The latest round of technical notices on a 'no-deal' Brexit issued by the UK Government portray a difficult scenario for UK animal and animal product exports.
In the event of a 'no-deal' departure, the UK would be required to apply to be listed as a third country trader before any further exports to the EU could continue.
If the UK leaves the EU in March 2019 with no deal in place, Export Health Certificates (EHCs) would be required for exports of all animal products and live animals from the UK to the EU.
Consignments would need to travel through a Border Inspection Post (BIP) within the EU. EHCs would need to be signed by an official veterinarian or authorised signatory following inspection of the consignment.
The Government is currently working on simplifying the EHC application process and ensuring that sufficient facilities are in place, should they be needed.
Requirements for trade to third countries outside the EU should not change; however, modifications would be required to the wording of the documentation - which would need to be agreed with the destination country - to reflect the fact the UK would no longer be a member of the EU.
Defra will work to agree updates for all existing EHCs.
The EU would require the UK to be a listed third country. In the unlikely event of a ‘no deal’ scenario, the UK would apply for this status but cannot be certain of the EU response or its timing.
Without listed status no exports to the EU could take place.
The Government is confident that the UK meets the animal health requirements to secure listing, as other countries such as Australia and New Zealand have done so.
The EU would also no longer recognise transport authorisations, certificates of competence, or vehicle approval certificates issued by the UK.
UK transporters wishing to transport live animals in the EU would need to appoint a representative within an EU country and apply to their relevant government department to obtain a valid Transporter Authorisation, Certificate of Competence, Vehicle Approval Certificate and, where necessary, a Journey Log.
Journey logs would need to be obtained from the EU country that is the initial point of entry into the EU for export. Exporters would need to present their transport documentation at a Border Inspection Post in the EU.
UK-issued transport documentation would remain valid for transport within the UK only.
There has been a recent call for evidence on the control of live animal exports for slaughter and to improve animal welfare during transport after the UK leaves the EU.
The Farm Animal Welfare Committee (FAWC) are undertaking this review of the welfare in transport regulatory regime, and proposals will be made in light of that FAWC report.
Norway, Iceland and Liechtenstein are party to the Agreement on the European Economic Area (EEA) and participate in other EU arrangements. As such, in many areas, these countries adopt EU rules.
Where this is the case, these technical notices may also apply to them, and EEA businesses and citizens should consider whether they need to take any steps to prepare for a ‘no deal’ scenario.