A ‘no deal’ Brexit would be an unacceptable and damaging outcome for British farmers, food businesses, consumers and the environment. Yet the understanding of how our food system works is dismayingly low among senior decision-makers. How can good food sense prevail? asks Kath Dalmeny, Brexit lead for Sustain, the alliance for better food and farming.
From all that Sustain has read, heard and discussed over recent months – with our sector and the food, farming, fisheries, transport industries, food standards inspectors and local authorities – the disruption caused by a Brexit without the UK agreeing a sensible trade deal with the European Union would be seriously damaging and potentially push a lot of our fellow citizens into more and worse food insecurity. This is concerning for both our country’s short-term and long-term food resilience.
The Government's 'no deal' technical papers (published 23rd August) do little to lessen such concerns. They cover technical and bureaucratic issues of labelling, certification, permissions and business registration. They do not talk about loss of a £13 billion EU export market for British food; talk little about the impact of high tariffs that would be levied on food and farming imports and exports; nor about labour shortages; nor about the jobs and businesses already being lost.
25 Brexit 'no deal' technical papers are being published today (23rd August) by the Government (55 more to follow in the next few weeks). Among the first are several dealing with farming-related issues:
* Trading with the EU if there's no Brexit deal
* Producing and processing organic food if there's no Brexit deal
* Developing Genetically Modified Organisms (GMOs) if there's no Brexit deal
* Receiving rural development funding if there's no Brexit deal
* Farm payments if there's no Brexit deal
Read Sustain's summary response here.
The UK gets about a third of our food (30 per cent) from other European countries and a further 11 per cent via deals done by the EU with other countries. Food bought from outside the EU is increasing, but remains at small amounts in comparison. The European Union is a critically important market for the thousands of farmers and food businesses in the UK who employ 3.9 million people, export £13 billion of food products to European countries, and import essential farm inputs and food ingredients that cannot be rapidly or easily substituted either by home-grown replacements or via new trade deals. It’s complicated. Don’t believe anyone who says substitution would be simple or quick.
A ‘no deal’ Brexit that means British farmers and fishers will have to compete with cheap imports could result in deregulation that weakens environmental, safety and animal welfare standards. British producers would need to find ways to stay competitive with overseas producers who may not be subject to such strict environmental, welfare and safety regulations. Existing regulatory standards would come under downward pressure as farmers have to look for immediate cost-saving opportunities.
Yes, we can and should all buy more British and sustainably grown food – this has always been a worthy ambition. However, this is not an adequate response in itself to a ‘no deal’ Brexit. More local food and the infrastructure to process and distribute it need investment and both take a long time to grow. In any case, there is frankly scant government commitment or funds to rebuild local food infrastructure, and little indication that Government will seek to invest in diverse farms post-Brexit that would meet our local food needs. A good food plan for the country would prioritise regeneration of British farming, local food infrastructure and a supply chain that rewards farmers fairly for their efforts in farming sustainably and safely, as a natural and essential complement to our continuing need to trade internationally in food. Are any of these in Defra’s policy plans? We have seen little evidence to suggest so.
Standards, inspections and agencies matter
When we trade in food there must be robust standards, and the trading arrangements must be as smooth as possible. A ‘no deal’ Brexit puts this in jeopardy, at likely very large cost. Food is perishable, requires reliably safe handling and full traceability at all stages, and is prone to substitution, contamination and fraud – sometimes with serious consequences for human, environmental and animal health. Food and environmental standards, scientific assessments and inspections matter because (put very simply) we eat the products, need clean air and water, and depend on soil and pollinators to produce our food. People’s safety, food quality, accessibility, reliability, prices and choices are directly affected by the decisions made all along the food supply chain. As are ethical considerations, such as supply chain fairness, working conditions and animal welfare. One of the most concerning backdrops to a ‘no deal’ Brexit is that it would confirm loss of cooperation between UK and EU agencies that oversee our food and environmental standards. It will also cost a lot of money to replicate their functions in the UK. The Greener UK alliance describes a “yawning governance gap” in the event of a ‘no deal’ Brexit.
