10.1 Overview

The National Farmers’ Union (NFU) has said that a no deal outcome is the “worst possible one” for the farming industry.392 The Food and Drink Federation (FDF) has called no deal a “grisly prospect”.393

In a no deal scenario for agriculture, trading arrangements, i.e. tariffs and standards, are the main issue.

No deal potentially means applying WTO tariffs where there currently are none for intra-EU trade, as well as WTO rules for plant and animal health checks (in trade terms these are known as sanitary and phytosanitary (SPS) measures).394 This could have a significant impact on the farming industry and consumers in terms of changing the balance of import and export markets and consumer choice, the speed of supply chains, and prices.

Tariffs are usually higher for agricultural products than for other goods and services. Perishable goods such as milk are also more sensitive to delays at borders, as are live animals.

Without an alternative arrangement, the EU will treat the UK as a third country and a range of tariffs, checks, registrations, certifications etc will start to apply for the first time for a range of commodities, food and feed and for plant and animal-based products. Agriculture is also impacted by the no deal effects of other policies e.g. immigration (for seasonal, agri-food workers and vets).

A number of practical issues arising from additional checks and customs processes could lead to supply chain disruptions if food consignments are held up at ports. The food and drink sector are reported to have been building up additional stock since mid-2018. There were widespread media reports in January 2019 that mounting concerns about supplies being affected by a no deal scenario had led to consumers stockpiling food at home.

10.2 Farm support schemes

The UK is already preparing farm support payment systems to apply outside the Common Agricultural Policy (CAP), whatever the Brexit scenario. This is because only EU Member States can participate in the CAP and its payment schemes.

CAP support is currently made up of direct payments under the Basic Payment Scheme (Pillar I) and payments for agri-environment measures and grants for rural development projects which contribute to wider rural development objectives (Pillar II) under the Rural Development

392 NFU Online, Technical notice serves warning over continuity of British food exports, 23 August 2018

393 FDF, FDF response to Government’s no deal technical notices, 23 August 2018

394 The WTO’s Agreement on the Application of Sanitary and Phytosanitary Measures (SPS measures) sets out the basic rules for food safety and animal and plant health standards

 

Programmes for each part of the UK. CAP support makes up around 50-60% of farm incomes in England.

395 In other parts of the UK it is a larger proportion, mainly because there is more land which has more difficult farming conditions e.g. hill farming.396

Consultations on new domestic agriculture policy have taken place across the UK legislatures. The UK Government has pledged to maintain the same cash funds as currently for farm support under CAP until the end of the Parliament, in the expectation that this will be 2022.397 This is for all of the UK and across all aspects of current CAP funding i.e. Pillars I and II. The ‘no deal’ technical notices issued by the Government in August 2018 included notices on Farm payments if there’s no Brexit deal and Receiving rural development funding if there’s no Brexit deal.398 These confirm that in the event of ‘no deal’ any remaining payments to farmers, land managers and rural businesses due after March 2019 would be funded. Rural development projects would be funded until they finish, and new projects can continue to be signed during the rest of 2019 and 2020 up to the value of programme allocations.

An Agriculture Bill (HC Bill 266) was published in September 2018 containing measures for the UK, with specific measures in addition for England, Wales and Northern Ireland. House of Commons Library Briefing Agriculture Bill 2017-19 provides full details of the Bill’s proposals and progress, as well as information on proposals being developed by the administrations in Scotland, Wales and Northern Ireland.

10.3 Regulatory issues: technical notices

The UK Government’s ‘no deal’ technical notices issued in August, September and October 2018 (updated in December 2018) and January 2019, have covered a range of food and agricultural issues. These outline regulatory changes which would affect certain activities and sectors, such as the regime for pesticide authorisations and exports of animal products to the EU.399

Some of these notices indicate that retained EU law may need to be amended, whilst other notices indicate that the law will not be amended, as equivalency agreements are being sought with the EU on the basis of harmonised law.

The main technical notices cover the following areas:400

Organic food

  • Producing and processing organic food if there’s no Brexit deal (published 23 August 2018)

395 Commons Library Briefing, Brexit: UK Agriculture, 8218, 11 September 2018

396 Northern Irish agriculture subsidies to fall after Brexit report warns, The Irish News, 16 January 2018

397 GOV.UK The Unfrozen Moment – Delivering a Green Brexit, 21 July 2017

398 GOV.UK How to prepare if the UK leaves the EU with no deal collection of guidance, [accessed 22 January 2019]

399 Ibid

400 Ibid

Although no official data is available, it is estimated that about 10% of the UK’s organic output (worth some £2.2billion in 2017) is exported and predominantly to EU countries.401

UK businesses will need to be certified by an organic control body to export to the EU. The body must be recognised by the EU but the UK control body cannot apply to the European Commission until the UK becomes a third country. Approval can then take nine months. The notice states that the Government is “exploring alternative approaches that should speed up this process”.

