Urban Food Chains

the links between diet and power

Imminent change

Since leaving the EU, the UK government has operated transitional biosecurity arrangements, including one called Place of Destination. After a number of postponements, the scheme is finally being withdrawn on April 30 to make way for the long-awaited Border Target Operating Model (BTOM).

This will redraw the map for traders, legislators and consumers alike, including a number of far-reaching modifications to the way the border will be managed. It marks the start of a shift away from EU standards to a home-grown hodge podge. In its day, Place of Destination allowed businesses to do their own product checks at a time when UK border facilities were either not available or still under construction.

DEFRA’s own description is an opaque blend of jargon and legalese: “The PoD scheme not only afforded flexibility to businesses as they adjusted to the new requirements following the end of the transition period, but also allowed the UK government time to thoroughly design BCP infrastructure and processes, maintaining frictionless trade, while protecting GB biosecurity.” The present outlook is not encouraging.

On Monday, March 12, the EFRA Select Committee met under the chairmanship of Dr Neil Hudson to discuss the ongoing shortage of vets to carry out routine health checks on inbound food products. The UK’s chief veterinary officer Christine Middlemiss told the committee that when the UK left Europe there was a shortage of vets in the order of 11%, and, that to her present knowledge, this was still the case. This sounds odd, since the demand for routine veterinary validations for food imports is rising steadily. Westminster has known for years that the food industry was facing a skills gap. A House of Lords committee warned of this in 2017 [click link to see context] and the idea that demand could be static is frankly a non-starter.

Consolidated Dover background

This extended post replaces a number of earlier posts, to include more detail.

 Two million lorries passed through Dover in 2022, down 17,000 on 2021. This year the government will roll out its Border  Target Operating Model (BTOM) management structure. Part of the new system is a flat rate payment of (£20 to £43) per consignment per lorry. The Common User Charge covers the use of the terminal, but not inspection fees.

International borders and biosecurity are 24/7 commitments, so when Dover Port Health Authority (DPHA) started planning its Point Bastion Border Control point (BCP) for England’s busiest port, it envisaged a 1,200-space lorry park close to the port with customs inspection facility working a 24-hour working day. Dover port received a royal warrant from King James I in 1606 and operates independently to this day, owned by Dover Harbour Board.

The port handles goods worth £144 billion a year, around a third of the goods traded in the UK. There are two distinct strands to its food enforcement workload. There are the ongoing investigations to catch impromptu smugglers with small batches of unhygienic meat in variable states of decay, destined for closed ethnic groups with money to spend on familiar foods and flavours. 

This contraband has no paperwork and is carefully concealed in all manner of vehicles. In the weeks running up to Christmas 2023, five or six tonnes of illegal meat products were confiscated at Dover. Legal lorry loads of meat and animal products pass through the port, destined for UK food industry customers: processors, manufacturers, wholesalers and retailers. 

The scale of this work goes a long way to explaining the original decision to have extensive parking facilities.  

As well as the Common User Charge, the range of foodstuffs that will be routinely tested on arrival in the UK will rise, with the addition of medium-risk plants and plant-based products. Environment ministry DEFRA is quick to point out that any inspection fees are payable on searched consignments in addition to the CUC. 

Dover handles millions of lorries in a year and Common User Charge would be expected to generate tens of millions of pounds before factoring in groupage.

The port is unusual but by no means unique to be a major port with an independent management structure. Dover East docks are built on an artificial headland created when the railway was separated from the dockside. Space is at a premium here, a deciding factor in the development of Point Bastion. The House of Commons Environment, Food and Rural Affairs Committee heard on March 1, 2022 that work was progressing well and 500 specialist staff had been recruited. (https://committees.parliament.uk/oralevidence/9794/pdf/)

The same committee hearing had similar news from Sevington BCP, a 174 million pound development close to the Eurostar terminal at Ashford. This site had originally been commissioned by the Department for Transport (DfT) with an expected lifespan of five to 10 years. 

What happened subsequently is not clear, but HMRC revised its parking requirement for Point Bastion from 1,200 spaces to 96. Dover Harbour Board (DHB) faces cuts to it enforcement activities. Someone in the corridors of power unhelpfully suggested recovering the shortfall from successful prosecutions of illegal meat and animal products. DHB is fending off calls for its food safety checks to be carried out at Sevington, 22 miles away on the A20(M).

More worryingly, the Commons EFRA select committee heard Karen Betts, chief executive of the Food and Drink Federation, expressing her concerns that official vets working for foreign food manufacturers might not fill in the customs  declarations correctly for ready meal products like lasagne. It  is a big ask. 

When the UK left Europe and re-instated third country export rules, the number of qualified vets  plummeted. Where once there had been 1132 vets in the UK to fill in export health declarations in 2019, now there are just 364. There has been a 1255% rise in requests for valid export certificates.

Brexit is far from being “a done deal.”

DEFRA description of common user charge:

Defra has developed a charging model to recover operating costs for government-run border control posts (BCPs) in England ahead of planned implementation of SPS checks on EU imports in January 2024. The legal basis for charging is Article 81(b) of the retained Official Control Regulations (OCR).

