IMTA calls for Defra to share its ‘rigorous analytical assessment’ of BTOM checks impact on UK consumers

IMTA was interested to see the latest Defra blog post which responded to various questions raised in the media on Defra’s calculations for the impact of the BTOM on consumers.

We would like to ask Defra to share the full analysis and methodology of their ‘rigorous analytical assessment’ to provide confidence in the introduction of border controls. If it is rigorous then there should be no issue in sharing it as it should stand up to scrutiny.

We would pose several questions on Defra’s analysis:

• Assuming the predicted 0.2% inflationary impact is across all food rather than particular products, what is the impact specific to meat?
• Is the 0.2% spread over the next three years or 0.2% per year for three years?
• Additionally, with regards to the comment "saving traders £520m a year compared to the import model originally proposed", what is the modelled cost of the originally proposed import model, from which this £520m saving has been calculated?
• How did Defra conduct this analysis when the Common User Charge (CUC) and other port charges were not yet known?
• How has the impact on supply chain operating hours, truck driving times, cold store bookings and people hours been factored into these calculations?
• How has any anticipated loss of supply been modelled in terms of impact on consumer prices?
• With the CUC, the cost does not consider size of consignment. As essentially a flat rate this disproportionately impacts on SMEs and those moving smaller consignments within groupage loads. How has the impact on SMEs and groupage loads been modelled within the analysis?
• Was the wider supply chain, beyond supermarkets, considered in the analysis? The food industry is much wider than that – smaller food retailers, foodservice, wholesale, butchers, manufacturers and beyond. How were these other parts of the food chain included in the analysis?

Whilst we fully support the need to protect UK biosecurity as paramount, this could have been achieved through more proportionate controls to support two-way trade and protect British consumers and businesses from substantial price rises.

As we illustrate in our ‘two-way trade’ infographics, imports are fundamental to UK food security. They complement domestic production and, as such, in the meat sector play a key role in ensuring year-round supply of a choice of products to UK consumers.

IMTA is a UK trade association, representing predominantly UK companies importing and exporting meat. Our goal is the facilitation of the trade in meat ensuring UK consumer choice, food security and carcass balance through import and export. IMTA provides leading trade expertise on UK trade policy including on customs, tariffs, quotas, rules of origin, WTO, trade agreements, SPS conditions and market access.