The UK Department for Environment, Food & Rural Affairs (Defra) has proposed regulatory changes that would reclassify half of all fresh produce imports from the European Union to Great Britain as medium- or high-risk.

The proposed changes pertain to Annex 11 of the retained Implementing Regulation 2019/2072. The proposal prompted a response from the European Fresh Produce Association (Freshfel) on behalf of the European fresh produce sector. Working in  collaboration with the UK Fresh Produce Centre, Freshfel said that if adopted, the update would impose checks and other unnecessary controls on fresh fruit and vegetable exports. 

The proposed changes would reclassify certain products, like tomatoes, peppers, apples, pears, grapes, or strawberries, as medium-risk. This would result in heightened controls and additional red tape. Other products, like lettuces, plums, and other stone fruits, would also be subject to additional regulation under a lower-risk designation.

In its response to Defra, Freshfel raised concerns that the proposed changes could significantly jeopardize the competitiveness of EU exports of fresh fruit and vegetables, increasing costs by up to £200 million (€235 million) due to additional administrative burdens and logistics rerouting to border control posts. Other cost concerns relate to documentary and physical checks, potential delays upon arrival due to inspection wait times, and various collateral aspects. 

These additional costs will render the British market less attractive for EU exporters, Freshfel said, endangering food security, fluidity of supply, and affordability of fresh produce in the UK. There is also concern about maintaining the freshness of fruits and vegetables, which are often shipped with just-in-time delivery in less than 24 hours. 

Significant trade partners

This issue is crucial for the UK, as it sources 38% of its vegetables and 34% of its fruit from the EU. This will lead to higher food prices in Great Britain, Freshfel warned, reducing consumers’ ability to access affordable healthy food. 

Freshfel Europe’s trade policy advisor, David Fernández stated: “A dangerous by-product of the proposed changes is that food waste is likely to increase, whether because of delays before departure or upon arrival in GB or a combination of both.” 

Moreover, Freshfel said it finds the proposed changes unnecessary and an unjustified obstacle to trade. The organization said there have been no noteworthy biosecurity or other food safety incidents or interceptions in the EU-GB fresh produce trade over the last half a century.

Phillipe Binard, Freshfel Europe’s General Delegate said, “The proposed changes challenge the stability of current solid business relations between EU suppliers and their British business partners. Previous examples of shortages in British supermarket shelves have already made clear the fragility of supply chains.”

For that reason, Freshfel has called on British authorities to rethink their approach and recommends finding an agreement with the EU on SPS matters to ensure seamless trade. Absent that, Freshfel calls on Defra to ensure transparent, clear, and flexible rules with the least possible impact on trade in light of the long history of fresh produce trade between the EU and the UK.