Defra proposes administering a single Common User Charge: a flat rate levied on every SPS consignment (Plants and Plant Products (P&PP) and Animal Products) which is eligible for BCP checks and enters through the Port of Dover or Eurotunnel Le Shuttle, whether selected for a check or not. This does not include goods arriving as rail freight via the Channel Tunnel, or personal imports arriving on the Eurostar and Dover Ferry passenger services as these goods will not be subject to SPS checks at a BCP. Imports of live animals will not have charges applied until they are subject to checks at a BCP, scheduled for late 2024.  The Common User Charge approach flattens the rates, spreads the burden, and provides a high level of certainty to importers. These charges are intended to recover the costs of operating the BCP facilities as set out in Article 81(b) of the retained OCR which are necessary to undertake physical inspections. This charge would be separate to any charges applied by the Port Health Authority and Animal and Plant Health Agency (APHA) for inspections. The Common User Charge also does not include charges applied by other government agencies for activities outside of the BCP, such as any customs checks.

https://consult.defra.gov.uk/government-bcp-charging-strategy-implementation/charging-at-government-border-control-posts/Click for source.

In DEFRA’s own words: “The Common User Charge… ( approach flattens the rates, spreads the burden, and provides a high level of certainty to importers. These charges are…) …(is)…intended to recover the costs of operating the BCP facilities(… as set out in Article 81(b) of the retained OCR which are necessary to undertake physical inspections…). This charge would be separate to any charges applied by the Port Health Authority and Animal and Plant Health Agency (APHA) for inspections. The Common User Charge also does not include charges applied by other government agencies for activities outside of the BCP, such as any customs checks.”

Food imports set for price hike

After a couple of years of waving through EU imports of meat and animal products with no dockside checks, the UK government is about to apply a sharp twist to food pricing this year. It will start charging businesses a fixed charge on all shipments passing through government-run Border Control Posts. Referred to as the Common User Charge (CUC), it was put out for consultation over three weeks in July last year. While the CUC will be a single fixed payment, there are uncertainties over inspection charges for food shipments that would be billed by BCP operators*. These can total hundreds of pounds for a large container.

On January 31 2024, DEFRA brought into force a number of measures for each of the three risk categories (https://www.gov.uk/government/publications/border-target-operating-model-information-leaflets-for-businesses/technical-questions-and-answers-about-sanitary-and-phytosanitary-controls-sps#risking-approach).

These are as follows

From 31 January 2024, DEFRA has introduced:

  • health certification on imports from the EU and European Free Trade Association (EFTA) of medium risk animal products and the introduction of health certification on imports from the EU, Lichtenstein and Switzerland of medium risk plants and plant products
  • health certification on imports from the EU and EFTA of high-risk food and feed of non-animal origin
  • import pre-notification and health certification when moving EU and EFTA animal products or EU, Switzerland and Lichtenstein plant products from the island of Ireland, to align with the rest of the EU (for example, any goods other than qualifying Northern Irish goods from Irish ports directly to Great Britain)

As of April 24,in DEFRA’s own words:

From 30 April 2024, DEFRA will be adding:

  • the introduction of documentary and risk-based identity and physical checks on medium risk animal products, plants, plant products and high-risk food and feed of non-animal origin from the EU
  • existing inspections of high risk plants and plant products from the EU will move from destination to Border Control Posts
  • beginning to simplify imports from non-EU countries – this will include the removal of health certification and routine checks on low risk animal products, plants, plant products from non-EU countries as well as reduction in physical and identity check levels on medium-risk animal products from non-EU countries

What will DEFRA deliver?

2.1 How are checks within a port or airport’s perimeter organised, and who does what and has accountability to make it happen?

Within the curtilage of a sea or airport, the port operator will direct the movement of consignments. At the Border control post (BCP), APHA will undertake checks on live animals, or plants and their products.  The Port Health Authority/Local Authority will undertake checks on animal products and High-Risk Feed or Food Not of Animal Origin (HRFNAO). The port operator will not release a consignment from the port until they have been informed that it has been cleared by the relevant inspection authority.

2.2 Will BCPs be ready? Do they have sufficient capacity?

Defra is confident that existing and new BCP infrastructure will have sufficient capacity and capability to handle the volume of expected checks outlined in the BTOM, with robust, dynamic, and effective operational measures ready to call upon if needed. Defra will continue to work with existing BCP operators to ensure they are prepared, and the Government has built new infrastructure at critical locations. Operators have not expressed concerns regarding under-capacity, we are therefore not anticipating queues but will continue working closely with operators to address any concerns they may have.

What next?

Britain’s busiest ferry port faces the risk of bankruptcy following Westminster’s decision to retract millions of pounds in funding for swine fever checks on pigs arriving at the port of Dover. The money has already been spent during the financial years for which it was allocated. The local council meets tonight (Monday February 5) to plan for the coming months, when food testing will be rolled out further.