The NFU has highlighted how this would in effect be a trade embargo on UK organic products and could have wider, disruptive implications for the future trade of all agri-food products if all of them were subjected to the same problems in approval and certification.402 The Food and Drink Federation (FDF) has pointed out that similar issues will apply for other food currently displaying EU marks or logos.403

The Government has said that it anticipates “continuing to accept EU organic products in a ‘no deal’ scenario, but this will be at the UK’s discretion” and it expects to negotiate an equivalency arrangement because the UK will be retaining existing EU requirements for organic food.

The technical notice also states that certification and traceability of organic food and feed products will continue to be required by the UK. However, a new UK-owned imports traceability system would replace the current EU TRACES.NT system to ensure the traceability of organic food and feed. The EU Trade Control and Expert System (TRACES) tracks the entire trade and certification process for animals, food, feed and plants. The FDF doubts the UK Government’s ability to replace TRACES with a new, comprehensive, functional UK alternative IT system in time for EU Exit Day.404

Genetically Modified Organisms (GMOs)

  • Developing Genetically Modified Organisms (GMOs) if there’s no Brexit deal (published 23 August 2018)

Applications for new GMOs are managed at EU level, with assessment carried out by the European Food Safety Authority (EFSA). According to the notice, the transfer of provisions under retained EU law with amendment only to make it operable in the UK-only context, means that there would be “no significant implications for UK stakeholders”. Regulatory decisions on proposed GM trials would continue as now on a devolved basis and the UK would apply the same risk assessment process on marketing GMOs as currently takes place at EU level (although it is not yet decided if this is to be on a joint-UK basis or separately across the devolved legislatures).

401 No deal Brexit could wipe out British Organic Farming, Farmers Weekly, 23 August 2018

402 NFU Online, Technical notice serves warning over continuity of British food exports [Accessed 22 January 2019]

403 FDF, FDF response to Government’s no deal technical notices, 23 August 2018

404 Ibid

 

  • Exporting GM food and animal feed products if there’s no Brexit deal (published 12 October 2018)

As the UK would be treated as a third country, UK businesses would only be able to export GMO products to the EU if the GMO had EU marketing approval. This would be the same for the EU with UK marketing approval.

If there is no deal, UK exporters to the EU will require representation in the EU or EEA. EU countries each have their own systems for this. The Food Standards Agency is currently seeking clarity on interpretation of changes to EU rules, but the notice advises that “companies should nevertheless anticipate this revised interpretation and consider designating a representative within the EU or the EEA”. The notice also notes that:

Changes to holder-specific authorisations for GM food or feed or for feed additives require amendments to EU legislation which would need to be in place by 29 March 2019 (may also apply to new exit date on 31 December 2020). Businesses in the process of such changes would need to approach the European Commission without delay.

Fertilisers

  • Manufacturing and marketing fertilisers if there’s no Brexit deal (published 24 September 2018)

There are currently both a UK domestic and an EU framework under which manufacturers can choose to market their products: the UK framework remains in place under ‘no deal’ as it is separate from the EU framework. Both regimes would carry on in parallel to provide “the greatest continuity in the short-term” and existing requirements would continue. The notice adds that:

Over time, the regulatory framework would then be reviewed and rationalised. However, there would be some implications for material labelled ‘EC fertiliser’ in accordance with the EU Regulation and sold in the UK […] after the end of [a] time-limited adjustment period, fertilisers placed on the UK market would need to comply with the current domestic regime or with the requirements of the new ‘UK fertiliser’ regime.

The Government will publish a new list of laboratories approved to test to the standards required for the new ‘UK fertiliser’ label. The laboratories would need to meet the same requirements as they do now and test against the same standards as set out in the current EU Regulation.

There would be no material change for users of fertilisers. All fertilisers currently marketed in the UK could continue to be imported and marketed in the UK provided they met the requirements set out above. The same standards would continue to apply to fertiliser products.

