They still don’t get it…

Amazingly, there are still folk around Britain who have failed to grasp the meaning of the words”third country”, let alone why it matters. The Centre for Inclusive Trade reports a 16% drop in British food exports to the EU and is calling for concessions that would be unfair to other third countries. There isn’t a cat in hell’s chance of the European Commission doing a special deal for a former member state that opted to become a third country.

Process of elimination

If there is so much money at stake, how strong is the case for accusing food manufacturers of Ultra Processed Foods (UPFs) of wilful distortion? The arrival of wall to wall processed foods in British aisles in postwar years has been accompanied by rising numbers of patients needing treatment for heart disease and diabetes. While the nation gorges on sugar, salt and saturated fats, there is a drop in foods that bring whole grains, let alone fruit and vegetables. Processing very finely divided ingredients allows fertilisers and other toxic residues to spread downstream through the food chain. More worrying is the uptake of UFPs in the population. These foods now account for 57% of the adult diet and 66% of adolescent food intake. The health issues in later life are already filling up British hospitals and soak up two thirds of the health budget.

Big Food’s Big Secret

The UK government spends more than GBP 90 billion a year treating chronic food-related illness, according to the Food, Farming & Countryside Commission (FFCC). Researchers estimate that investing half that sum would be enough to make a healthy diet accessible to everyone living in the British Isles. The full extent of the damage caused to the UK economy by a dysfunctional food sector is GBP 268 billion pounds a year, taking lost productivity and early mortality into account, FFCC warns.

The Food, Farming & Countryside Commission is an independent charity, set up in 2017 to inform and extend public involvement in ongoing discussions about food and farming. Using government data as a starting point, FFCC argues that it would be significantly cheaper to produce healthy food in the first place. More to the point, it is not an option to go on footing the bill for damaged public health resulting from the commercial sector’s activities. There is simply not enough money in the kitty and time is running out. 

Researchers took into account government estimates of productivity and lost earnings arising from chronic illnesses. These indirect costs are borne by a range of actors in the economy, such as local government departments. Such costs are real expenditure, but the total figure is not recorded as a single aggregate figure. When combined with the initial figures, the result is a more imposing figure and looks like figure S1.

The direct costs (in red) are existing government data; indirect costs (in orange) indicate the economic impact associated with the prevailing levels of unemployment and early mortality. Like the submerged part of an iceberg, we ignore these costs at our peril.

Working with indirect costs opens the door to accusations of misinterpretation, but economists have worked hard to establish methods that can avoid serious pratfalls. Healthcare is supported by a wide range of funding sources, from government down to private individuals. The money is real enough, even when it comes from private individuals. It just becomes harder to count. There are times when budgets for nearby or related units will be skimmed to meet ad hoc requirements. Welcome to the economists’ underworld, where early retirement due to ill health is just another negative variable.

Pink, salty and out of stock

The UK’s high spending foodies have been facing empty shelves, where they would normally find taramsalata. The strike action at a Bakkavar factory in Lincolnshire has successfully kept the salty pink dip out of big name retailers, including Waitrose, Sainsbury and Tesco. These industry heavyweights will get their on back on all those involved in due course — and reduce dependency on Bakkavar by recruiting other suppliers. Here is how the BBC covered the story.

Delivering results?

Turn the clock back to 2013 and the UK was divided over its membership of the European Union. Given the vehemence of the anti-EU campaigners, buoyed up with sympathetic media treatment,  the 4% majority in 2016 was hardly a ringing endorsement for such a major change. The most memorable slogan of the time was “Brexit means Brexit.” Not surprisingly, there were also opportunities to use Machiavellian creativity to plug gaps in the Leave campaign.

It was a time in British politics when the civil service was flexing its muscles and in a position to engineer bids for power with a free hand, actively encouraged by Tory grandees like Francis Maude. Running the Cabinet Office, Maude had a  new vision for the Civil Service, which was going to be set free from such tawdry constraints as public service: it was to be redefined and rewritten using People Impact Assessments (PIAs). The Cabinet Office led the way, setting up hybrid public/private joint ventures and mutuals in a bid to gain the best of both worlds, so to speak. These were not just government departments on steroids, these were new power structures of a sort that could be presented as a public service and a commercially savvy business at the same time.

