Memorandum submitted by H M Customs and Excise (F6)
Customs is keen to make best use of our expertise and knowledge in support of the DEFRA led Illegal Imports Programme.
We consider the Risk Assessment being carried out by the Veterinary Laboratories Agency (VLA) is fundamental to the development of future policy.
We agree that the immediate way ahead is to strive to achieve better inter-agency working and information sharing.
1. Customs plays an important role in supporting DEFRA, Devolved Administrations, Port Health and Local Authorities who are the lead agencies for the enforcement of controls designed to protect the UK from animal and human health diseases. Customs role and responsibilities are summarised below.
INTRA EU MOVEMENTS
2. Since 1 January 1992 (completion of the Single Market) Customs has had no role in enforcing controls to protect animal or human health on intra EU movement of agricultural products. There is no general requirement for intra EU movement of goods to be declared to Customs, thus we do not routinely have information to reliably and comprehensibly identify meat movements. In addition, any checks made by Customs need to be proportionate to the risk being addressed. Given the EU regimes established to control intra EU movements through checks at traders' premises by veterinary and health officials, any routine regulatory border control regime would appear difficult to justify.
THIRD COUNTRY CARGO IMPORTS
3. Commercial imports of livestock and animal products are only permitted to enter the UK (and other EU countries) through approved Border Inspection Posts (BIPs). These posts are operated in the UK by, or on behalf of, DEFRA and the Devolved Administrations. They undertake physical and documentary checks. Customs supports the operation of the BIPs by arrangements to ensure that goods that are declared as being of a description requiring BIP checks are not released until the appropriate authorities have completed their action. This is done by use of profiles on the Customs computerised import entry processing system that identify to Customs goods subject to BIP checks.
4. In addition Customs co-operate with the agencies which operate the DEFRA controls in identification of suspect consignments. For example we can through use of our computerised system identify suspicious imports to a particular importer from a specified country.
5. Customs examine import cargo to ensure compliance with a range of requirements. Should such examination identify meat or meat products which have not properly been declared as being of a description subject to control, these imports would be drawn to the attention of the appropriate DEFRA agency.
THIRD COUNTRY PERSONAL IMPORTS AND IMPORTS THROUGH THE POST
6. Personal imports of meat and meat products from countries outside the EU are prohibited, except for an allowance of 1Kg of fully cooked meat in hermetically sealed containers. If during the examination of passengers' baggage or postal packets Customs identify illegal imports of meat or meat products the product is either seized or, where DEFRA agencies are present, referred to them for action.
7. Customs also co-operate with the DEFRA lead agencies in joint exercises to address the threat posed by illegal meat imports, particularly so called "bushmeat" imports originating mainly from certain parts of West Africa.
8. Customs has a separate interest in bushmeat imports. Such imports may include endangered species subject to control under the Convention for International Trade in Endangered Species (CITES). Customs is the enforcement authority for CITES import controls.
Customs Support for Illegal Imports Programme
9. Customs is represented on the Steering Group for the Risk Assessment being carried out by the Veterinary Laboratories Agency (VLA) and is actively participating with DEFRA on work to support completion of the project (eg assistance in special exercises for risk testing). Customs consider that this Risk Assessment is fundamental to the development of future policy. It will be instrumental to understanding the nature of the risk and identifying where and how a virus might enter the country and spread. In turn this would lead to an informed assessment of the resource required for a control programme targeted according to risk (including any risks inherent in legitimate consignments). However, given the importance of international trade to the UK economy, it is not feasible to establish a level of import control that would eliminate the risk of illicit meat importation. Customs therefore considers that reducing the risk through improved import controls can form only one element of an overall strategy to combat the introduction and spread of animal diseases. Activity on import traffic should be focused on those aspects of illicit meat import activity assessed as presenting high risk to animal health if it is to make a worthwhile contribution to reducing the risk
10. Customs, together with other relevant Government Agencies and Departments, was represented at the Industry Forum on 21 March. Although these agencies gave an account of their respective responsibilities for preventing and detecting illegal consignments of products of animal origin, subsequent discussions revealed that the other interested stakeholders present at the Forum perceived a plethora of control points and agencies which was hard to understand, inefficient, poorly co-ordinated and getting in the way of sharper delivery. Customs fully supports views expressed at the Forum that the immediate way ahead is to strive to achieve better inter-agency working and information sharing. We are assisting DEFRA in their immediate response to produce a Guide to the roles, responsibilities and powers of the relevant agencies and will continue to work with them in developing improved co-ordination of enforcement activity. In particular we can assist with intelligence sharing, publicity and experience of the application of enforcement tools.
11. From the description of the Customs role it will be evident that we are not the lead authority for import controls of meat and other animal products. We are however committed to making best use of our expertise and knowledge to assist in the taking forward of the DEFRA led Illegal Imports Programme. A specific example is our agreement to test how effective our x-ray technology is in identifying illicit meat imports. In addition the Government has agreed to provide funding for 36 staff this year for enhanced Customs frontier activity at ports and airports. This is to be used to provide a flexible resource to address illicit drug traffic and provide some additional capability to support DEFRA led joint exercises particularly at airports.
12. Finally we note from your invitation to submit evidence that you intend to make use of examples of policies and practices adopted by other countries in your assessment of the Action Plan. Customs is aware that different arrangements are in place in other countries and fully supports your view of the need to take account of and learn from experiences elsewhere. It will however be necessary to consider these in the light of the very different circumstances which can apply, for example the nature and volume of trade and the UK's position as a member of the EU.