APPENDICES TO THE MINUTES OF EVIDENCE
Memorandum submitted by the Food and Drink Federation (F2)
THE UK FOOD AND DRINK MANUFACTURING INDUSTRY
1. The food and drink manufacturing industry is one of the two largest manufacturing sectors in the UK, employing over 500,000 people. Its annual turnover is around £64.5bn. The industry purchases some £11 billion worth (about two thirds) of UK agricultural produce. Provisional figures for 2001 suggest that UK food and drink exports dropped by £0.2 billion to £8.55 billion due to the FMD epidemic. Some 39.4 per cent of total exports went to non-EU countries. In turn, UK imports of food and drinks total over £17 billion each year, of which £7 billion goes for processing or further processing.
2. FDF represents the interests of the UK food and drink manufacturing industry and addresses every aspect of food and drink manufacturing, from research to sourcing raw materials, processing, packaging, labelling and distribution. We promote the industry's views and work to improve understanding of its operational requirements at home, elsewhere in the EU and internationally.
3. FDF's formal position on import controls is attached as Annex 1. This has already been submitted to the Committee, last month, forming part of FDF's "FMD-lessons learned" memorandum.
4. In any review of import controls FDF would stress:
(a) that illegal imports must be deterred, not least to ensure the highest practical consumer protection: FDF is concerned that the current legislative and regulatory framework is complex, and that prime attention should be given to ensuring that a more coherent and more mutually informed set of powers operate at the point of entry. This must involve all relevant authorities, including HM Customs & Excise, Port Health Authorities, DEFRA and officials at Border Inspection Posts;
(b) the need for a common approach across the European Union, concentrating on the initial point of entry into the EU, in order to maintain the Single Market, whilst ensuring that such a system will be efficiently maintained as and when the EU enlarges, when the number and diversity of EU entry points will greatly increase;
(c) that whilst tightened controls that concentrate on clamping down on illicit trade are necessary, these should not unduly penalise or delay licit commercial (or personal) trade, not least to avoid deterioration/loss of perishable products or the addition of extra costs of industry: "don't throw the baby out with the bathwater".
Any revision of current import requirements must result in a practical system, with fair and simple procedures, that avoids delays to the movement of goods and minimises the cost impact on industry through quay rental and demurrage charges. The critical controls areand should remainthose at the first point of entry into the EU.
FDF believes that effective import controls should:
offer consumers the highest practicable protection from the contaminated and unsafe products entering the food chain;
protect against the re-emergence of FMD or the introduction of other critical animal diseases.
Changes to import inspection procedures could have significant implications for the food supply chain. Equal consideration needs to be given to controls on exported foods, not least as the recent FMD crisis has exposed weaknesses in those procedures.
FDF considers that where it becomes essential to contemplate more stringent import or export control measures, the following guidelines should apply:
any extra restrictions must, unless otherwise justifiable, apply throughout the EU;
controls must apply at the first point of entry into, or exit from, the EU;
the system should be easy to apply and to interpret;
consistency throughout the EU is essential. The current legislative and regulatory framework is complex and the practical difficulties arising from the provision, funding and variability of the many inspectorates increases the risk of ineffectual enforcement;
illegal imports must be vigorously deterred;
there should be increased restrictions and better controls on personal imports, even to the extent of banning personal imports of meat products;
any review or change to import procedures must focus on enforcement ie the import controls and the role and resourcing of Port Health Authorities (PHAs);
the movement of goods through ports should be as expeditious as possible to avoid deterioration/loss of perishable products and problems further down the supply chain.
15 May 2002