Sorry to hear all that
I do feel for you on this, you've always wanted to do what's best practice, and laboured to correct policies whilst others with more influence may have been acting in bad faith.
I suspect that what's been raised above is probably the third-party issue via Europe you that you highlighted earlier, you would have thought food prices would be going down with us eating dog food like. Personally, as a 'consumer', i'm finding it harder to get certified goods, most probably because of provenance issues.
Just a quick one. How many of these issues, in your opinion, are being created/impeded by corporate lobbying/influence ?
So, I’ll try to go into this in a bit detail this will be specifically for Products of Animal Origin. I may touch on things that don’t make much sense, so I’m to clarify any points. I have, and continue to believe, that the Europe system for SPS checks is slightly outdated and does impact smaller nations who are trying to increase exports.
The EU's system is straightforward: every product necessitates an Official Certificate signed by a veterinarian from the country of origin, alongside notification via a centralised system (Traces NT). Failure to comply results in rejection at the border. Additionally, all products, categorised by their Commodity Code, are subjected to a 20% physical inspection at the border. In cases of serious issues, this percentage may increase.
What the government has introduced is a risk-based approach, consisting of three risk levels: High, Medium, and Low. Products, based on their CN code, are categorised according to intelligence data gathered worldwide. The requirements are as follows:
- High Risk: Requires 100% physical checks, along with notification (via IPAFFS) and an official certificate submitted to the relevant Port Health Authority.
- Medium Risk: Subject to 1-30% physical checks (to be determined for each product), alongside notification and an official certificate submitted to the relevant Port Health Authority.
- Low Risk: No physical checks required, only notification. No official certificate necessary.
The kicker: importers get to choose the risk category, and the criteria for these categories are highly complex. For instance, canned fish should typically be low risk unless it poses a high histamine risk, in which case it should be categorised as medium risk - the expectation is that same admin person, who completes the notifications, is suppose to know this!!
This risk model applies to both EU and Rest of World products. What the EU deems risky might, depending on risk categorisation, enter the UK without checks.
Now, consider this from the importer's perspective: with the potential for increased physical checks and administrative burden to obtain official certificates, why would they categorise their product as medium risk? The bigger risk is food criminals who can easily smuggle illegal products into the country. Even if only 1 out of 10 consignments gets intercepted, there are still 9 products flooding the market.
Then there's the issue of charges for SPS checks. While the EU model is straightforward at €9 per tonne, the UK government has left it to local authorities to set their own charges to cover costs. This will create significant discrepancies across the country. Local authorities with low product throughput face a dilemma: either increase staff and pass on high costs to importers, allow goods to pile up at ports awaiting checks, or allow goods into the country with minimal scrutiny.
These additional costs will be passed onto the importer, who, in turn, pass them on to the customer.
This entire setup seems to prioritize business interests. One proposed solution, influenced by a major "budget" food retailer, is the "Trust a Trader" scheme. The idea is to conduct physical checks inland, possibly by the importer or business operator rather than qualified food officers. While these checks focus on compliance issues like labelling, cold chain integrity, and illegal imports, the main concern remains the origin of the product. Good compliance from an importer doesn't guarantee the integrity of their supply chain. Past scandals, such as the one involving rotten meat from Brazil used in canned products, highlight this risk.
I've probably glossed over things writing this, if these come to me I'll update as and when
So, to sum it up; its been bad, its getting worse and I still cannot foresee anything other than a serious public health incident. I just hope I’m wrong.