Food labelling

  • Producing and labelling food if there’s no Brexit deal (published 24 September 2018)

Initially, the EU-based provisions would all be rolled over under the EU (Withdrawal) Act, and fixed where necessary by statutory instrument so the rules apply as before. However, some changes would be required to reflect the fact that the UK will no longer be a member of the EU.

For example, use of the term ‘EU’ in origin labelling would no longer be correct for food or ingredients from the UK and some products, such as honey blends from more than one country, will require further changes. In addition, from April 2020, the country of origin or place of provenance of the primary ingredient of a food (where different to that given for the food overall) will be required on labels as part of EU rules on food labelling. The Government may seek views on whether similar national rules would be appropriate in the UK when EU rules no longer apply.

The Government launched a consultation on food labelling: amending laws which closed in November 2018. This sought views on the changes needed to legislation under a ‘no deal’ scenario. The results of the consultation, which closed in November 2018, will be published by 7 February.405

Animals and animal product imports and exports

  • Importing animals and animal products if there’s no Brexit deal (updated 19 December 2019)

In a ‘no deal’ scenario the EU will not allow the UK to access the EU import notification system, TRACES. A new UK import notification system is being developed to take the place of TRACES. The new system will be available for early testing in January 2019, to be fully operational for all users from the day the UK leaves the EU.

There would be no change to current import controls or requirements for notifications of imports of live animals and animal products for imports direct from the EU.

To maintain high levels of food safety, the UK would require importers of high-risk food and feed to pre-notify the Food Standards Agency (FSA) of imports from the EU. The notice states that “this requirement would have no direct impact at the border or for port health authorities. Pre-notifications would be made electronically, in advance, by those introducing high-risk foods into the UK, and would be managed by the FSA. No additional controls would be introduced at the border”.

There will be no change to current import controls and requirements for notifications of live animals, animal products, and high-risk food and feed imported directly from third countries. The only difference is that importers would need to use the new import notification system instead of TRACES.

Changes would apply to control requirements for imports of third country animal products and high-risk food and feed which move

405 Written Question 908633 16 January 2019

 

through the EU before arrival in the UK, from 29 March 2019 (may also apply to new exit date on 31 December 2020). Importers would need to notify UK authorities using the new import notification system and would be directed to an existing UK Border Inspection Post (BIP) where the relevant checks would take place. This requirement would ensure the current level of biosecurity is maintained.

The requirement for live animal imports from a third country, which move through the EU before arrival in the UK, to enter via a UK BIP is being reviewed, as all live animals would have been subject to checks at the point of entry to the EU. For live animal imports the importer will be required to notify the UK authorities using the new import notification system.

  • Exporting animals and animal products if there’s no Brexit deal (published 24 September 2018)

If there is no deal all UK animal product and live animal exports to the EU must be accompanied by Export Health Certificates (EHCs) signed by an Official Veterinarian or authorised signatory following inspection. The consignment must travel through a Border Inspection Post. The UK would need to be listed as a third country. The notice says that:

the UK would apply for this status but cannot be certain of the EU response or its timing. Without listed status no exports to the EU could take place. We are confident however, that the UK meets the animal health requirements to secure listing, as other countries such as Australia and New Zealand have done so.

Plant imports and exports

  • Importing and exporting plants if there’s no Brexit deal (published 24 September 2018)

Currently there are no border controls on most imports and exports of plants and plant products between the UK and the EU. Some plants and plant products that present a higher biosecurity risk are managed under the EU plant passport regime. The notice states:

In a ‘no deal’ scenario, the UK would become a third country, and would need to meet EU third country import requirements to export controlled plants and plant products to the EU, including controls on all plants for planting and all wood packaging material.

The process for sending controlled plants and plant products to the EU would be the same as the current process for sending them to third countries. Under this process, businesses need to apply for a Phytosanitary Certificate (PC) from the relevant UK plant health authority before they can export. Some commodities require laboratory testing of samples to ensure they are free from pests and diseases, while others also need to have had an inspection during the growing season.

On imports, the notice states:

To deliver a smooth transition when we leave the EU, in a ‘no deal’ scenario the Government has decided that the majority of plants and plant products are low-risk and should continue to enter the UK from the EU freely, as they do now, with some exceptions such as Plants and plant products managed under the EU plant passport regime

Geographical protections

  • Protecting geographical food and drink names if there’s no Brexit deal (published 24 September 2018)

EU rules allow product names to be protected under geographic indication (GI) regulations, in line with the WTO Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPS). UK GIs are protected from imitation and evocation throughout the EU. There are currently 86 GI-protected UK product names, comprising 76 agricultural and food products, five wines and five spirit drinks which together make up a quarter of the value of UK food and drink exports.