The food industry – farmers, supermarkets, manufacturers and foodservice – have frequently expressed dismay over recent months about how little the British Government and top decision-makers understand about how our food system works. The dismay relates mainly to access to workers, and most recently the consequences of ‘no deal’ - the loss of smooth trading with our nearest and very largest trading partner, the European Union. The biggest UK food trade bodies say they have not been consulted about what could happen with ‘no deal’. The British Retail Consortium said, “Failure to reach a Brexit deal – the cliff edge scenario – will mean new border controls and multiple ‘non-tariff barriers’ through regulatory checks, creating delays, waste and failed deliveries. This could lead to dramatic consequences, with food rotting at ports, reducing choice and quality for UK consumers. It could also lead to higher prices as the cost of importing goods from the EU increases.” Meanwhile, National Farmers Union representatives from England, Wales, Scotland and Northern Ireland together warned that a ‘no deal’ Brexit would be “potentially devastating” to the UK’s livestock sectors.
Most food and farming trade bodies also vociferously say they want to stay closely aligned with EU systems such as the European Food Safety Authority and REACH chemical regulations. It makes good economic sense to do so. No food or farming business dealing with imports and exports wants to have the expense of proving compliance with the multiple or divergent standards that a ‘no deal’ Brexit is likely to mean, nor to be excluded from a trading bloc as large as the European Union.
Union and business leaders of the Trades Union Congress, the Confederation of British Industry, the European TUC and Business Europe (the European CBI) (together representing 45 million workers and 20 million employers) jointly called for ‘regulatory alignment’ – maintaining frictionless trade, and avoiding a hard border in Northern Ireland – together backing “a mutually acceptable level playing field for workers’ rights”.
'No deal' Brexit means shortages in people, jobs and transport
Many of the supposed ‘border solutions’ necessitated by a 'no deal' Brexit, and being put forward by politicians, feel like they have little grounding in reality. Our food supplies are highly reliant on the smooth and reliable flow of vehicles transporting ingredients and finished products – often passing many times over country borders – including a significant amount, worth billions, across the Irish border. Much of this food supply is now managed – for good and ill – on a ‘just in time’ basis, with slim-to-vanishing capacity for delays, disruption, stockpiling or crisis management. This is a system little suited to disruption of the scale likely to be associated with a ‘no deal’ Brexit.
The Freight Transport Association recently issued a scorching press statement laying out the challenges to the 300,000 truck journeys needed to keep UK-EU trade on the road, arising from lack of clarity and the “reckless attitude” of “some members of the Government”. Small surprise that the Government was earlier reported as planning to call in the army, but even the valiant British Army would not be able to grow, buy or transport large amounts of food at short notice. Food hauliers have expressed dismay at how little grasp the Secretary of State for Transport Chris Grayling has of the consequences of a ‘no deal’ Brexit for the smooth flow of British trucks carrying over one third of our food as imports from or via the EU, and over £13 billion of food exports destined for EU countries. Border checks, delays, tariffs and expensive paperwork are the everyday realities of ‘no deal’ Brexit.
The Government says they will issue 80 or so notices of preparedness, and have started with the first 25 this week (23rd August, and mirroring the 70 or so issued by the European Commission to inform businesses in other EU countries), signalling that at least 20 will be relevant to UK food and farming. In the event of a ‘no deal’ Brexit and possibly rapid introduction of new arrangements, the food industry has said that there is little physical capacity to stockpile or deliver large amounts of food under new or chaotic arrangements, especially at short notice. The technical notices advise pharmacies to plan for stockpiling six weeks worth of medicinal supplies. Should food businesses do so too? The government has not yet advised. A recent report from the Food Research Collaboration called Feeding Britain: Food Security after Brexit suggests that the Government’s contingency plan is to throw open the borders for emergency food supplies, throwing the usual checks and traceability into question.
Some food processing businesses – notably in the fish and horticulture sectors – are already choosing to shift their operations to other EU countries, or even further afield. Whereas a growing or processing site in the UK was previously attractive, the prospect of extra paperwork and paying very high tariffs to export fish products or berries from the UK to the EU is not. A large amount of the UK’s fish catch is exported – we don’t have the taste for many species caught here – and an expensive tariff arrangement from a ‘no deal’ Brexit could see a massive hike in costs pretty much overnight, especially for processed and smoked fish products.
Just as one example, over a third of all the langoustines caught in the UK are exported quickly to Europe – either alive or killed but transported fresh. The main countries that we export to are France (66%), Spain (20%), Italy (7%) and Ireland (5%). Langoustines command a better price the fresher they are, with live prawns the most valuable per kilogram. At just over £170 million, the economic value of nephrops (scampi) is small, but nephrops – usually transported live – are the second highest value fish species in Scotland and the UK and the lifeblood of some coastal communities. Delays in transport would clearly be a huge risk for food products that rely on rapid transport and no delays at borders. Such are the realities of ‘just in time’ supply chains.
