Thoughts. Company reputadon is at stake risk avoidance taken creates costs to trade. => The direcdon of travel regarding barriers to trade is unclear

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1 Thoughts Clear views that the playing field is not level (actual vs anecdotal ) Clear concerns regarding NTMs in EU: Importance to verify origin for both imports and exports (customs to consumer) StandardisaDon required for all EU countries (e.g. SPS, cerdficates etc) There are costs in navigadng non- tariff measures SomeDmes it can be a direct cost of losing business or even a shipment SomeDmes it s just red tape Company reputadon is at stake risk avoidance taken creates costs to trade => The direcdon of travel regarding barriers to trade is unclear 10/10/2017 NTM Workshop, Brussels October

2 # Technical Measure Brief descrip3on Examples A B C SANITARY AND PHYTOSANITARY MEASURES (SPS) TECHNICAL BARRIERS TO TRADE (TBT) PRE- SHIPMENT INSPECTION AND OTHER CUSTOMS FORMALITIES Measures that are applied to protect human or animal life from risks arising from addidves, contaminants, toxins or disease- causing organisms in their food Measures referring to technical reguladons, and procedures for assessment of conformity with technical reguladons and standards Compulsory quality, quandty and price control of goods prior to shipment from the expordng country, conducted by an independent inspecdng agency mandated by the authorides of the impordng country hazard analysis and cridcal control point (HACCP) requirements maximum residue limit is established for insecdcides, pesdcides, heavy metals and veterinary drug residues tesdng and cerdficate requirements for SPS related factors Labelling, marking and packaging requirements Product idendty requirement (including biological or organic labels) Conformity assessment related to TBT (including tesdng, cerdficadon and traceability) Goods imported under a preferendal scheme such as GSP must be shipped directly from the country of origin in order to sadsfy the scheme s rules of origin condidon # Non- technical Measure Brief descrip3on Examples D CONTINGENT TRADE- PROTECTIVE Measures that counteract adverse effects of imports in the AnDdumping to counteract imports injuring domesdc companies MEASURES market of the impordng country, condngent on fulfilling Countervailing to counteract subsidies of expordng country certain condidons E NON- AUTOMATIC LICENSING, QUOTAS, PROHIBITIONS AND QUANTITY- CONTROL (MEASURES OTHER THAN FOR SPS OR TBT REASONS) Measures to limit the quandty traded, such as quotas. It also covers licences and import prohibidons that are not SPS- or TBT- related G FINANCE MEASURES Measures intended to regulate the access to and cost of foreign exchange for imports and define the terms of payment. H MEASURES AFFECTING COMPETITION Measures to grant exclusive or special preferences to one or more limited group of economic operators An import- licensing procedure where approval is discredonary or requires specific criteria to be met RestricDon of imports by a maximum quandty or value that is authorized. Tariff rate quotas for EU fish traders as this may result in different tariffs (i.e. zero or WTO) being charged within or above quota limits They may increase import costs in the same manner as tariff measures Advance payment requirements (import transacdon and/or import taxes) MulDple exchange rates (varying rates, depending on the product category) ProhibiDon of foreign exchange allocadon and other authorisadons) These refer mainly to monopolisdc measures, such as State trading, sole impordng agencies, or compulsory nadonal insurance or transport O RULES OF ORIGIN Laws, reguladons and administradve determinadons of general applicadon applied by government of impordng countries to determine the country of origin of goods For fish products, rules of origin must be shown on import to EU countries. This includes processed products and may be open to challenge if the correct documents are not available P 10/10/2017 EXPORT- RELATED MEASURES Applied by the government NTM of the Workshop, expordng country Brussels on October Export- licenses, 2017 export quotas, prohibidon of exports 2 exported goods.

3 Results ies type # fish 6 ne fish 24 taceans 11 ed fish 9 p sh an) Pollack es vies n (fresh/frozen/smoked) p (aquaculture) g rel h fish e molluscs (e.g. scallops) ops t mmary of issues iden7fied NTM category # HEALTH AND SAFETY 10 TRACEABILITY AND LABELLING 8 TECHNICAL MEASURES 17 CerDficate of Origin Catch cerdficates Health cerdficate CoaDng used in cans Limited access to market at reduced duty Different label criteria IUU fishing Names result in different duty (e.g. Gadus="cod") SPS level of andbiodcs Finance measures Heath and safety List of permiied species CoaDng inside cans Origin label Managing origin to reduce tariffs Financial measures VAT Export measures Differences in ports Delays in export cerdficates Delays in imports with fresh/super fresh Region # INTRA EUROPE / ICELAND&NORWAY 9 NORTH AMERICA 12 SOUTH AMERICA 7 ASIA 19 MIDDLE EAST & NORTH AFRICA 9 Value chain Cost # 0-5% 12 5% 11 10% 10 25% 1 Vietnam Bangladesh China Korea Morocco ArgenDna Iceland Norway US Vietnam Angola Japan Netherlands Russia Italy France ArgenDna Gabon Chile Primary producer / First buyer / Wholesaler (EXPORTS) First buyers / agent / wholesaler / processor (IMPORTS) Agent / Processors (EXPORTS) Secondary Processors (IMPORTS) Distributor / Retail / Catering (IMPORTS) 10/10/2017 NTM Workshop, Brussels October

4 Some examples Names simplificadon needed Delays in export cerdficates Delays in imports with fresh/super fres One EU country has a more restric2ve law Nephrops catchers in the UK dip their catch in 4HR to avoid browning. 4HR has been permiied in the EU since August 2006 for use in crustaceans up to a level of 2mg/kg, and has largely replaced the use of sulphites. Some countries outside the EU (e.g. Japan), do not permit this addidve. There is a chemical used in cans that is put in the lacquer of the interior part of the Dn France has prohibited it, rest of the EU hasn t This makes us to have to duplicate the number of references, increase cost, complicate management, et Fish fingers. US exporters don't use correct "non- manipuladon cerdficate" as required by EU, as product is exported first to Korea and not require There is a +- max tolerance on levels of andbiodcs if close at point of export, difficult to judge how this may be when tested on import given random samples are taken. If found "over" then go on a blacklist to be checked. Procedural, SPS level of andbiodcs not accepted. No further communicadon with EU legal authorit Container destroyed if not accepted 10/10/2017 NTM Workshop, Brussels October

5 Iden7fying trade issues he choice experiments plementadon is esigned to elicit details f measures impacdng he trade of seafood in urope. t is built from five main iributes: species, non- ariff measure, region, alue chain stage and ost impact. 10/10/2017 NTM Workshop, Brussels October