LEAVING the EU with NO-DEAL
1 The inevitability of delays at borders is accepted. Under EU regulations for CITES A,B,C and D species all will require Import and Export Cites and 30 days quarantine. All imports will have to be via an approved BIP, with Dover and Eurotunnel not designated for personal/hobbyist imports. All permits will have to be stamped by customs in the exporting countries with the potential for administrative delays and will probably need clearance by an agent.
2 CITES species will require import and export permits – this seems to scupper the pet passport proposal. DEFRA hope that CITES permits will be issued within 15 days of application – however the regulations allow up to 30 days for processing. DEFRA continue to look into the pet passport possibility but this is complicated by the need to comply with EU regulations on CITES – A B C and D are EU regs, whilst CITES only has 1, 2 and 3. It seems highly likely that all raptors will be caught by EU rules.
3 The requirement will be for all crossings into the UK to be from recognised EU border inspection ports. These are limited in number. The welfare of raptors in transit for extended periods was raised but the availability of CITES/animal trained Border Control staff overruled the automatic use of the shortest routes. Numerous arguments presented about welfare risks inherent in long delays may persuade a rethink.
4 This meeting was fundamentally about CITES, however importing issues for animal by products (Raptor food) was raised – only the Border Force representatives had any idea of likely problems. The longest delays may come getting animal by products into the UK (rather than out of the EU). The Border Force thought every vehicle would require a separate customs declaration and inspection with associated delays and costs.
5 There were limited assurances that Government departments have contingencies for the increased work-load inherent in a No-Deal BREXIT. These assurances all come with caveats however, such as ‘Due to the increase in the volume of border checks we propose to designate a greater number of ports of entry and exit – subject to adequate infrastructure, facilities and the availability of Border Force personnel trained in CITES’. There are budgets for limited increases in staff but little has been allocated for physical infrastructure.
The DEFRA Engagement Session left the impression that little preparatory work has been undertaken by Government departments, to understand and mitigate the No-Deal situation. Were the UK to exit the EU in these circumstances we will face a prolonged period of restriction and uncertainty – I make no political assertion here, merely as assessment of the likely consequences.
Whilst at the time of writing, the Prime Minister’s negotiated agreement looks unlikely to be supported in Parliament. Were it to win a majority in the House of Commons, the status quo for EU/UK import and export, border crossings and the like, applies for the time being. However there will be changes as the UK moves to the final settlement.
DEFRA have kept the door open for further engagement and I am grateful that we have had the opportunity to contribute.