On 8 March 2024, Freshfel Europe submitted its response to the consultation launched by Defra on the proposed changes to Annex 11 of the retained Implementing Regulation 2019/2072 which, if adopted, will impose checks and other unnecessary controls on half of all EU fresh fruit and vegetable exports to the Great Britain.

Freshfel Europe, on behalf of the European fresh produce sector, and working in close collaboration with the UK Fresh Produce Centre, submitted the response of the sector to the proposed changes by Defra to Annex 11 of Implementing Regulation 2019/2072 which would reclassify half of all EU exports to Great Britain as medium- or high-risk.

Under Defra’s proposed changes, common exports like tomatoes, peppers, apples, pears, grapes, or strawberries, all in all totalling 1 million tonnes worth of exports in 2022, would be recategorized as medium-risk and subjected to heightened controls and additional red tape. Similarly, an additional 250.000 tonnes of lower risk control including lettuces, plums, and other stone fruits would also be subjected to new red tape.

In its response to Defra, Freshfel raised concerns that the proposed changes can significantly jeopardise the competitiveness of EU exports of fresh fruit and vegetables, increasing by up to 200 million pounds (€ 235 million), due to the direct and indirect costs relating to administrative burden, logistics rerouting to border control posts, documentary and physical checks costs, potential delays upon arrival due to inspection wait times, as well as various collateral aspects.

These additional costs will render the British market less attractive for EU exporters, endangering food security, fluidity of supply and affordability of fresh produce in the UK, particularly the freshness of fruits and vegetables, which are often shipped with just in time delivery in less than 24 hours. This 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, 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 finds the proposed changes unnecessary. Over the last half a century of EU membership, and still since the British departure from the EU, there have been no noteworthy biosecurity or other food safety incidents or interceptions in EU-GB fresh produce trade, making these rules an unjustified obstacle to trade. Freshfel Europe’s General Delegate, Philippe Binard confirmed “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 those reasons, Freshfel calls 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 non-problematic fresh produce trade between the EU and the UK and to prevent a repetition of past instances of empty supermarket shelves in Great Britain, as witnessed already in early 2023.








Note to the Editors: Freshfel Europe is the European Fresh Produce Association, representing the interests of the fresh fruit and vegetables supply chain in Europe and beyond. Freshfel Europe currently has over 200 members, including both companies and associations. For more information, please contact Joanna Nathanson at j.nathanson@freshfel.org.

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