Written evidence submitted by Hospitality Ulster (NIP0017)

 

 

NI Affairs Committee on Brexit Impact for NI Business

 

 

 

The main focus of businesses throughout the food supply chain is to create and implement systems and processes to ensure the most efficient and effective methods of continued food supply in NI, and as such the following issues have been seen in the run up to and since the implementation of the Protocol.

 

The finalising of the “Deal” and implementation of the protocol so late in the day before the festive period has caused a number of issues within the supply chain especially for “fresh food product” suppliers. The reluctance of suppliers to adapt processes in readiness for the Protocol has led to a number of challenges within the industry, which are still being felt now some 4 weeks into the new process. Recent weeks have shown this to be the case with GB suppliers in particular.

 

The uncertainty of what exactly was required by suppliers and the lack of guidance in time to implement required changes prior to the 1st January has meant that certain GB suppliers have stopped NI supply which in turn has caused availability issues within the NI markets as suitable product alternatives needed to be sourced from the Island of Ireland at relatively short notice.

 

The industry has experienced delays in product deliveries due to paperwork checks at Ports, sometimes up to 2 -3 days product shelf life loss – this in turn can cause further problems down the supply chain when product is dispatched out of warehouse to retail shelves as consumers have come to expect longer shelf life. Business systems which operate “Just in time” deliveries have experienced product shortages due to these delays.

 

Another significant impact caused by the implementation of the protocol was that the availability of “Groupage Transport” effectively disappeared overnight due to implications caused by seals, sign off and additional paperwork requirements being too detailed for many smaller product suppliers to deal with. The costs associated with product supply via non - groupage methods have meant that smaller product suppliers have been priced out of the supply chain and in turn meant that there could have been product shortages on the shelves had Wholesale Businesses not stock piled products prior to the Festive period.

 

Businesses have experienced challenges to service levels, with an average of up to 12% decrease in service level when compared against the same period last year. This significant decrease of service level could have proved catastrophic to the Retail industry leaving empty shelves had businesses not stock piled products before the implementation of the protocol, with ambient products being hit the hardest as priority at Ports is being given to fresh and frozen foods. Only due to diligent planning prior to and throughout the implementation of the protocol have businesses been able to maintain their outbound service levels at levels similar to that of the same time period last year.

 

 

 

 

 

The end of the “grace period” will no doubt cause further delays in the food supply chain with loads being held up at Ports due to paperwork issues and further, more in-depth product inspections being carried out at Point of entry to NI. Further delays in the supply chain process will not only result in more product wastage due to shortening of shelf life due to processing issues and delivery vehicles being held up at ports, but it will also affect product pricing, as the cost of implementing the required changes and processing of certificates etc will need to be recouped by the supplier therefore it will inevitably end up with the consumer footing the bill as per example below:

 

Ware potatoes from GB are subject to phytosanitary and plant health documentation. This is slowing down the supply chain considerably, loads are taking several days to receive the green light from TTS. Due to this delay, when moving potatoes, a much longer timescale must be factored in from ordering to arrival. Currently due to the 'Grace Period' there are no extra costs. From 1st April when this ends there will be an additional cost of £150 per load for this documentation which equates to approximately £5 per ton.

 

Another example of increasing costs, now includes additional charges in relation to suppliers having to provide heat treated pallets and additional labelling to satisfy legislative requirements this can add up to an additional £40 per pallet of goods ordered. These additional charges are currently being described as transitional costs to cover the rework of current stocked items, therefore it is likely that a deduction in additional charges will occur in the coming months when stocks deplete and are replaced with fresh stock.

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With the added tariffs now being applied to certain product ranges being imported from GB from alternative origins, NI consumers will see price rises on their everyday grocery items. Industry officials are currently looking at ways to ensure that additional costs passed on to end consumers are kept to a minimum to ensure competitive pricing within the retail environment, but ultimately the additional costs need to be recouped to ensure the supply chain is maintained at financially viable levels.

 

 

As was evident in the first few days of the Protocol implementation lack of training and awareness caused a number of teething problems, within an already fragile nervous industry, questions are being asked as to what plans government departments have in place to prevent such issues arising again when the “Grace Period” ends on the 1st April.

 

As there has been a zero-tolerance approach to errors on critical paperwork – this has led to hold ups at Ports to allow the errors to be rectified. Those which have not been able to be rectified have seen loads rejected for sailing or held so long that the shelf life reduction of products has deemed them unfit to delivery.

