‘It took us 6 months to export 4 pallets of gluten-free ham and cheese toasties’

The UK’s departure from the EU was intended to give the nation greater control over its policy, which had previously been agreed at EU level.

Whilst ex-Prime Minister Boris Johnson said his plan to get Brexit done would ‘untangle’ us from 40 years of EU membership, it appears as though we have instead tied ourselves into knots.

One of these tangles lies firmly in how we trade with the EU – and whilst there’s been many issues making headlines in exporting and importing, one major government oversight resulted in sandwich manufacturer Raynor Foods having to delay an export of gluten free ham and cheese toasties for 6 months.

Life before Brexit

Before the UK left the EU, it benefitted from free trade between all member states. Part of this was automatic access to an EU-operated software known as TRACES NT.

This online platform is an integral part of the exporting process – without it, produce of animals, animal products, food and feed of non-animal origin and plants are not getting across the border and into the EU.

The blanket removal of businesses in the UK meant everyone had to (re-)register – but as Raynor Foods soon discovered, part of the form necessitated a health mark certificate.

In a nutshell, this is an identification mark applied to products of animal origin to show it has been produced in an establishment approved in accordance with food safety and hygiene regulations.

Before Brexit, products produced by Raynor Foods for the European market were subject to regular inspections under the Food Hygiene (England) Regulations 2006 for the purposes of monitoring compliance with regulation (EC) No 852/2004 on the hygiene of foodstuffs.

However, as a producer of composite products, it was exempt from Regulation (EC) No 853/2004 on the hygiene of food of animal origin. Therefore, requirements related to approved premises including the application of an approval number did not apply.

Without a trace(s)

The company still does not need a health mark, but for some reason the TRACES system demanded one in order for the organisation to register.

Whilst the business could have entered the laborious process of obtaining a health mark to gain access to the system, it seemed like a redundant and costly task simply to address an oversight.

One would have assumed to gain access to TRACES would have been a simple fix – a phone call or email, surely? Unfortunately, no. It turned out to be a 6-month process.

Karina Gluszczyk, the company’s microbiologist and lead for exporting at Raynor Foods, was thrown between government departments, including the Animal and Plant Health Agency (APHA) and Food Standards Agency (FSA), in a bid to get an answer.  

Finally, after several months of this back and forth, Gluszczyk discovered the business was suddenly, somehow, on the system.

“I kept checking it and then one day, we were just there! I still have no idea how,”​ she told Food Manufacture.

The business still doesn’t have access to TRACES, nor as Gluszczyk explained has she been informed how or who managed to get the business onto the system.

Obviously, the lack of conformation and communication has left her feeling nervous, and to quell these fears Gluszczyk says she always checks with the EU customer that the business is still on the system.

“Customers are always puzzled as to why I’m asking – but I’m just worried one day we’ll disappear!”​

Like many have aired, Raynor Foods is concerned around the growing costs new exporting processes will bring, alongside the risk of goods being held up at ports as a result of complications, confusion and vet shortages.

Speaking with Tom Hollands, the company’s innovation and technical director, he explained that currently different port authorities seem to have slightly different interpretations of import requirements, which has resulted in international calls for clarification. Meanwhile, divergence between standards in the UK and EU could cause further complications, although for now it does appear that we are following a similar path in many regards.

“We don’t want to disappoint any of our customers, and we pride ourselves on our delivery service of 99.99% on time and in full,”​ he said.

“Although entering the European Union has created barriers to trade, we are optimistic that these barriers can be resolved so we can trade more freely with the country’s biggest market.”​

Left to our own devices

Speaking with another food producer who has been recognised for its great exporting work but wished to remain anonymous, the spokesperson explained that while they had not experienced this exact issue, the additional work and confusion for Northern Ireland customers has been a logistical headache.

“When I have had issues in the past with exporting, particularly when it came to the issues post Brexit, there was very little support given to me or seemingly anyone and I even had other suppliers asking me how to navigate some of the red tape because the information from places like Defra or DBT [Department for Business and Trade] etc., was too general and non-specific,” ​the representative said.

“More often than not, I am directed to general information on gov websites or receive generic information that is not specific to my specific question. My opinion is that we need to have more dedicated people working in these organisations who dedicate time to getting actual answers and helping companies who have these issues because there is nothing like that and we are more often than not left to fend for ourselves and try and work things out.”​

A one-off? 

Defra was approached for comment regarding the issues over the TRACES system and explained to Food Manufacture that as this is an EU system, the department’s hands are somewhat tied in terms of how much help it can offer to producers around technical issues.

The spokesperson for Defra said this is likely to be a one-off, technical problem and reassured, that as far as they are aware, it is not a widespread issue causing problems for other importers and exporters.

When asked who producers should defer to if they do experience issues, they said APHA is the first port of call for exporters and importers, with this arm of Defra able to help them navigate the systems and operations that the EU is responsible for controlling.

Let’s hope next time it doesn’t take 6 months.

In other news, the UK Government has published illustrative base fees ahead of EPR rollout.​​