On page 34 there is an astonishing comparison between the steps needed to ship food products to the EU before 1 January and afterwards. Up to the end of the transition period there was just a single step:
The haulier loads the goods onto a truck along with a consignment note (CMR).
Afterwards there is a 20 stage process piled high with acronyms, involving Common Health Entry Documents (CHEDs), Export Health Certificates (EHCs), certifying officers, the EU’s Trade Control and Export System (TRACES-NT), the Common Transit Convention (CTC) and goodness knows what else. Steps 10 to 13 are these:
10) The haulier pre-lodges a combined export, and safety and security declaration (EXS) on HM Revenue and Customs’ CHIEF (Customs Handling of Import and Export Freight) system, so generating an Export Accompanying Document (EAD). They also submit a transit declaration into the New Computerised Transit System (NCTS) and generate the Local Reference Number (LRN).
11) NCTS validates and sets the Transit Accompanying Document (TAD) and the transit movement can start. The Movement Reference Number (MRN) is produced and the paper TAD and MRN is given to the haulier.
12) The haulier holds an EU EORI number and has also made the Entry Summary Declaration (ENS) entry into e.g. the French Import Control System (within two hours of the arrival of the ferry).
13) The haulier receives a Permission to Progress (P2P) departure message from CHIEF, telling him that the export has been discharged.
The process, with so many steps and different actions by many different people in different places is prone to mistakes and therefore the risk of delays and even rejection of the load will always be much higher.
The 'teething problems' are simply getting everybody to understand and follow what is now required but afterwards all the extra work will be a permanent drag on both the time and cost and also a constant incentive on the part of the customer to source products from places where they can go back to how smooth and frictionless it was last year. Some, and perhaps a lot, will do so.
But then I see another article in the same journal, this time from NFU Scotland president Martin Kennedy which is titled: Door remains firmly closed to Brexit compromise.
I have no evidence which way Mr Kennedy voted in the referendum, but I suspect he was a leaver from an article he wrote last December when he was musing on how the EU should have made concessions to David Cameron and "decided that it is in everyone’s interest that the UK should remain part of the family but deemed it only fair they have more control over their own regulations and laws etc."
And:
"having to accept rules and draconian penalty matrixes that simply do not fit our farming and crofting systems here in Scotland and indeed many other parts of the U.K. is ludicrous, hence the reason there are advantages in not being part of the EU."
That was last year.
Now in his latest piece, he explains that UK farmers have kept a place at the Copa-Cogeca table, and we still have the opportunity to use the platform to feed in concerns on many topical issues facing agriculture right across Europe (Copa is the body that represents all the European farming unions and Cogeca is the body that represents European farming cooperatives).
At a recent meeting he says it was "blatantly obvious, given the response from the Commission to questions, was Brexit was a UK decision therefore the UK will have to face the consequences for any friction in trade or checks."
Mr Kennedy seems surprised that having left the EU and the CAP, Scottish farmers have no influence over the CAP and the EU. How was that possible?
"The tone of the conversation," he says, "was incredible, despite calls for discussion and dialogue to try and resolve some of the serious issues we are facing right now. That included attempts to discuss economically important trade matters for Scotland such as seed potato exports and live animal trade between ourselves and Northern Ireland. In short, the door was firmly closed in our face."
He is upset and disappointed, not so much with the lies and the liars who persuaded so many farmers to vote to leave the EU, but with the EU for not allowing us to have our cake and eat it. And he is totally confused with the TCA when he claims:
"However, the trade and cooperation agreement that’s in place already allows trade to happen provided there isn’t a significant change in production standards, i.e., equivalence is recognised, but again it’s politics that’s stopping this trade from continuing."
There is no "equivalence" in SPS and there never will be. He is asking for 27 member states to accept UK food standards of the future and this is not going to happen. It is blindingly obvious that the answer to all the bureaucracy and Mr Kennedy's problems is that we must align with the EU27 because they will never align with us.
Does he expect the USA to accept UK food standards? Of course not. This is not how matters of trade work. The bigger party always holds sway. It is why we joined the EU in the first place. Despair.
