Four years on: How food importers are feeling the Brexit ‘dividend’

It’s four years to the day since the UK formally left the EU and producers in the EU are preparing to face the biggest change in UK border rules since Brexit as the new Border Target Operating Model comes into force. The right time to introduce these changes - and indeed whether to introduce them at all – has been debated for many years by ministers. Now, they are finally going ahead.

The three core elements of border checks - Customs Declarations, Safety & Security Declarations, and Export Health Certificates for plant and animal products - have been mandatory for UK suppliers to the EU since December 2020, when the EU imposed all requirements in full. But until now, suppliers going the other way have only needed to tick off customs declarations from their list. This all changes today when the two other elements will begin to be phased in.

Proponents of these checks in the UK Government have argued they will allow important security and biosecurity gains to be made, and there is no reason why EU businesses should not have to face the same requirements that UK businesses have for the last three years. There is also the suggestion that these changes will create leverage on the EU to make them consider simplifying their own import procedures. If all goes to plan, these new checks will protect biosecurity, have minimal impact on food availability and cost, and could even provide an incentive for the UK and EU to work together to reduce red tape in the longer term.

Conversely, opponents of this piece of regulation have questioned whether the changes are really necessary – arguing that Brexit should be an opportunity to do things differently and not simply copy and paste the EU’s import rulebook. Increased costs on imports are also unlikely to be welcomed by British consumers at a time when prices are already rising. The Government has acknowledged that that the extra paperwork will lead to increased food prices (estimated at 0.2% over three years), although this is negligible compared to the shockwaves felt since Russia invaded Ukraine. One significant concern for those in the food industry is whether the EU even has the veterinary capacity to process all the necessary Export Health Certificates, which will need to be signed off individually by a certified vet in the country of origin. As current cross-continental food supply chains are often designed to deliver highly perishable foodstuffs just in time, it will be interesting to see if there will be an impact on British supermarket shelves.

Ultimately, the UK has ended up with a solution somewhere between these two positions. The full set of import controls will be introduced this year, but the UK will also be introducing facilitations into the operating model, which it would not have been able to do as a member of the EU. For example, low-risk products, such as dried foodstuffs, will be exempted from the requirements for full Export Health Certificates.

Perhaps most significantly, the UK will also be able to apply these simplifications to Rest-of-World imports, providing a boost to the UK’s trade with non-EU countries. The UK is also moving towards full digitalisation and integration of these procedures with the rollout of the Single Trade Window.

While the overall shape of the operating model is now clear, the UK Government’s priority will be to ensure the smooth flow of imports and minimal disruption to supply chains. This period therefore presents a key opportunity for industry bodies to engage with the Government and ensure that the new arrangements are bedding in as smoothly as possible to enable EU businesses to continue trading easily with the UK.