A third of Dover District Council’s budget is diverted from local government to funding food safety checks at the UK’s largest passenger and freight terminal. In June, this figure will rise to nearly half. Dover handles up to 120 ship movements a day at peak periods and moves a third of the UK’s food imports.

The harbour is run by an independent trust, set up by an act of parliament and given the task of managing the busiest ferry port in the UK. Since the legal requirements are set by national laws, Dover has no choice but to comply. The district council is run by a Labour group with a majority of one elected in May last year. The harbour’s independent status means that theoretically it can set whatever prices it needs for its services to pay their way. The reality is not that simple

The real retail equation
https://www.channel5.com/show/aldi-vs-lidl-supermarket-wars

This evening I watched the Channel 5 documentary Aldi vs Lidl: Supermarket Wars. The program makers correctly identified the standard set of superficial differences that are plain for all to see. However, while setting out to explain the yawning gap between UK and Continental business models, the detail was a bit sparse. For instance, consumer journalist Harry Wallop does his bit to keep alive the 1966 World Cup mindset, evoking a long departed anachronism rather than twenty first century marketing.

The programme’s narrative starts in the 1990s and portrays the discounters as eccentric oddballs with a business model that worked in Germany but needed tweaking for more lavish UK mindsets. British food retailers had established a stranglehold on the postwar consumer economy and raked off substantial sums of cash from suppliers, known as shelf money, hello money, listing fees, the list was endless. Large retail businesses expected to be paid GBP 5,000 a year per Stock Keeping Unit (SKU) to be listed at 200-300 stores. Example: food manufacturer presents a family of six snack products in the early 1990s and would be asked to stump up thirty thousand quid for listings in up to 300 stores. Any subsequent special offers were funded by suppliers, in the form of free product (physical stock); or credit notes or deductions from existing/current invoices.

Given that even a modest hypermarket would stock 25,000 to 30,000 SKUs in those days, the retailers were making lorryloads of money while pretending to be church mice earning a miserable 4% profit on return. The arrival of the German discounters threatened to blow their cover and the major multiples were not keen on this. The reason Aldi and Lidl could run rings round the big four within a few years of arriving was that the discounters only ever discussed prices with suppliers and never asked for shelf money. Carving out a substantial market presence without constantly squeezing suppliers, the discounters have demonstrated that it can be done and done honestly. That spooked the multiples even more.

Footnote: At the time of writing, continental retailer Carrefour is playing the commercial equivalent of Russian roulette with snacks and soda giant Pepsico. Initially limited to France, Carrefour stores across Germany, Italy and Spain are now all locked in to a life and death fight over trading terms (shelf money). Even if Carrefour dumps Pepsico (unlikely) there is no way that the tonnages of product could be secured from other manufacturers. Also in France, the eponymous independents’ chain E Leclerc is reading the riot act to its suppliers. Running a tighter ship than BlueBeard, second generation chief executive Michel-Edouard is threatening hellfire and brimstone for all those who challenge his figures. For years now, the group has only ever paid for one tonne of potatoes out of every 1.2 tonnes delivered, insisting that there is a lot of slack (waste) with this crop. This is simply not true: any fresh produce department anywhere in Europe that is experiencing more than 2.5% slack across a week would be hauled over the coals.

245% duty shock for UK cheese

British cheese exports to Canada will face duty of 245% next year, once the third country duty-free quota is exhausted. Some 95% of this quota is already taken by products arriving from Norway and Switzerland, leaving very little for shipments to any other third country.

This slap in the face for British cheesemakers comes as Canadian negotiators came amid talks on the implementation of the much-vaunted bilateral trade deal. Refusing to roll over previous extensions to zero percent duty available under former EU terms, the so-called cheese letters, the decision vapourises pre-Brexit claims of extensive growth in UK food exports. These will in fact be treated like any other third country products, in the absence from specific terms agreed during the framework negotiations. Last year, the UK exported cheese worth nearly GBP 19 million to Canada.

Growing concern

Hundreds of acres of cultivable farmland will be cleared to make way for houses as far as the eye can see. In the coming months, Mid Sussex District Council will hear applications from developers wanting to build 1500 houses between the villages of Ansty and Cuckfield. As well as residential properties, there will be shops and amenities in addition to a headline-grabbing 30% allocation of social housing. Whether or not the developments will ever release as much as 30% for social housing remains to be seen, but it needs to be there at the outset..

This major development plan faces problems, however. To begin with the new homes will generate additional demand for water in a part of the world where demand for water is already comparabl;e to desert regions.The loss of 250 acres of farmland is nothing short of disastrous: the UK cannot afford to throw away productive land.

Global factors keep pushing up UK food prices

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.

Late, random and arbitrary

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.

Coincidental good fortune

A recurring theme in Chris Packham’s series Earth is the timely coincidences that came with planetary events. Having just re-watched the third of the five part series, it is striking how the twin-track development of what later evolved into plants depended on some shared resources with what later became fungi. The proto-fungi extracted minerals from bare rock that nourished evolving plants, while the early plants gave glucose to their fungal partners. Without this leap in evolution, we would not exist today.