The first employee-driven joint venture was the Behaviour Insights Team (often referred to as “the nudge unit”) which opened for business in March 2013. Here is what was said at the time (https://www.gov.uk/government/news/government-launches-competition-to-find-a-commercial-partner-for-the-behavioural-insights-team):

“The government’s Behavioural Insights Team will take its first step to becoming a profit-making joint venture today as the Cabinet Office launches a competition to find a commercial partner for the business. Less than three years after it was set up in the Cabinet Office the team is the first policy unit set to spin off from central government. This has been employee-led as the staff of the BIT have driven the process and will continue to run the organisation.

“The team was established to find ways of encouraging, supporting and enabling people to make better choices for themselves. Since then it has delivered rapid results – identifying tens of millions of pounds of savings, spreading understanding of behavioural approaches within government, and developing a reputation as a world leader in its field. Demand for its services from within government, the private sector and foreign governments has grown significantly.” 

The decade was to see a blurring of the distinction between public servant and executive power. If political  factions ever needed to inject reliable, hand-picked people to oversee critical functions in the political process, a joint venture with a government department takes a lot of beating.

Networking and data services have been at the heart of a number of government joint ventures, with the government’s 25% stake being sold off at the end of the first ten years. So it was that the French business Sopra Steria bought out the Cabinet Office’s stake in Shared Services Connected Ltd in October 2023. Here is what they said at the time:

“The transition from joint venture to wholly owned subsidiary will not affect the management, employees, clients, or services of the business, which has delivered significant savings and value for money for the taxpayer.

“Since Sopra Steria founded the company with the Cabinet Office in 2013, SSCL has become the largest provider of critical business support services for the UK Government, Ministry of Defence, Metropolitan Police Service, and the Construction Industry Training Board (CITB), delivering shared services at scale.”

It is not uncommon for IT suppliers to be over-confident about their system’s ability to cope and there are signs that all is not well at the points of delivery in the UK. Dover issued a note to port users in early June, seeking details of operational failures with BTOM. Invoicing for the Brexit border tax has been plagued with errors, including double-billing.

Ten years ago, there can be little doubt that Francis Maude knew and understood the Sopra Steria motto of the day: “The world is how we shape it.” Reality has since dawned on the management and it has been withdrawn.

Taxing times

Time is running out for importers of food to the UK. On September 4 HMRC will demand its pound of flesh and the UK food industry will find itself between a rock and a hard place. This is not the first time that the deliberate destruction of the British economy by the departing government has been discussed on this site: it is still a live topic. Called the Common User Charge by civil servants, the UK’s stealth tax on food imports is also known as the Brexit border tax and doubtless has cruder titles.

Since August 4, many importers have been receiving their first invoices for Common User Charge (CUC. Importers of animal and plant products that would usually be considered for food safety checks can expect to pay over the odds for driving a lorry off a ferry at Dover to join the UK road network. Hauliers booking a DFDS one-way ticket online to Dover pay three pounds for this indispensable service, while lorries carrying grouped consignments of SPS foods face open-ended bills in the hundreds or low thousands for the same access. The simple explanation is that Britain is playing catch-up: the European Union had everything in place to trade with the UK as a third country the minute it ceased to be a member state. Britain was so totally convinced that it would somehow negotiate a favoured nation package Brexit that there was not even a sketchy idea of what a post-Brexit customs system might look like. The years passed, conveniently putting off the awkward moment when Brexit would be complete. As recently as November 2023,  DEFRA describes the organisational basis for European food imports to the UK thus: 

“Currently, imports from the EU and certain imports from Greenland, Faroe Islands and EFTA countries do not need to enter Great Britain via a BCP and are not subject to veterinary checks at the border.” 