The UK Government has recently consulted on proposals for the new UK GI schemes which will bring the EU GI regulations into UK law via the EU (Withdrawal) Act 2018 from exit day to meet WTO obligations. There is only limited scope to diverge from the EU approach but the UK is consulting on a new logo and appeals process.406 Commons Library Briefing Brexit: Future UK Agriculture Policy (chapter 8.4 Food Labelling) provides more background information on this topic.407 According to the Institute for Government the provisions of the Withdrawal Agreement on GIs would have important implications for UK’s trade policy: “it prevents the UK from importing other countries’ versions of protected products (such as Australian feta cheese) or manufacturing its own (such as English Champagne)”.408

The notice says that the new GI scheme will be:

no more burdensome to producers. The UK would no longer be required to recognise EU GI status. EU producers would be able to apply for UK GI status. We will be publishing guidance on the UK GI schemes in early 2019.

Pesticides

  • Regulating pesticides if there’s no Brexit deal (published 12 October 2018)

This notice sets out how the complex area of Plant Protection Products (PPP) regulation currently covered by EU rules will be addressed after Brexit. The UK currently works within an EU regulatory system of pesticide approval. Active ingredients are authorised at EU level for use across Europe, but Member States

406 Defra, Consultation on establishing UK Geographical Indications (GI) Schemes after EU Exit, October 2018

407 Commons Library Briefing 8218, Brexit: Future UK Agriculture Policy, 11 September 2018, pp73-75

408 Institute for Government, The November Draft Withdrawal Agreement, 19 November 2018

authorise the specific products which make use of these ingredients and set conditions for their use. The competent authority for doing this in the UK is the Chemicals Regulation Directorate (CRD) in the Health and Safety Executive.

The notice states that in a ‘no deal’ scenario the UK would repatriate all decision-making to the UK, but for stability would retain the two main EU regulations in national law with no change to policy. However, for the regime to operate in a domestic setting, secondary legislation is needed to make some technical corrections to “ensure a smooth transition in the event of no deal”. The Government is already planning for the regulatory capacity needed to implement the regulation of plant protection products in the UK, “building on the existing capacity in the Health and Safety Executive”.409 The notice states that EU legislation on active substance approvals and Maximum Residue Level will be replaced in the UK by a new statutory register which will be publicly available online.

All current plant protection product approvals in place on 29 March 2019 (may also apply to new exit date on 31 December 2020) would remain valid in the UK, so “businesses could continue to trade and products would continue to be available”. An extension of three years to active substance approvals will be granted to those due to expire in the three years after Brexit to provide time for national renewal arrangements to be established. Parallel trade permits in force at the point of exit would remain valid for a two-year transition period or the extant expiry date (whichever is sooner).

The UK would not be legally committed to “medium or long-term regulatory alignment with the EU” under a no-deal Brexit so divergence from developing EU legislation would be possible “in due course”.

Other Technical Notices on preparing for ‘no deal’ published in 2018 and 2019 included:

  • Plant variety rights and marketing of seed and propagating material if there’s no Brexit deal (12 October 2018)
  • Breeding animals if there’s no Brexit deal (12 October 2018)
  • Trading timber: imports and exports if there’s no Brexit deal (22 January 2019)

10.4 Food supply

Potential disruption to food supplies and price rises in the short-term immediately after a no-deal Brexit has been given regular media coverage.410

409 HC PQ 163617 18 July 2018

410 See, for example, the Metro, Pets at Home to stockpile £8 million of pet food ahead of Brexit, 22 January 2019, and BBC My Brexit Box: the people stockpiling food, 9 November 2018

Supply chain disruption

Under a ‘no deal’ scenario, Export Health Certificates (EHCs) would be required for all animal products (such as dairy and meat products) and live animals from the UK to the EU, and consignments would need to travel through Border Inspection Posts.411 The UK would need to be listed as a third country, as without this no exports to the EU could take place. There are currently no border controls on most imports and exports of plants and plant products between the UK and the EU but a no-deal outcome means the UK would need to meet EU third country requirements, including for all wood packaging material.412 This could have practical impacts on food supply, potentially disrupting just-in-time supply chains, especially affecting fresh produce.

