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.
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.
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.
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 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.
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.”
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.”
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.
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.
For years the Common European Tariff has ensured that imports of third country pet food have been taxed heavily at the border. Duty of up to EUR 948/tonne is added to the invoice price of any dog food that might cross the EU border. The exact rate depends on the product’s composition. During the UK’s years as an EU member state, UK customs officials were ready and waiting to do their bit to ensure that third country pet food did not arrive unchallenged by officialdom. Needless to say, a duty regime as strong as this has successfully excluded products which faced duty out of all proportion to their price.
Click the image to download Schedule XIX, then go to file page 93, which is folio 87. (A folio is a printer’s name for the number on a page, the numbering of which may be dislocated by front matter, such as prefaces and other preliminary matter.)
That was then and this is now. We have been through Brexit, which remains a work in progress. As the world’s most recent third country, has the UK risen to the challenge and opened the gates to imports of third country pet foods? Have the punitive levels of duty been dismantled in the UK’s Schedule XIX? Guess.
The table shows the current duty rates for goods covered by customs code 2309 10 – Dog or cat food, put up for retail sale (highlighted in yellow). Click the image to download the complete document. Betweentimes, the tariffs have been redenominated in GBP at an exchange rate of around 85 pence to the Euro. Depending on the formulations, these products face duty up to GBP 805/tonne and are essentially unchanged. Given the stated aim of Brexit to boost trade with the rest of the world, it would have been simple to edit the twenty or so tariff lines, setting them to zero, job done.
The irony of the Brexit debacle is that it neither achieved any of its wild dreams, nor were any logical adjustments carried out to meet Brexit’s stated aim of trade liberalisation. The Common European Tariff (CET) was drafted as a blunt instrument to suggest that the cost of subsidised products under the Common Agricultural Policy (CAP) could be calculated with a degree of accuracy. The CAP has evolved since these agri-tariffs first saw the light of day, losing much of their relevance in the process.
But let us start at the beginning. At the risk of stating the obvious, the UK chose to become a third country, in the EU sense of the term, used to refer to non-members of the EU. The Common European Tariff is built on this “us and them” view of the world. This detailed document was structured for this purpose and no other. The UK has adopted it with a surprisingly low number of often symbolic modifications, leaving the original EU intent intact.
It comes as a bit of surprise to learn that such humble products as dogs’ dinners command such high levels of duty. Animal foods are a downstream activity that typically draw in by-products from the manufacture of more lucrative goods. Industrialised food production brings with it a higher degree of homogenisation in both ingredients and by-products. There is a business case for ensuring that all available downstream ingredients are incorporated in some sort of secondary product, even if it only serves to dodge the cost of waste disposal. Indeed, the tipping point between a positively-priced ingredient and the operational cost of managing indeterminate mush is a crude measure of technological sophistication. That said, it will be searched for more closely in company accounts than production lines.
Working with documents generally supposedly means keeping one’s hands clean. This is a moot point, which can be illustrated with a straightforward example: tariff item 0208 40 10 is whale meat, once a common ingredient in pet foods many years ago. Third country whale meat is taxed at 6.4% ad valorem. There is a case to be made for taxing it mercilessly, on environmental grounds. There is a procedural problem with this, however, since the World Trade Organization will only cut tariffs, but not raise them. Since the WTO decisions are based on consensus, any attempt to obstruct international trade in whale meat will be systematically be blocked by Japan, Iceland and the Faroes. There are similar problems, on a smaller scale, with a 6.4% ad valorem duty on tariff item 0208 90 70: frogs’ legs.
Not long ago the Grocery Code Adjudicator’s office published its report for the past year. The reality behind the lukewarm prose is more disturbing than might first appear: the complaints raised are predictably familiar and there are multiple labels for what appear to be depressingly perennial abuses. More to the point, given the confidentiality of the process, it is not possible to determine an order of magnitude for the sums involved. This is not just a nice-to-have ballpark figure, but a true measure of the scale of a continuing problem.
The presentation and figures can be downloaded here. There are a good two dozen descriptions for the issues that have been raised by suppliers. The rates of change given for year-on-year complaint numbers are within five or six percent of the previous year, which is supposed to mean that everything is under control. The message is a very firm “…nothing to be seen here. No, really, THERE IS NOTHING to be seen here…” Yet the sort of practices that suppliers are complaining about would normally merit criminal investigations. Or would insisting on the letter of the law just put suppliers out of business?
Those who have been in the food industry for years will have acquired a collection of tales of extortion and graft that at first hearing seem overstated, but which become hard to ignore or dismiss. A lifelong food industry veteran put it this way: “The multiples have been running circles round the government for years. It’s been going on for decades. These days retailers are so used to demanding money left right and centre that it’s hard to know how they keep track of their real costs.”