(Source: http://apha.defra.gov.uk/documents/bip/iin/vcap.pdf)

Just two months later, Britain was rolling out its three-phase Border Target Operating Model (BTOM). (The label ‘world-beating’ is optional.) Lorry drivers arriving in Britain have not been impressed by the service standards they have encountered on  the ground (https://urbanfoodchains.uk/sevington-gives-cause-for-concern/), which is more of a hostile environment than a workplace.  

DEFRA has gone from absentee administrator to nitpicking zealot overnight and is chafing over the accuracy of form-filling, notably for consignment detail on Export  Health Certificates (EHC). Hang on to your hats, here is a sample:

Continuous and/or deliberate non-compliance  

It has come to our attention, that some traders and logistics companies are making continuous and/or deliberate errors including:

mis-declaring goods as low risk when they are medium;

or as medium when they are high;

 not including a relevant Export Health Certificate (EHC) or Phytosanitary certificate.”

Or the consequences… :

“Continued non-compliance within either the EHC or the CHED is not acceptable and will not be tolerated by Port Health Authorities (PHAs). Deliberate misdeclaration is a criminal offence.  PHAs will be actively looking to identify such behaviour.

“Where there is repeated non-compliance or evidence of misdeclarations, the appropriate authority will take statutory action. This will result in goods being held at a Border Control Post (BCP) for a physical inspection, which may lead to the consignment being ultimately returned or destroyed at cost to the person responsible for the load.

Entering a conversation with a tone like that is doomed to become a monologue. Enough said. Now it just remains for the law enforcers to round up a bunch of suspects.

Since the end of April, Dover has been receiving a steady trickle of complaints about the way the Brexit border tax has been implemented. Here is what Dover had to say on the subject, again verbatim:

“As you are aware, the Border Target Operating Model (BTOM) checks have been operational for a month. Aside from initial teething problems, we are receiving a growing number of queries and concerns about how the checks are being carried out versus the costs that are being charged, delays to consignments, poor responses to calls and/or appropriate live assistance with your imports, the impact on biosecurity and the possibility of using Dover BCP to complete checks.

“It is important to understand your experiences so far to enable us to help establish simple solutions moving forwards, so we would like to set up a short call to discuss this with yourselves.

“Please drop us a line outlining your concerns and suggested solutions so we can escalate these for you. In addition, a member of our team may also call you.” 

The simple fact is that the CUC started off on the wrong foot and is compounding ongoing problems on the way. It was cobbled together out of retained EU law. Its stated aim is to recover the operating costs of Border Control Posts in the UK, but this does not stand upto close inspection. Officially, CUC rates for privately-owned ports are set by their owners. At regular intervals, DEFRA kicks the distinction into touch by stating that the tax is being charged at Dover and the Eurotunnel terminal. 

The port of Dover  has belonged to the town since it was incorporated in 1608 by James 1. Some members of the port harbour authority board are appointed by the department of transport, but this is a working arrangement rather than a power grab.

At the beginning of June, Dover issued the following statement, which I cite verbatim:

“We are writing to you with reference to the ‘Operational Border Target Operating Model Information’ Defra circulated on the 03/06/2024 which contained a significant inaccuracy regarding the BCP for high risk food not of animal origin arriving via Dover within the section ‘Moving high-risk food and feed not of animal origin at the Short Straits’.

“To clarify, if you are importing high risk food not of animal origin (HRFNAO) through the Port of Dover, either via RORO ferry terminal and / or deep sea cargo, you must continue to pre-notify Dover Port Health Authority on IPAFFS using the Dover Terminal BCP code GBDOV2P and not, as outlined in the Defra information update, Sevington BCP.

“Official border controls on high risk food not of animal origin arriving via RORO freight have been undertaken at the BCPs in the Western Docks for over a decade and since 2019 at the Cargo Terminal GBDOV2P (in the Western Docks).  