 

Availability of resources could lead to further issues down the line – with limited numbers of trained professionals within the food industry, which could in turn see shortfalls in production with Technical Staff from the industry being recruited to facilitate checks at ports. This point also relates to Environmental Health Office staff and Vetinary Officers.

 

In preparation of the supply chain facing more issues with delays at Ports due to paperwork checks, suppliers have already started to investigate and implement changes in their processes to enable them to streamline the overall flow of goods. One such change which has been felt by consumers in NI since 1st January is that product ranges in retail stores have reduced significantly limiting customer choice. This reduction in product range has been implemented to limit the effect of product unavailability being passed on to the consumer and prevent chaos within the retail sector caused by consumer panic buying.

 

 

 

 

Supply chains are still adapting!! Most of the adaptations come within the route to market. Supply chain models have had to change where possible from the “Just in Time” model to a more contingency method where product is sourced and stored weeks in advance to avoid disruption to supply. Obviously, this change in process can only be applied to certain sectors of the Food Supply Chain – such as Ambient and Frozen products. Fresh Food products which cannot be sourced and stored weeks in advance are a different matter and have meant that businesses have had to rethink their supply chain. Some businesses pre-empted the disruption which has ensued at the ports over the recent weeks and prior to the Protocol being implemented had switched the majority of their fresh product supplier to the Island of Ireland supply where possible, or at the very least, have a contingency supply agreement in place with ROI suppliers for products currently sourced from GB. Direct shipment of loads from the Continent to ROI on existing routes and through brand new routes have seen a significant increase in recent weeks as businesses are trying to redirect the supply chain to avoid traveling through GB where at all possible, as a method of stream lining and simplifying the delivery process.

 

Businesses have also proactively sought out new product ordering processes in order to limit effects on their supply chain – examples of these changes include streamlining product varieties to ensure continuity of supply. As a method of deflecting, and passing associated increased costs on to end consumers, suppliers and wholesalers have implemented changes to ordering quantities and frequencies. For example, wholesalers who previously have provided two deliveries per week have altered their lead times, increased their minimum order quantity to try and limit the need to have Vets on their site to sign off consignments thus saving on administration and governance costs. NI Businesses where possible have increased stock holding to limit the risk of product shortage, this in itself, can cause businesses further issues, as it directly effects cash flow and available funds for other products. Unfortunately, this step is not one available to all NI businesses as most smaller companies do not have either the additional storage space or the resources available.

 

 

              Collectively across the supply base, businesses are requesting that ongoing funding be               provided for suppliers who now need to pay for Phyto certs, this would ensure that small GB               suppliers don’t stop dealing with NI due to increased documentation costs and any other               costs associated with GB to NI Trade.

 

              Businesses across the UK are asking that more clarity and awareness to be provided with               regards to whose obligation it is to complete clearance documentation on the TSS portal, as               to date guidance has been vague and has left a level of ambiguity whether the haulier or end               trader complete this paperwork.

 

Some Businesses are calling for the “Grace Period” to be extended to allow more time to create and implement more stringent workable solutions for all issues the supply chain is facing.

 

              Decisions need to be made and process changes implemented on rules around groupage to               allow this vital service to remain viable within the industry. An industry without straight               forward groupage transport processes will see a large amount of smaller bespoke product               suppliers close their doors to trading with NI.

 

              Calls for concise guidance on Computerised Operating Systems have been echoed across the               industry, with particular concerns being noted regarding the contingency process should               systems such as TSS and GVMS crash and what load tests and other checks are being               completed to ensure that the systems are fit for purpose, come 1 Apr.

 

Throughout the industry communication channels and working groups have been created to ensure that there is a collective shared knowledge base to enable a proactive combined approach to problem solving across all aspects of the supply chain. This shared knowledge base will continue to function in the months ahead, though calls from across the working groups reiterate the need for additional government support and guidance to bolster the working knowledge base.

 

Industry representatives are calling for clear and timely guidance regarding training on new systems and processes being implemented by Government to allow individual businesses throughout the industry to adapt and upskill staff in a timely manner in order to prevent a repeat in further delays and noncompliance issues, at the end of the “grace period”.

