Brexit Potential Regulatory Impacts Fishery Product Trade

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1 Dr. Micheál O Mahony Authority Member Veterinary Specialist Sea-Fisheries Protection Authority Brexit Potential Regulatory Impacts Fishery Product Trade Ocean Wealth Galway 2018

2 Overview EU Trade Fishery Products Food Safety Regulatory Framework IUU Pre Brexit Trade Impacts Food Consignments Post Brexit Landbridge Direct Landings Page 2

3 Overview EU Trade Fishery Products Food Safety Regulatory Framework IUU Page 3

4 EU Trade Fishery Products Linguistics EU Member States (MS) Third Country (TC) Intra-EU trade EU Common market Free trade Page 4

5 EU Trade Seafood EU Single biggest seafood trading block in world EU Production 6 MT + EU Imports 9 MT - EU Exports 2 MT = EU Market 13 MT Page 5

6 Trading BLOCK World EU Page 6

7 Entry Gateway Then Release for Free Circulation Page 7

8 EU Border Inspection Posts Page 8

9 Gateway Concept Outside EU Food Regulations Equivalent Standards Pos Listing Country & Plant Documents CHED Health Cert Border Post Official Contro l Check IUU Regulations Wild-Caught Fish Fisher Legitimacy No Neg listing Country or Vessel Document Catch Cert Free Circulation Within EU Page 9

10 Imports of Fishery Prods to EU from TC Food Regs IUU Regs Pos Listing Country & Plant Documents CHED Health Cert Border Post Official Contro l Check No Neg listing Country or Vessel Document Catch Cert Page 10

11 Reciprocal Exports from EU to TC Third Country Entry Requirements Listing Notification CHED Usually Health Cert Export MS Authority Entry Gateway Sometimes Catch Cert Flag MS Authority Page 11

12 Overview EU Trade Fishery Products Food Safety Regulatory Framework IUU Pre Brexit Trade Impacts Post Brexit Page 12

13 Page 13

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15 Trading BLOCK World UK EU Page 15

16 Trading BLOCK World UK EU Page 16

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19 Before BREXIT Fish Product trade Consignments Between Ireland UK Free trade within EU Intra-EU, Inter-MS Common Market Normal EU Approval No restrictions Enter / leave MS Anywhere Any Time Common Fishery Policy Normal vessel licence No additional food/fish controls Beyond intra MS trade Page 19

20 After BREXIT. Possible Scenario Consignments from UK to Ireland Imports from Third country to EU Entering EU through Ireland Border Post Food Regs Pos Listing Country & Plant Documents CHED Health Cert Border Post Official Contro l Check IUU Regs No Neg listing Country or Vessel Document Catch Cert Page 20

21 After Brexit: A possible scenario Consignments from Ireland to UK Exports from EU to Third Country Leaving EU from Ireland Usually Health Cert Export MS Authority Listing Notification CHED Entry Gateway Sometimes Catch Cert Flag MS Authority Page 21

22 Overview EU Trade Fishery Products Food Safety Regulatory Framework IUU Pre Brexit Trade Impacts Food Consignments Post Brexit Landbridge Direct Landings Page 22

23 A Particular Case 1. Land-bridge Consignments Transit through UK On the way from Ireland to EU continent On the way from EU continent to Ireland Land-bridge e.g. Road from IE fish landing to Irish Ferry port, Ferry IE to UK Ferry Port Road from UK Ferry port to UK Ferry Port Ferry UK to EU continent Road to EU Continent destination Other real examples Page 23

24 Before Brexit. Land-bridge Consignments through UK Free trade EU market Origin, transit, & Destination all within EU Common Market Normal EU Approval No restrictions Enter / leave MS Anywhere Any Time Common Fishery Policy Normal vessel licence No additional food/fish controls Beyond intra MS trade Page 24

25 After Brexit. Possible Scenarios Consignments through UK Transit outside of EU, en route from EU origin to EU destination Export - Import Full EU export to UK, then full UK export to Two gateways Bonded Transit scenario Virtual non-uk transit In-transit from EU origin, to EU destination Never enters UK Seal at origin, Check at EU exit and/or re-entry to EU Page 25

26 Overview EU Trade Fishery Products Food Safety Regulatory Framework IUU Pre Brexit Trade Impacts Food Consignments Post Brexit Landbridge Direct Landings Page 26

27 Specific case 2: Direct Landings Landings of fish to EU port by third country fishing vessel which caught the fish Recognised in both Food & Fish Regulations Still an import of food to EU A form of international food trade Some derogation in food regs Overall burden greater than CFP & Common market Page 27

28 Gateway Concept Outside EU Food Regulations Equivalent Standards Pos Listing Country & Plant Documents Captain s CHED Health Declaration Cert Border Post Border Post Official not necessary Contro if Fresh. l Designated Check TC Port Free Circulation Within EU IUU Regulations Wild-Caught Fish Fisher Legitimacy No Neg listing Country or Vessel Document Catch Cert Pre notification Pre discharge Authorisation Page 28

29 Before Brexit Direct Landings UK vessel to IE ports Direct Landings IE vessel to UK ports EU vessel to EU port. Common Fishery Policy Common Market Wide Choice potential landing ports Discharge at-will Some CFP restrictions Notification Frequently Page 29

30 After Brexit. A possible Scenario Direct Landings UK vessel to IE ports Third country food import to EU Food Regs Pos Listing Country & Plant Documents Captain s Declaration Border Post If Frozen Designated TC Port Pre notification IUU Regs No Neg listing Country or Vessel Document Catch Cert Pre discharge Authorisation Page 30

31 After Brexit. A possible Scenario Direct Landings IE Vessel to UK port Import to UK. EU export. Reciprocal TC requirement at entry Pos Listing Country & Plant Documents Captain s Declaration Designated TC Port Border Post If Frozen Pre notification No Neg listing Country or Vessel Document Catch Cert Pre discharge Authorisation Page 31

32 Overview EU Trade Fishery Products Food Safety Regulatory Framework IUU Pre Brexit Trade Impacts Food Consignments Post Brexit Landbridge Direct Landings Page 32

33 Take-Home Message Business models involving market routes 1. Export to UK 2. Import from UK 3. Export to EU through UK 4. Import from EU through UK 5. Direct Landings of UK vessel to Ireland 6. Direct Landing of Irish vessel to UK Need to plan post-brexit logistics or alternatives

34 Dr. Micheál O Mahony Authority Member Veterinary Specialist Sea Fisheries Protection Authority Sin an Méid