It is well nigh impossible to assign an order of magnitude or give a steer on how serious the ongoing abuse might be in the grocery trade. Let us be as circumspect as possible in unpacking this one. Let us assume, for instance, that there is only one instance of a dispute under any of these headings and that the percentage figure, rather than referring to a case load, is a crude measure of the sums of money involved. Anything bolder than that would suggest a totally compromised food industry. Don’t rule that out, by the way.
Now take the following two GCA sub-headings as examples:
(a) Requests for payments to keep your existing business with a Retailer (pay to stay)
(b) Requests for lump sum payments relating to Retailer margin shortfall not agreed at the start of the contract period.
These both look suspiciously like blackmail, but let’s try to estimate an order of magnitude for these actions. Shelf money demands are usually based on a fixed sum per SKU per product range, for a listing across two to three hundred sales outlets. To get an idea of the sums of money that can be involved, assume the product concerned costs one pound and comes in five flavours and three pack sizes (sub-total 15 SKUs). Pull a pay to stay value out of thin air of GBP 5000 for each SKU listing across 250 sales outlets, fifteen SKUs times GBP 5000, guesstimate budget GBP 75000. If the retailer has a markup of 20p, the pay to stay demand is equivalent to a supplier “giving” 375,000 units of product (20p times 375,000 = GBP 75,000). While it is not unheard of for retailers to withhold all or part of an invoice, it is not in the suppliers’ interest to hand over lorryloads of product, which will earn the retailer the full retail price at the checkout: literally having their cake and eating it.
Given that a hypermarket can easily have up to 20,000 food SKUs, not counting own-label lines, you could end up with an aggregate demand for shelf money running to millions of pounds if they were all to be counted towards a shelf money Christmas list. Given that these are very large wadges of money to conceal on a balance sheet, our imaginary retailer will probably need all the accounting strategies they can think of to hide the true state of the cash flows. Again, to avoid overstatement, we will assume that each heading only refers to a single instance of a commercial abuse.
In choosing a theoretical sum of GBP 5000 per SKU for shelf money, this could be seen as an exaggeration. However, one simple factor ramping up shelf money demands is the simple proliferation of the high street formats for mainstream food retailers. It is highly improbable that a retail multiple would forego an established shelf money framework when opening high street stores. However, competing convenience stores simply do not have the kind of clout that a major multiple can bring to bear on brand owners in a store format that leans heavily on established brands.
The office of Grocery Code Adjudicator was set up about 20 years ago and spent about half that time building up its role as a trusted arbiter, a lap dog rather than a watchdog. It is hard to imagine that it has done more than scratch the surface of the very real problems facing food manufacturers and brand owners in their dealings with a clique of very powerful customers, the multiple retailers.
If current headlines (week 24, 2023) about the turmoil in the Conservative party appear serious, wait until the parlous state of the UK’s unfinished Brexit arrangements come home to roost. History will judge those responsible, but the UK population will pay the price. Having copied and pasted the Common European Tariff into the UK economy, ministerial hands have been fiddling with some of the detail, but not with any visible signs of understanding what they were about.
As one might expect, the Common European Tariff is haunted by a number of ghosts in the machine. These are mainly mechanisms that protected former cornerstones of the Common Agricultural Policy from third country imports. With some dating back to the 1970s, these tariffs were supposed to make subsidised EU agricultural products competitive on the internal market against third country goods. Many of the tariffs are ad valorem percentages, but most of the politically sensitive sectors supported by the CAP are made up of an ad valorem percentage and a flat rate payment per 100kg in Euros, redenominated in GBP.
Third country olive oil arriving in the EU still faces a flat rate duty of EUR 124.50 per 100 kg. For some years now, there have been trade deals with third countries such as Tunisia, which establish a duty-free quota for EU packers. This olive oil can then be traded freely within the EU.
Under Rules Of Origin (ROO), however, any third country olive oil arriving in the UK is liable for duty at GBP 104 pro rata in blends, converted into sterling at around 85p to the Euro. Now the UK has no indigenous producers of olive oil to protect from competitive pricing of third country oils and ministers could have cheerfully set the duty to zero.
All the schedule XIX money values appeared in Euros before Brexit, as they did when the document first appeared in the summer of 2018. For its UK enquiries, HMRC works in pounds and pence. The transfer of Schedule XIX to Sterling was carried out by the WTO (World Trade Organisation) but there remain a lot of unresolved issues that will take a lot longer to resolve than Brexit. With more than 160 members, the WTO’s insistence on consensus makes bluster and confrontation counter productive. Brexit negotiations were shot through with contempt for consensus on the British side. In Geneva it doesn’t wash.
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