The looming checks on imported food that are scheduled to start at the end of the month are really focusing minds in the trade organisations that represent UK hauliers, food processors, and retailers. There is fury among them. Yesterday, the government published for the first time the Common User Charge Rates and Eligibility which will apply to all UK businesses importing consignments of goods through the Port of Dover or Eurotunnel which are eligible for sanitary and phytosanitary (SPS) checks at a government-run border control post (BCP). It is literally the price of adding friction to Britain’s food supply chains.
Why it only applies to Dover and the Channel Tunnel I have no idea. Presumably, food comes in through other ports as well, but it seems that produce there will arrive uncharged. No doubt it will all become clear later. The rates will apply whether border officials actually check goods or not.
Those in government once told us that imported food would be cheaper after Brexit, trade would continue just as before and would even increase. Now they're imposing a sort of flat tax on most things edible coming into Britain from Europe.
The charges themselves appear modest, £29 per individual commodity line with a maximum of five per consignment, meaning a maximum fee of £145 but William Bain, head of trade policy at the British Chambers of Commerce, told the FT they would be a “hammer blow” for smaller importers.
Let's be clear about it. The government has meandered into the position it finds itself by firstly shouting about "taking back control" of our borders, then signing the Johnson/Frost Trade and Cooperation Agreement. Next, as the Border Target Operating Model (BTOM) was developed it became clear SPS checks would be needed and the notion that we could rely on the EU to police our food standards was dispelled. About 75 tonnes of illegal meat has been found at Dover in the last 18 months, often in 'grim' conditions and this is without systematic checks.
The i newspaper claims officials believe it represents the 'tip of the iceberg' with much of it quietly winding up in Britain't takeaways.
So, step by step, we have reached the point where our own government is forced to impose charges to fund the Border Control Posts and the hundreds of extra staff needed to operate them.
There are some exceptions:
The complex rules say you won't need to pay the common user charge for:
- low-risk plants and plant products – if these goods are pre-notified on IPAFFS, you may still be charged
- plants and plant products checked at an inland control point instead of a government-run BCP
- plants and plant products moving from one country to another and transiting through Great Britain (this is known as ‘using Great Britain as a landbridge’) – if these goods are pre-notified on IPAFFS, you may still be charged
- goods for personal use you’re bringing on Eurostar or Dover Ferry passenger services
- Participants of the Authorised Operator Status (AOS) pilot for plants and plant products will not need to pay the common user charge provided SPS checks take place at an inland control point.
Trade bodies are up in arms. The CEO of the Cold Chain Federation Phil Pluck has said that the charges, which are in addition to other new costs such as obtaining EHCs for plant and animal products, would negatively affect food prices. He claimed it would "discourage smaller EU producers from exporting plants and animal products to the UK. Result for the UK consumer: less choice, more food inflation.”
James Barnes, Horticultural Trades Association chair, warned that SMEs that typically imported multiple commodity codes per individual consignment would be hardest hit. “In reality, businesses in our sector will be paying the £145 maximum charge,” he said.
The Association of British Ports, which represents the UK's privately owned port operators is unhappy for the opposite reason. Mark Simmons, policy manager at the BPA said: “The charge is at the lower end of our expectations, which whilst better for traders places more pressures on those ports that were forced to build new border infrastructure at significant cost.”
The sorry truth is that if you leave the single market you appear to save the money the government paid to Brussels but the money is still needed. You now have to pay to have goods checked not at the point of manufacture as they were previously by state inspectors but at the borders when they're in transit.
I wouldn't mind betting if someone were to tot up what the UK is paying both privately and publicly we are not far short (and it may even be substantially more) of what we coughed up as an EU member.
We have hundreds of thousands of extra civil servants, much bigger certification bodies, far more paperwork, and now import charges on foodstuffs plus £billions in the costs of rejoining and contributing to joint research projects under the Horizon programme.
It is crazy.