“Dover Port Health Authority will continue to provide this statutory function and ensure that your goods are handled efficiently and without undue delay. Please note, the Common User Charge does not apply to the Dover Cargo Terminal BCP. The Common User Charge will be applied if your goods are notified to Sevington BCP by selecting their different BCP code on IPAFFS.”

Dover puts food safety first

 Dover port health staff carrying out food safety checks are being sidelined by DEFRA, which is telling importers that their goods should be routed through Sevington. Before shipping certain goods, importers must pre-register the shipment using a system called IPAFFS which is short for Import of Products, Animals, Food and Feed System. DEFRA is telling everyone to delete the Dover port code from the documentation and  to change their IPAFFS point of entry to  Sevington.

Staff at Dover have been carrying out SPS food safety checks for a decade, but they have never found themselves at loggerheads with DEFRA before. The root of the problem is the Border Operating Model (BTOM), which is not set up to manage product assessments requiring detailed knowledge and experience. 

Assigning three levels of risk to food imports does not cover real life situations. Take High Risk Food Not Of Animal Origin HRFNAO, which is a detailed listing of food products that need to be checked for specific  hazards. These can include central European blueberries, which are checked for radioactive Caesium 137 from Chernobyl; peanut products from north and south America, which are checked for aflatoxins; or US fishery products, for which processing hygiene standards vary widely.

There is a statutory compliance angle to these product checks, which are regulated by assimilated European laws. At this point they are beyond the remit of BTOM and DEFRA is not authorised to change their enforcement. So instead, the ministry has been advising importers to amend the IPAFFS entry from Dover to Sevington.

In the meantime, Dover port health staff continue to carry out the food safety checks that keep the nation’s food safe.

Every one of them is different

Sky News is currently streaming an overview of British farming (https://news.sky.com/story/it-keeps-me-awake-at-night-can-british-farming-survive-13132220) which raises a number of questions that have been dodged for years and are coming home to roost with a certain inevitability. They are as predictable as ever, as intractable as ever and demand answers as urgently as ever. The only certainty is that the farming sector faces a crisis which has been ignored for years and will no longer wait in an orderly queue.

The first thing that needs to be made clear at the outset is that there is no such creature as an average farmer. The Sky presentation is very careful to choose visually tame representatives of a sector that  is universally misunderstood. Sky’s lead journalist on this reporting, the west of England and Wales correspondent Dan Whitehead, would doubtless agree that despite the rapidly falling numbers of farmers in Britain, there is no such creature as an “average” farmer anywhere in the world.

The industrial world develops and markets a range of specialist vehicles and technology for a sector that has as many solutions for its many technical challenges as it has practitioners. The general public, in Britain and further afield, has no problem synthesising a stereotype notion of a nonexistent rural world. In the process, any suggestion of  a viable business model  runs counter current to the town dweller’s vision of a rural idyll.

It would not be productive to imagine that rural businesses are complementary to industrial or urban economic structures. Nor can the transport and distribution networks that link urban consumers to an imagined rural hinterland ever ensure that each business gets what it needs in a timely manner.

A frequent town dweller’s  notion of a farm is more like a zoo than a production unit. Go back a century or so to George Orwell’s Animal Farm and you encounter a group of anthropocentric livestock: hens, pigs, cattle and heavy horses. Truth to tell, if it ever existed, this diverse community of livestock was a casualty of the first world war. The two million British equine casualties had a greater impact on warfare and industry than the loss of several millions of military personnel or civilians killed in air raids elsewhere. British army officers were required to supply a horse’s  front hoof when reporting an equine casualty, whereas they did not need to furnish any such grisly evidence for human casualties among their ranks.

The wartime massacre of draft horses was beyond the breeding capacity of the northern hemisphere and cleared the way for mechanisation in both rural hinterlands and metropolitan centres alike. The British army bought in horses from as far away as North America, but they were ill-suited to military requirements.

Both agriculture and industry have exhibited huge appetites for energy during the past two centuries. The combined effects of converting the plains of North America into a grain exporter on a continental scale. This was accompanied by the relentless westward advance of the railroads through the 1850s and 1860s, hauling wheat back to the east coast and shipping it on to Europe. 

