APPENDIX 9
Memorandum submitted by the Chairman of the UK Association of Frozen Food Producers (F16)
As Austin Mitchell has pointed out, we do have problems with UK Port Health Authorities which we have raised with the Food Standards Agency, the Better Regulation Task Force and elsewhere. Our main criticism is that of "Gold Plating" by some UK PHA's of EC regulations.
These regulations are made for the purposes of the hygienic protection of imports to EC standards and we have no quarrel with the hygiene requirements as such. Our complaint is in respect of the over-zealous and, in our view, incorrect enforcement of some of the administrative requirements. We also have serious problems with delays at UK ports, which can routinely be of 2/3 weeks. Moreover, there are no cold storage facilities within the jurisdiction of UK BIP's/PHA's and food is obliged to remain in refrigerated containers on the dockside at a cost of between £50 and £80 per day whilst hygiene tests and administrative procedures are carried out. PHA's have so far refused to allow transfer arrangements to bonded or other controlled cold stores outside the BIP area.
At the DEFRA Forum on illegal imports on 21 March, the point was made by the PHA representative that Rotterdam was becoming known as the principal port of entry into the United Kingdom. I expressed my lack of surprise at this discovery as, in the case of fish (of which 80 per cent of UK consumption is imported) imports via Continental ports have risen from about 5 per cent to over 50 per cent during the past few years. The point I wished to make was that, with far better facilities, including on-site cold storage and smoother administrative systems, the costs of importing fish via Continental ports is now about 50 per cent of that of UK ports. I ventured that the provision of better facilities at UK ports might improve their ability to handle all food products and that perhaps a more efficient operation might help the objective of detection of genuine fraud.
Attached is a copy of a briefing note (not printed) on problems encountered by our members with UK PHA's prepared for a meeting with the Fisheries Minister last August. Our files contain detailed examples of these and other problems. The point is that all of these could be deemed to be cases of attempted illegal imports. We challenge this judgment on both technical grounds (ie that they did not constitute breach of the EC Directives or the implementing UK laws) and, importantly, on the grounds that safety was not compromised.
27 June 2002
| 