Meanwhile, horticultural production is highly dependent on seasonal labour, which is likely to be in short supply – whether a deal is reached or not. Some businesses are not prepared to weather such risks and are already moving their growing operations or processing factories overseas – and the jobs with them.
It has often been pointed out, but it must be said again. Our food system is currently reliant on migrant workers – all along the supply chain, from strawberry pickers, truck drivers, meat and fish processors and pie makers, right through to the chefs and waiters in the restaurant and hospitality trade. These industries have been crying out for the past two years for a sensible approach to finding workers – already warning of shortages pre-Referendum, and finding recruitment challenges only exacerbated by Brexit. Migration – particularly of the so-called ‘unskilled’ workers (a sad misnomer) who grow, make, transport, cook and serve our food – has become such a toxic political subject that Government decisions or inaction – as well as the notorious ‘hostile environment’ – have already pretty much guaranteed shortages of people. A ‘no deal’ will potentially make access to the semi-skilled and skilled workers we need across supply chains even harder.
Will 'no deal' Brexit result in food shortages?
This summer has seen worrying headlines about food shortages and stockpiling – driven no doubt partly by alarmist politicking, but also partly by genuine concerns about how food deliveries can be arranged in the event of ‘no deal’. Should households and food businesses plan to stockpile six weeks' worth of food, as government has now advised pharmacies to do with medical supplies? Do we face actual food shortages? Do we face a big hike in food prices? It is very hard to tell, and Sustain does not want to add unnecessary fuel to the fire of such speculation. We are acutely aware that over 8 million of our fellow citizens already live in food insecurity – around half of them children – who are ill-equipped to deal with food shortages or even a short-term disruption in food supply, nor the anxiety that alarming headlines may induce.
What we do know is that in the event of a ‘no deal’ Brexit, there needs to be a sensible plan, led by government, fully involving the food and farming industries, and taking into account the realities of 'just in time' and perishable food supplies. If there is any food disruption or shortages, then the plan must set out clearly how the needs of vulnerable people such as children and the elderly will be met – fully and fairly. It will also need to ring-fence resources to help local authorities to help local people through a hopefully temporary crisis, just as many already try to do for the millions of people who already falling through the welfare safety net. This all sounds plausible and doable, we’re a plucky and stalwart nation – we step up to challenges, don’t we? Let us hope so, but let us not forget that we enter Brexit with many people and local authorities still in the throes of austerity. Nor let us forget the shameful way in which so many of our current leaders have refused to acknowledge or even measure the dramatic rise in household food insecurity that already casts an unpleasant shadow of modern-day hunger across our country and resulted in over a million visits to emergency food banks over the past year.
Working together for a Better Food Britain
As a diverse alliance, Sustain has stayed neutral on Brexit itself. We have worked hard across a broad alliance and the political spectrum to focus on the priorities for our country’s food, farming and fishing in all political scenarios. However, we see no sign of a sensible plan for British food, farming and fishing in the event of a ‘no deal’ Brexit. We hear political opinions expressed with little basis in reality. We see enough evidence to stir many deep-seated concerns and a frankly dismaying lack of understanding among senior decision-makers about how our food system works. We see little commitment by Government to listening to legitimate health, environmental and social concerns relating to new trade deals. We were already witnessing growing household food insecurity and small farms going out of business before the EU Referendum – these trends look set to get worse, not better. We are therefore convinced that our alliance must speak out against a ‘no deal’ Brexit. Please consider joining us in doing so, in whatever way you can.
If you represent a Sustain alliance member organisation and have any comments on this article, or our approach, do let us know.
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Published 20 Aug 2018
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Kath is Chief Executive of Sustain: The alliance for better food and farming, since 2016 leading the alliance's response to Brexit and its profound implications for healthy and sustainable food, farming and fishing and developing the Campaign for a Better Food Britain. During the Covid-19 coronavirus pandemic in 2020, Kath has been the alliance lead on Food and Vulnerability, serving on numerous liaison and coordination groups to support the emergency food response at local and national level. She was instrumental with the Good Law Project and Doughty Street Chambers in launching a judicial review of the government's approach to children's holiday hunger during Covid-19.
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