The age of steam put bread on the tables of starving cities. It may even have given urban populations a passing curiosity as to where food comes from and what sort of people might produce it. But the only people that ever had contact with producers and consumers were traders with a limited interest beyond crop forecasts and spot prices. It is hardly surprising that during the intervening decades, a parallel web of dreams fed on pictures in books and magazines should inhabit part of the cultural vacuum between town and country. 

Dan Whitehead’s rural narrative assembles facets of the  agricultural world as a kaleidoscope might do. He starts by talking to Welsh sheep producer Rhodri, who has seen a 40% cut in his income, now shorn of subsidy. He is worried that his school age son will not inherit the family farm.

Outdoor pork producer Jeff laments the supposed passing of the British pig industry. Like many British pig producers, he believes his European counterparts are subsidised as generously as they have ever been. He can’t go into a supermarket without spotting foreign meat: pork chops from Spain, chicken from Poland and Brazil. He can sum up Brexit in one word: “atrocious”. From his farm in Kent,  Jeff drove a tractor up London for a city centre protest. Like many in the pig sector, he is adamant that breeders have been thrown under a bus by a government that doesn’t care. “There’s an  unfairness in British agriculture,” he argues. Looking at the deals the UK government signed with Australia and  New Zealand, he might have a point.

Nearby, fruit grower Tim has built up a strawberry business valued in tens of millions of pounds. He needs a workforce of 2000 to pick thousands of tonnes of strawberries. Most of his recruits are from EU member states. When the UK was in the single market, workers could move  freely with no time limits. Now they are limited to six months and have to move on regardless of whether or not they are a net gain or a net drain on their employer. Tim is frustrated because he cannot negotiate prices for his crop from a solid position. 

There are plenty of British pig producers who will argue that foreign pigmeat is hindering domestic producers, but the story is a little bit more subtle than that. If British producers could earn a living off the sales of pork loins, they would cheerfully do so. Since loins are used for roasting joints or bacon, there will always be buyers for this cut. This often leads to a situation whereby British loin are sold through for roasting joints. Meeting demand for bacon packers, there is a steady trade in pigs from Dutch and Danish units. These have been raised to British standards for decades and are effectively competing on a level field, even if their British counterparts see it differently. The key to staying in business is referred to as balancing the carcase, ensuring that every saleable part of the carcase is sold. Hams or gammons are straightforward to prepare for the retail market and represent a good return. What British pig breeders often overlook, however, is that they will routinely export forequarters to cutting halls in northern Europe, which have skilled workforces that make short work of the technically challenging forequarters. These are home to the animal’s powerful jaw muscles. If a pig bites your hand, count your fingers as soon as you’ve stemmed the bleeding.

Measuring progress

On Your Farm presenter Charlotte Smith and Archers’ actor Lucy Speed open the programme from the middle of Devon by explaining that they are looking for a farm but are surrounded by large sheds and outwardly industrial structures. Somewhere in this seemingly inappropriate setting, they are expecting to meet Andy Gray, a possible finalist for one of the programme’s annual awards.

Andy’s business bridges the gap between livestock farmers and end users of meat. He operates the large food grade cutting and packing lines that they saw on arrival. As well as selling dog food, he also farms 150 hectares of arable crops, as well as keeping a herd of deer and a herd of cattle. Other business activities in his eclectic business include a quarry for heritage building stone.

During the visit, the conversation turns to remedial best practice for soil and the new funding schemes for English farming, based on the provision of a public good such as healthy soil. Rothamstead soil scientist Andy Neil is on hand to discuss some of the vital detail. Charlotte Smith is impressed that Andy should have engaged a Rothamstead professional to measure the recovery of former arable fields. Andy, on the other hand is pragmatic: if he can’t quantify the improvements he is making on his land, he won’t get any government cash. Gotcha.

Milestone or millstone?

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.