Written evidence from British Veterinary Association (UKJ0012)
1) The British Veterinary Association (BVA) is the national representative body for the veterinary profession in the United Kingdom. With over 18,000 members, our primary aim is to represent, support and champion the interests of the United Kingdom’s veterinary profession. We therefore take a keen interest in all issues affecting the profession, including animal health and welfare, public health, regulatory issues and employment matters.
2) We welcome the opportunity to provide evidence in relating to the UK/Japan Comprehensive Economic Partnership Agreement (CEPA). This treaty was presented to Parliament in October 2020.
3) Agreeing a comprehensive free trade agreement (FTA) with Japan has been a priority for the UK as we leave the current transition period and lose the benefits of the EU-Japan Economic Partnership Agreement. Therefore, securing this new trade deal with Japan that maintains reduced tariff barriers and a simplification of Sanitary and Phytosanitary (SPS) barriers offers an opportunity for the export of UK products of animal origin (POAO).
Engagement with the veterinary profession
4) Veterinary surgeons deploy their expertise across domestic food production, from farm to fork, ensuring UK production meets the highest standards of animal health, animal welfare and food safety. They also play a unique role in international trade which is recognised around the world. The involvement of veterinary surgeons protects public health, food safety and animal health and welfare as well as providing assurance to trading partners.
5) FTAs contain provisions relating to animal health, animal welfare and public health: areas which fall within the expertise of the veterinary profession. It is therefore disappointing that no consultation with the veterinary profession was undertaken by the UK government as it completed the CEPA.
6) This FTA has highlighted the need for genuine veterinary input into future trade negotiations. As the UK continues to strike new trade deals with partners around the world, which will have consequences for animal health, animal welfare and public, we would ask that the Department for International Trade reflect on how better to engage the relevant profession.
7) BVA has welcomed the announcement by Government that it will place the Trade and Agriculture Commission (TAC) on a statutory footing. It is essential that this strengthened body draws upon veterinary expertise to scrutinise future trade deals and put animal health and welfare at the centre of decision making.
Sanitary and Phytosanitary (SPS) measures
8) Imports of both animals and animal products may carry pathogens that can represent a threat to UK public health and the health of animal populations. Sanitary and phytosanitary (SPS) measures are those measures to protect humans, animals, and plants from diseases, pests, or contaminants. SPS measures form a vital part of the UK’s biosecurity framework and should not be seen solely as a barrier to trade that needs to be overcome. In the broadest sense, biosecurity can be said to cover every aspect of disease control, prevention and treatment, all of which are areas that rely upon the knowledge and skill of veterinary professionals.
9) The great majority of new free trade agreements (FTAs) now contain provisions seeking to reduce friction caused by sanitary and phytosanitary (SPS) trade barriers. SPS issues have often taken centre stage in the most recent and wide-ranging trade agreements, such as the EU–Canada Comprehensive Economic and Trade Agreement (CETA), the 11-party Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) or the abortive EU–US Transatlantic Trade and Investment Partnership (TTIP).
10) The EU-Japan Economic Partnership Agreement deal includes an SPS chapter which seeks to simplify the Sanitary and Phytosanitary processes on trade between the two markets. CEPA includes an SPS chapter which largely replicates that found within the EU-Japan Economic Partnership Agreement. We welcome the maintenance of these benefits for UK agriculture and aquaculture which export to Japan.
11) This deal will provide continuing opportunities outside of formal trade negotiations to simplify SPS requirements or remove barriers. This work is often technical and requires professional knowledge, hence the importance of veterinary surgeons within the trade sphere. The inclusion of veterinary surgeons as part of trade negotiation teams, trade missions, and within embassies is the norm for many of our trading partners, and as such the UK should bolster its trade personnel with veterinary expertise. As veterinary surgeons deploy their expertise from farm to fork, ensuring UK production meets high standards of animal health, animal welfare and food safety, they are able to provide an unparalleled level of assurance to trading partners.
12) To support cooperation on SPS barriers under the FTA, the UK Government should develop a process whereby vets, farmers and processors are engaged to identify unnecessary SPS barriers. This could form a key component of the UK’s ongoing cooperation with Japan on SPS barriers.
Veterinary capacity to meet certification demand
13) Vets work to both certify and supervise the import and export of animals and animal products. The vital role of veterinary surgeons in trade, protecting public health, food safety and animal health and welfare is recognised around the world. In order to meet the opportunities afforded by international trade, the UK will require a veterinary workforce with the capability and capacity necessary to facilitate international trade both with the EU and other trade partners. To continue to trade, the UK must have enough appropriately trained Official Veterinarians (OV) to meet the additional demands for export and import certification. If that requirement is not fulfilled, it could present a significant barrier to trade and have a substantial impact on the farming and food sectors.
14) From January 2021, exporters will require an export health certificate (EHC) signed by an OV to transport animals, products of animal origin or germplasm from Great Britain to the EU Single Market and Northern Ireland. The OV signature attests that relevant public health and animal health requirements have been met. The requirement for EHCs will be similar if the UK and EU reach a free trade agreement, or if no trade deal is agreed. However, there are material uncertainties and limitations on knowing what the exact increase in export health certification is likely to be. When preparing for a no-deal exit in 2019, Defra’s “mid estimate” assumption was a fivefold increase in the number of EHCs.
Animal welfare standards
15) Veterinary surgeons, as qualified professionals who play an essential role in the operation of international trade, want to see a high standard of animal health, welfare and food hygiene prioritised within any trade negotiations and deals including with Japan. In our previous evidence we called for a free trade agreement with Japan to include an ambitious and comprehensive animal welfare chapter, including detailed provisions on animal welfare cooperation.
16) The relevant section of CEPA is quoted below.
1. The Parties will cooperate for their mutual benefit on matters of animal welfare with a focus on farmed animals with a view to improving the mutual understanding of their respective laws and regulations.
2. For that purpose, the Parties may adopt by mutual consent a working plan defining the priorities and categories of animals to be dealt with under this Article, and establish an Animal Welfare Technical Working Group to exchange information, expertise and experiences in the field of animal welfare and to explore the possibility of promoting further cooperation
17) This is less comprehensive than would have been expected and the commitment to animal welfare appears weaker the more the language is scrutinised. Of note is that the parties “may” adopt a working plan as opposed to “should” or “must”. Additionally, the scope of the technical working party is largely limited to sharing information and expertise.
18) The membership of this technical working group will be important. We would ask the UK government to consider the balance of expertise it proposes for the group. Defra, as the UK Government department with responsibility for animal welfare should lead on this process. The involvement of veterinary surgeons will be essential.
19) The latest figures show that Atlantic salmon exports to Japan were 1,060 tonnes, worth £8.7 million in the 12 months to October 2019, an annual increase of over 71.8%. Given this significant trade in fish between the two nations, fish welfare expertise would be beneficial to any group.
20) High animal welfare standards and high environmental standards reinforce the marketability of our produce. Within its trade policy, the UK Government should look to maximise opportunities to promote high-quality, high-welfare UK produce to export markets, including those products which might benefit from labelling that demonstrates region of origin (e.g. Scottish salmon, Welsh lamb and Yorkshire Wensleydale cheese). This can help secure opportunities for UK farmers and open up new export opportunities.
21) It is therefore welcome to see that the UK-Japan deal includes a new provision allowing more British products to receive protected recognition in Japan.