Dear Ms Gallina,
EDA and Eucolait both welcome the EU-UK Trade and Co-operation Agreement and its ratification by the
European Parliament as the start of a new phase in the relationship between the EU and the UK.
Nevertheless, the difficulties arising from certificate requirements and procedures being experienced by
EU operators since the beginning of 2021 cannot be ignored. Since 1 January, UK goods entering the EU
have been subject to full SPS checks and have required a veterinary certificate. The increased hurdles to
overcome have been cumbersome and costly enough to render certain trade unviable. Looking at Q1 2021
figures, UK dairy exports to the EU were down by 37% compared with Q1 2020 (see annex). It can be
expected that there will be a gradual rise in UK goods entering the EU in the months to come (with stocks
built up before the end of 2020 depleted) but it is virtually guaranteed that imports from the UK will not
recover to the levels they were in the past.
EU goods entering the UK will face the same barriers once the UK implements their border operating model
(requiring that EU goods be accompanied by veterinary certificates from 1 October 2021 and requiring full
checks on goods entering the UK from the EU from 1 January 2022). There are already signs of UK buyers
moving away from EU product – EU dairy exports to the UK were down 35% in Q1 2021. Moreover, the
requirement for pre-notification of products 24 hours in advance of arrival in the UK is virtually impossible,
given the proximity of the UK to major EU dairy exporters. This is a particular concern in relation to fresh
products, for example milk, cream and yogurt.
To facilitate trade in the future, an EU-UK SPS agreement (similar to that between the EU and Switzerland)
is the best solution. As of now, the SPS rules in the UK are still aligned with EU rules. This should render
full checks on UK goods entering the EU (and visa-versa) unnecessary from a food safety perspective.
Article 87 of the Trade and Co-operation Agreement provides for a ‘Trade Specialised Committee on
Sanitary and Phytosanitary Measures’ to oversee SPS related matters – any potential future changes to
either side’s SPS regime will be monitored closely. Therefore, the conditions are perfect to allow for an
SPS agreement which will enable facilitations to be rolled out.
On the basis of a shared common market history of 47 years, we ask the partners to reconsider the real
need of new health certificates in the trade between the UK and the EU. In the event that an SPS
agreement based on (dynamic) alignment or equivalence of rules cannot be achieved, we would at least
like to see full digitalization of the processes (for veterinary certificates and other required documentation)
to ensure that the process is as smooth as possible and to eliminate complications caused by the
requirement that the original physical certificate must travel with the goods.
We look forward to your response and remain at your disposal for any complementary information.
Download the full letter here.