland Sites to recover operating costs which are necessary to undertake physical inspections at BCPs. The UK Government will consult on its proposed methodology and rates in the coming weeks to inform charging levels. The proposal is to administer a Common User Charge on each consignment which enters through Port of Dover and Eurotunnel that is eligible for SPS checks. The charge would apply to all eligible consignments, whether or not they are selected for a BCP inspection. The indicative Common User Charge rate is estimated to be in the region of £20-£43, however final rates will be determined following consultation.”

The document does not specify a price range for physical inspections and it is not clear whether there are enough qualified vets to cover such a requirement. This light touch, combined with the government’s enthusiasm for trusted trader schemes suggests that physical inspections will be the exception rather than the rule.

The extra cost of shipping animal products into Europe as a third country has hit UK exporters, who were not warned in advance. There’s a footnote about import VAT here, by the way.