Defra Secretary Michael Gove’s speech to the Oxford Farming Conference in January 2019 noted that the EU had said that 100% of (animal) products would face sanitary and phyto-sanitary checks, although the EU had pledged to accelerate recognition of the UK as a third country to allow exports to continue freely. He referred to practical obstacles for exports facing increased checks:

Much of our trade currently reaches European markets through the narrow straits between Dover and Calais. At the moment there are no border inspection posts at Calais. While we do hope the French take steps to build capacity there, that capacity is unlikely by the end of March to be generous.

He added that:

The EU have also said that hauliers from the UK can carry export goods to EU markets but they cannot make multiple journeys from EU country to EU country and thus the costs of haulage could rise as well.

The combination of significant tariffs when none exist now, friction and checks at the border when none exist now and requirements to re-route or pay more for transport when current arrangements are frictionless, will all add to costs for producers.

As will new labelling requirements, potential delays in the recognition of organic products, potentially reduced labour flows and the need to provide export health certificates for the EU market which are not needed now.413

Previously, in August 2018, then EU Exit Secretary Dominic Raab said the Government had set out “practical measures to mitigate any risks of disruption to supply”. He said this would be achieved through “the recognition of EU food standards, our pursuit of equivalency arrangements on food regulation with the EU and indeed with non-EU countries, and through our support for UK farmers in terms of financial funding schemes”.414 Mr Raab highlighted that the UK’s food and drink supply is diverse, with the UK supplying half of the food that we consume with 30%

411 GOV.UK, Exporting animals and animal products if there’s no Brexit deal, 24 September 2018

412 GOV.UK How to prepare if the UK leaves the EU with no deal collection of guidance, [accessed 22 January 2019]

413 Rt Hon Michael Gove MP, Address to Oxford Farming Conference, 3 January 2019

414 GOV.UK, Secretary of State Dominic Raab’s speech on no deal planning, 23 August 2018

imported from the EU and 20% from the rest of the world. He confirmed that there were no plans to deploy the army to maintain food supplies and played down the likelihood of the EU not offering some kind of mutual recognition in this area in a ‘no deal’ scenario: “Who is credibly suggesting, in a no deal scenario, that the EU would not want to continue to sell food to UK consumers?”

None the less, a number of food industry companies said they were stockpiling supplies in case of no deal.416 The British Retail Consortium has expressed concerns about the practicalities: 417

Stockpiling of food is not a practical response to a no-deal on Brexit and industry has not been approached by Government to begin planning for this. Retailers do not have the facilities to house stockpiled goods and in the case of fresh produce, it is simply not possible to do so. Our food supply chains are extremely fragile and this is yet further demonstration of the need for an agreement on the backstop to ensure frictionless trade is maintained after the 29 March 2019 (may also apply to new exit date on 31 December 2020).

The extent of any disruption at ports will in part depend on EU Member State preparations – to put in place Border Inspection Posts capable of undertaking checks on food imports from the UK at French ports, for example. The French Government triggered a no-deal plan on 17 January 2019. This included an Ordinance to “enable the emergency construction of the necessary infrastructure for restoring border checks (for customs, sanitary and phytosanitary standards, goods and people)”.418 Some €50 million (£44 million) would be invested in ports and airports, focusing on “control points and parking areas”, with the possible appointment of 580 customs and veterinary staff.419

Price impacts

On prices, Defra Secretary Michael Gove told the Oxford Farming Conference in January 2018 that the costs imposed by tariffs ( for example those above 40% on beef and sheep meat) would exceed any adjustments in currency markets. Although this could make exports more competitive, it also would “feed inflationary pressures at home”.420

The Federation of Wholesale Distributors has cautioned that without a trade agreement, the food and drink wholesale distribution sector will face upward pressure on their suppliers’ prices.421The Food and Drink Federation reported in October 2018 that 38% of surveyed members

415 Ibid

416 See also for example, The Grocer, Stockpiling begins among food suppliers as Brexit approaches, 14 September 2018

417 British Retail Consortium media statement, Stockpiling of food is not a practical response to a no-deal on Brexit, 26 July 2018

418 French Government press notice, France triggers contingency plan in the event of no-deal Brexit, 17 January 2019

419 Ibid

420 Rt Hon Michael Gove MP, Address to Oxford Farming Conference, 3 January 2019

421 FWD, Brexit: Current issues [as viewed on 26 July 2018]

reported increases in costs as a result of stockpiling supplies in preparation for any no deal Brexit.422

