Stuck in the slow lane

A pilot scheme suggests that digitising export paperwork could save producers time and money.

Since the end of the Brexit transition period, increased bureaucracy has added an extra £3m each year to the cost of exporting salmon to the European Union.

So says Tavish Scott, Chief Executive of Salmon Scotland, who says progress towards developing a long-promised digital Export Health Certificate (EHC) system needs to be speeded up.

The new system for EHCs is due to replace the costly paper process companies are currently having to endure, but there is, as yet, no date for its implementation.

Scott said trials of a new online system – with consignments of salmon being sent to the EU using digital certificates – have shown already what can be achieved in terms of efficiency and reduced costs.

The farmer taking part in the pilot study was Cooke Aquaculture Scotland, one of the leading producers of Scottish salmon, and the largest supplier of organic Scottish salmon. It exports to more than 16 countries worldwide and more than half of the salmon it produces is destined to European markets via Boulogne-sur-Mer in France.

Cooke’s Supply Chain Manager, Gillian Devine, says: “Compared to the pre-Brexit trading arrangements, there’s no question that we are experiencing tariff and non-tariff barriers in our trade with Europe.

“Trucks are leaving distribution hubs in central Scotland later due to the number of checks and paperwork that are required to complete the EHC and Ched-P [the Common Health Entry Document for consignments of products of animal origin] paper documents required for all EU countries, which is why a digital EHC is so important.

“Operation Brock (the UK Government’s traffic management plan) is in place at the moment, which is causing huge tailbacks on the main roads to Folkestone and Dover. We believe this is due to high demand, the current cancellation of P&O crossings, and Covid, all coinciding with the Easter holidays.

“The reality of Brock is that many drivers are running out of driving time and they then have to be rescued. This creates enormous stress: for us as the supplier; for the customer as they have no idea if and when they will receive their goods; and for the driver who is then stranded with perishable goods in their load.”

Devine adds that there are now onerous physical checks at SIVEP, France’s veterinary and phytosanitary border inspection office, that can take a long time.

She says: “The changes introduced in January 2021 were a huge shock to the system in the UK and Europe, where perishable goods went from being ‘day one for day two’ before Brexit to ‘day one for day four to five’ in the early days.

“Now that things have settled down they typically track around ‘day one for day two’ albeit much later in the day, but in recent weeks ‘day one for day three’ is normal. The value and volume of salmon exports from Scotland to the EU have held up, but we’ve undoubtedly lost orders to competitors from other countries as a result of the increased hassle of importing from Scotland.

“The situation has improved over time as processes became embedded and companies got to grips with the new requirements, but it still takes more time and costs more money to export to the EU than it did before Brexit.

“We don’t have as much confidence as we’d like about when our product will arrive in Boulogne-sur-Mer or with our customer, and this experience changes on an almost daily basis.”

How, we asked, could these challenges be overcome?

“Good lines of communication between producers, customers, transporters, DEFRA and other agencies governing the supply of fresh fish into Europe,” Devine explains.

“Digitising the export process is something that could, and should, have happened before now, and before Brexit. If there is one benefit of Brexit, it will be that all these challenges have created a solution that works on both sides of the channel.”

The UK Government has also agreed a plan to fast-track between 70 and 100 truckloads of perishable foods a day, with priority for live and fresh seafood and day-old chickens. This, says Devine, has never been implemented.

She adds: “Saving an hour or two on paperwork in Larkhall or Bellshill is for nothing if our trucks are only going to be held in a Kentish layby for 12 hours or longer.

“We need digital EHCs to be recognised and rolled out on both sides of the channel as quickly as possible, and we need the UK Government to get to grips with the freight transportation issues that continue to dog our side of the channel.”

Devine describes the pilot study of a digital EHC system, which Cooke operated in collaboration with logistic business O’Toole Transport, as “very encouraging”.

As she explains: “The same information is required but it is much more intuitive, better organised and more user-friendly on the digital system – instead of up to 30 stamps on a paper copy, making sure to use the right colour of ink, it creates one digital signature saving so much time and removing the room for error.

“The transporter processes the documents for Food Standards Scotland’s environmental health officers, which can be uploaded onto the EU’s Traces system and produce the CHED-P (Common Health Entry Document) using a unique reference code produced by the digital EHC.

“This also saves time and duplication of effort as this will populate information from the EHC into the Ched which will match-up the documents in Traces. This will be much more helpful to the Douane manning the EU customs border and the SIVEP officials to find and process the export documents on their own system.

“We believe the pilot has been an unqualified success for all parties. [It is] subject to agreement between DEFRA, the French Government and the EU, but I believe this will help UK and EU to have a more sustainable process for the future.”

Seafood Scotland’s Chief Executive Donna Fordyce agrees: “It seems to have been successful in that the digital approach resulted in significant time savings, primarily at the distribution hub in Scotland but also at the hub at Boulogne-sur-Mer in France. We have heard that vets certifying the salmon in Scotland found the digital system much easier to use and quicker to complete.

“Another encouraging outcome was that when the salmon arrived at the Border Control Post in Boulogne, the digital ‘paperwork’ was already in the system for the vets there to refer to, aiding the speed of clearance for onward dispersal of seafood products. This outcome should help with the roll out of the digital approach for non-groupage exports, which in practical terms means salmon.

“A further pilot is now being planned for export products that are normally exported under the groupage scheme. That will be a bit more complicated of course – requiring potentially two EHCs, one for fish, and another for shellfish – but we are optimistic that the groundwork has been laid to move forward.”

Fordyce says that in the long run, what is needed is a pan EU-UK agreement of equivalence of Sanitary and Phytosanitary Standards (SPS), which would negate the needs for any checks at all. Scottish food and drink producers, including Seafood Scotland, are pushing for this as an industry.

She argues: “Failing that, the next best situation is one where you can maximise the permitted time for each part of the supply chain, while reducing errors at each stage. This twin approach would take care of most of the issues that come up. Further simplification of the customs process would also help, e.g., doing away with import VAT.

“We are aware that commercial technology suppliers are looking at whether a truly end to end digitised system is possible – which would be ideal, but the industry has a way to go in terms of understanding how the chain fits together, and where individual responsibilities lie.

“Certainly, the EU is geared to accepted digital information and legally they are allowed to do so, but it would need agreement between the EU and British Government.”

Fordyce concludes: “Brexit can be characterised as ‘pain by a thousand cuts’ because of the creeping changes which have continued to appear. Just when you think you have everything sorted, along comes another bit of legislation which changes things again.”

Beatrice Wishart, MSP for Shetland, on a visit to Cooke Aquaculture (July 2021)