WRITTEN BY Elaine Lownds of Bethan Customs Consultancy
The fact that the UK exports most of the seafood we catch, while we import most of the fish that we eat is a paradox that is not lost on the fish-processing sector in the North-east.
With intra-EU trade – fish caught and processed within Europe – making up the majority of EU exports (77%), it’s little wonder that there is a palpable sense of uncertainty in an industry which employs around 7000 people (Seafish UK, Seafood Processing Sector Labour Report 2018) across the North of Scotland.
While the next year will see a period of transition, from 1st January 2021, the fish processing sector will need to adopt and become conversant with a raft of new legislation, if they are to continue exporting to the EU.
However, as with most situations, doing your homework and being prepared will go a long way towards alleviating potential disruption to your business and/or supply chain.
Currently, UK fish processors can export their produce to the EU with minimal paperwork – a straightforward invoice is all that’s required. However, from 1st January 2021, the UK will be classed as a third country and will need to adhere to the rules applicable to non-EU states – incurring potential delays and additional costs in the process.
The first step should be to ensure you have all the relevant approvals in place in the UK and the EU. Have you registered for Fish Export Approval? Are you aware of UK Catch Certificate criteria? Are you registered to buy and sell fish by the UK competent authority?
Catch certificates must outline detailed information, such as: the value of the fish to be exported, the vessel which landed it, as well as the weight and classification of each species of fish in the consignment. Similarly, before an Export Health Certificate is awarded, the produce must be examined by a vet.
As well as making sure the paperwork boxes are ticked, businesses should also investigate whether they can still use their customary route and landing port. Post our official exit from the EU we will only be able to land at specific ports in the EU, which are authorised to allow border inspection to take place.
This will be a crucial consideration for those exporting perishable goods such as processed seafood. The need for more paperwork, combined with a greater volume of ships landing at fewer ports, could potentially lead to a perfect storm of delays in consignments clearing customs. Outstaying our welcome in these ports could also incur penalty charges.
When it comes to contracts, the devil is in the detail. Fish processors exporting to the EU should consider which commercial terms they have signed up to with their customers. Who is liable for any additional payments due to delays or more paperwork? What are the consequences of a worst-case scenario where a consignment is deemed unfit for import to the EU? It is a prudent business that carefully checks the terms of their contracts with their EU counterparts.
The waters may be choppy at the moment, but be proactive in making sure your procedures are water-tight, and there should be no reason why your business can’t continue to cast its net across the EU.