The British Poultry Council said on 21 January 2019 that increases in the cost of production could, in a “worst case no-deal scenario” lead to the price of chicken breast meat rising by 25%.423

Dairy UK has said that the worst outcome from the Brexit negotiations would be for trade with the EU to be based only on WTO rules. This is because the tariffs for dairy products in the EU’s WTO Most Favoured Nation (MFN) tariff schedule are “prohibitively high” in order to prevent the import of dairy products into the EU. Working to the WTO schedule, in the absence of another agreement, would make EU dairy imports into the UK much more expensive, which would impact on UK wholesale prices.424

10.5 Agri-food sector concerns

The potential longer-term impacts of a ‘no deal’ scenario vary widely by commodity and sector of the food chain and will also depend on the decisions made on applying tariffs under WTO schedules. This is because some agricultural sectors, such as sheep farmers, export far more produce to the EU than other sectors. Under WTO schedules, tariffs for many agricultural products are high – averaging more than 11% but considerably higher for many products.425 However, sectors could face competition from non-EU countries if the UK applied low or no tariffs, as the UK would have to apply the same tariffs to non-EU imports as to EU imports under WTO non-discrimination (‘Most Favoured Nation’) rules.

A joint letter to all MPs on 10 January from four farming organisations (the NFU, NFU Cymru, NFU Scotland and the Ulster Farmers’ Union) warned that ‘no deal’ could result in “huge disruption” as a result of “an effective trade embargo on the export of animal and animal-based products. The letter added that no deal could lead to:

Affected sectors facing particularly high customs tariffs on exports. For example, the effective EU tariff would be 65% on beef, 46% on lamb and 27% on chicken.

Impacts on UK production as a result of the government potentially choosing to unilaterally lower the UK’s import tariffs to control food price inflation, resulting in the UK market being open to imports of food produced to standards lower than that produced here by UK farmers.426

422 Food and Drink Federation news article, More than a third of food and drink manufacturers facing increased costs as a result of ‘no-deal’ Brexit stockpiling, 30 October 2018

423 British Poultry Council Press Release, No-deal Brexit worst case for affordability and availability of British food, 21 January 2019

424 Dairy UK. The White Paper, October 2017, p.7

425 The average EU tariff on agricultural goods was 11.1% in 2016 compared with 4.2% for non-agricultural goods. The average EU tariff on dairy products is over 30% and on sugars and confectionery over 20%. Some individual products have tariffs over 100%. [Source: WTO, World Tariff Profiles 2017, p81

426 NFU Online, UK farming industry urges MPs to take action to avoid no-deal Brexit, 10 January 2019

Scenario modelling by the Agriculture and Horticulture Development Board (AHDB)427 and the NFU428 have shown the lamb and beef sectors to be potentially two of the most vulnerable UK sectors post-Brexit overall. In particular, the sectors’ prospects suffer if there is no comprehensive trade deal with the EU that maintains similar tariffs to now, and if subsidies are reduced or removed. A variety of sector reports are available at https://ahdb.org.uk/brexit/.

A 2016 analysis commissioned by the NFU looking at a range of potential Brexit trade scenarios (including trading on WTO rules) and farm support levels found that, for most sectors, the biggest driver of UK farm income changes was the level of public support payments available. The loss of these support payments offset positive price impacts in all of the potential Brexit trading scenarios examined.

The British Poultry Council has said that:

A no-deal Brexit would be incredibly damaging for our sector, for our ability to trade, for our workforce and for British consumers of poultry meat. We directly employ 38,000 people up and down the country, 60% of our workforce are EU nationals. Britain could risk losing the EU nationals employed by our sector, the £5bn Gross Value Added we contribute to the economy and the £1bn in tax revenue we generate.

Almost three quarters of our imports (£2bn/year) and exports (£500m/year) are with the EU – ensuring a continuation of trade with that market is essential. We are concerned that leaving with no-deal could effectively result in a trade embargo; in the import of products produced to lower standards; and in export tariffs being imposed on poultry meat that goes to the EU (27% increase on chicken).429

427 NFU online, NFU and AHDB team up for Brexit Roadshows, 25 October 2017

428 NFU Online, British Agriculture: The implications of a UK Exit from the EU – Summary of a study by the LEI Wageningen UR for the NFU of England and Wales, April 2016

429 British Poultry Council Press Release, No-deal Brexit worst case for affordability and availability of British food, 21 January 2019

158 What if there’s no Brexit deal?

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