 

In conclusion the consensus across local business is that the best outcome for the overall supply chain would be the implementation of a digital solution (from source to shelf) covering the logistical and technical requirements for ensuring compliance to the legislative requirements. This would ensure a more effective and efficient process throughout the supply chain and limit the costs and burden to the industry of what currently is a complicated process, while helping create a frictionless goods movement process, and maintain availability and price of food products across the NI market.

 

February 2021

                           

Annex A: Hospitality Ulster briefing paper: Brexit- Making the NI Protocol work for our Foodservice Supply Chain

 

Updated 3rd February 2021

 

Hospitality Ulster is the professional body supporting the Hospitality Industry and its supply chain in Northern Ireland.

The Hospitality Industry in Northern Ireland sustains c.65, 000 jobs, has a turnover of c£2bn and forms the backbone of the developing Tourism offering in Northern Ireland.

 

With our foodservice supply chain directly employing c2,500 people, generating £1bn of sales and supplying thousands of hospitality businesses across Northern Ireland, it is both an integral part of the hospitality industry and an important economic asset to the Northern Ireland economy.

 

With the Brexit transition period now over and the ‘soft touch’ period rapidly coming to an end, there are now serious concerns at the continuing challenges being experienced with the Great Britain to Northern Ireland supply chain post January 1st 2021. 

 

At present, our foodservice supply chain is experiencing difficulties with the required paperwork and delays at our ports; which if not resolved could have serious consequences for the future functioning of the sector. It must be noted that these are real problems that will result in major disruption to the foodservice supply chain if left unresolved.

 

This paper sets out key challenges and provides constructive solutions to ensure the sustainable operation of our foodservice supply chain whilst procedures/regulations are refined and developed within the NI protocol.

 

  1. GB businesses supplying into Northern Ireland

The NI supply chain businesses have been preparing for Brexit for years, contingency planning based on either a ‘Deal’ or a ‘No Deal’ being agreed between the UK and EU.  Although we were pleased that a deal was agreed between the UK and EU before Christmas, it has not left adequate time for businesses to prepare for the consequences.

 

As a result, we have experienced severe supply chain disruption from GB with loads not getting through and/or being detained due to insufficient or missing paperwork.- resulting from the fact that GB suppliers are not ready and require further support.

 

Hospitality Ulster believes that HMRC/DAERA urgently need to provide expert support to GB suppliers and their agents 7 days a week to help businesses that are struggling to complete customs and SPS import requirements.  This will allow faster resolution of some of the issues and improve capability.   

 

  1. Grace Period

From the 1st April, at the end of this three-month grace period, full Export Health Certificates (EHCs) per product will be required. Currently, for prohibited and restricted goods, EHCs are per container level, this changes on 25th January and again in mid-February before full EHCs are required from 1st April. This is an unmanageable scenario and changes will be needed to ensure the continued flow of goods

 

With the majority of the hospitality sector currently in Covid lockdown, the grace period will have expired before the normal level of trade resumes and significantly magnifies the current challenges.

Hospitality Ulster believes that an extension of the three-month grace period to twelve months is required to afford adequate time to refine the processes and give businesses adequate time to develop systems that facilitate the movement of goods within the NI Protocol. This must not be used to ‘kick the can down the road’!

  1. Ensuring a level Playing Field:

We are thankful of the three-month grace period which has been agreed via the Authorised Trader status.  However, this only works in respect of goods classified as not at risk, i.e. not at risk of onward supply to the EU.  The majority of NI’s foodservice supply chain also have an ROI customer base.  Indeed supplying parts of ROI, like Donegal is not commercially viable if supplied from depots in ROI.

 

Hospitality Ulster believes it is essential that after the temporary authorisation period that Authorised Trader status will continue to apply to Northern Ireland wholesalers and supermarkets. It is also vital that a solution to facilitate the continued sale of goods to the ROI customer base is developed within the NI Protocol as a matter of urgency.

 

  1. Conclusion

Hospitality Ulster calls on the UK Government & European Union to facilitate the continued operation of our foodservice supply chain, whilst procedures and regulations within the NI Protocol are refined/amended.

 

We believe extending the grace period to twelve months and providing additional support to GB suppliers would allow time for the establishment of the Joint Consultative Working Group. The working group could then properly examine the challenges to the sustainable operation of our GB – NI supply chain; developing solutions that do not place the EU single market at risk or impose unworkable regulatory barriers to GB – NI trade.