UK warned on post-Brexit restrictions

THE EU has warned the UK it faces a “restrictive legal framework” for agri-food exports to the bloc postBrexit, particularly for live animals and animal products.

In a slide presentation for EU diplomats published last week, the European Commission said existing precedents for preferential market access on food products “fall very far short of EU membership”.

Non-EU countries, products and companies have to be legally “approved” by the European Commission before they can export to the bloc. They must then comply with the EU’s sanitary and phytosanitary (SPS) standards and undergo customs controls.

Standards

The EU has a chapter on SPS standards in its recent trade deal with Canada, and has veterinary agreements in place with New Zealand and the US, but the Commission said these do not amount to a “mutual recognition” of standards, which the UK says it wants.

UK health secretary Jeremy Hunt said last week that the UK would align with EU rules in certain sectors, on a “voluntary basis”, and would be free to diverge in others.

The approach was dismissed by the EU as “not compatible” with its negotiating mandate on Brexit.

The EU and UK are also negotiating a 21-month transition period that would kick in on 30 March 2019, where the UK would continue to be part of the EU’s sanitary and phytosanitary system and there would be no need for customs and health and safety checks.