Aviagen UK Ltd (PAB0003)

Introduction

1. Aviagen welcomes the opportunity to provide written evidence to the Committee’s inquiry on this matter. A common approach to biosecurity across the EU, and increasingly at a global level, is vitally important to the global food supply chain and how Aviagen trades.

2. Aviagen is a world leading poultry breeder with a significant research and development operation in the UK supplying domestic and international broiler (chicken meat) producing customers across the EU and 130 countries worldwide. Our turnover in the UK is £180 million and we employ over 900 staff.

3. Approximately 50% of all chicken and turkeys consumed globally are derived from Aviagen’s UK breeding stock.

4. Aviagen’s main chicken EU operations and global R&D HQ are based in Newbridge, just outside Edinburgh and our UK hatchery, from where its chicks are distributed globally, is based in Stratford-upon-Avon – it is one of 13 Aviagen-owned hatcheries in Europe. Uniquely for Aviagen, its Stratford hatchery is the only one hatching multi-generation breeding stock and is a strategic part of its EU business as it supplies all its other EU based businesses. Aviagen’s main EU turkey operation is based near Chester.

The extent to which a common UK-EU approach to biosecurity will continue to be desirable post-Brexit

Our current trading arrangement

5. Aviagen UK sends millions of eggs and chicks to EU Member States, including France, Germany and Spain using the Trade Control and Expert System (TRACES) – in practice, this means no border controls, no tariffs, no hold-ups for livestock, based on reciprocal agreements. These agreements are outlined, in summary below:

• Aviagen requires approval to send hatching eggs (HE) and day-old chicks (DOCs) into the EU. This is governed by EC Regulation 798/20080.
• We use a system known as TRACES (Trade control & export system) for applying for veterinary health certificates for trade with the EU and also for trade travelling through the EU to third countries.
• Third country (Non-EU) imports are covered by EC Regulation 798/2008 & Council Directive 2009/158 EC - an annex of the Directive lists which third countries can export HE and DOCs into the EU.
• Chicks hatched from third country eggs in the EU must be taken to their final destination and kept there, in quarantine, for three weeks.   This final destination may be in another EU country.
• Imported DOCs from third countries must be isolated at a destination in EU for at least six weeks or three weeks (if extra disease testing is done at owner’s expense).

The Withdrawal Agreement

6. The Draft Withdrawal Agreement, published on the 19 March and subject to final agreement by the EU and UK by October 2018, includes measures to continue the current trading relationship outlined above during the transition period. Specifically, Article 37 (Continued circulation of goods placed on the market) includes reference to Chapter II of Council Directive 2009/158/EC of 30 November 2009 on animal health conditions governing intra-­‐Community trade in, and imports from third countries of, poultry and hatching eggs in Annex Y of the Agreement. We welcome this clarification from the UK and EC and look forward to its ratification later this year.

The future relationship; what we need

7. Once the transition period ends on 31 December 2020, the existing trading relationship will be subject to the ‘future relationship’ that is to be agreed between the UK and EU. At present Aviagen exports HEs from the UK to the other EU states to hatch.   The resultant chicks are sold in the EU and to third countries. Under EC Regulation 798/2008 there does not appear to be provision to import HEs from a listed third country, hatch them in the EU and send the chicks to a third country.    This has a significant impact on Aviagen’s business if this is not possible. Loss of trade as a non-EU country with the 3rd country restrictions on quarantining could reduce Aviagen’s business by 75%.

8. The UK will need to be recognised as a third-country under EC Regulation 798/2008 to ensure Member States will accept poultry (as DOC, HE or breeding poultry).  Only a limited number of countries are listed at present including Australia, New Zealand, USA & Canada.

9. Aviagen recognise that there is a module of TRACES that exists which is used by third countries. However, it has no experience using this module and since it needs to work the day after Brexit (Aviagen will have chicks in transit the very first day post Brexit) it will require a period of familiarisation to ensure everything works correctly from day one.

10. The UK government’s Customs White Paper, published last year does not take biosecurity matters into account. We note the two broad approaches outlined in the Future Partnerships Paper recently published by the Department for Exiting the European Union seeking either a ‘highly streamlined customs arrangement’ or a ‘new customs partnership’ with the EU. Neither scenario currently outlines how the UK would seek to ensure that control measures for animal health checks or disease notification will be recognised as part of any future customs arrangement. It is our opinion that these issues cannot be addressed separately, and UK government should outline its proposals as soon as possible.

11. As Aviagen is dealing with live chicks even a short delay could result in the loss of livestock and significant lost sales. Aviagen rely on being able to export chicks of different generations from its production base in the UK. In some cases this may require road transport to EU MS’s then air transport to final destinations, especially if non EU, all of which are time critical. It is therefore critical that the matters raised can be resolved so that its business can continue post Brexit.

The ways the UK and EU currently share biosecurity information, and whether these can be maintained

12. The other main area of concern, and where Aviagen is seeking assurance from government, is the impact of Brexit on phyto-sanitary and zoonotic disease measures. Today, Aviagen can continue to trade within the EU, even if the UK is Avian Influenza (AI) or Newcastle Disease (ND) positive, because EU Member States observe regionalisation rules under the auspices of the World Organisation for Animal Health (OIE).

13. In addition, because all EU Member States follow agreed common rules on the control of notifiable disease and all actions are communicated with the European Commission as soon as an outbreak occurs, regionalisation is granted almost immediately once control zones are set up by the UK. We seek assurance that third countries do not see the UK’s exit from the EU as diminishing its recognised status in this area. We also seek assurance that EU Member States will continue to recognise the UK and approve movements under regionalisation rules as expeditiously as occurs today.

14. This issue was highlighted to the Committee when it took evidence from the UK’s Chief Veterinary Officer, Prof Nigel Gibbens last year: “The other important thing is the framework that allows EU member states to recognise disease quickly and share knowledge about where a disease is and where it might have gone to, so our ability to trace, if you are in a very high-volume trading situation, is very important. Those systems that allow animal movements to be tracked to give traceability of animal products that might spread disease will be critical and we will need to adjust that for the future, operating outside of the EU but with a very important trading partner. I think there is a clear change there.”[i]

15. Aviagen in the UK was the first poultry breeding company to achieve companywide Compartment status recognised by a government body. Designed specifically for high generation poultry breeding stock, the scheme that Aviagen in the UK is a member of is the “GB Enhanced Standard” (GB = Great Britain).

16. Both Compartmentalisation and Regionalisation are important tools that give assurances on disease freedom for international trade purposes.

• Compartmentalisation is “a sub-population of animals which is not based on its location but rather on a common standard of biosecurity and management practices combined with a distinct health status which is monitored and controlled under a single management.”
• Regionalisation is “the recognition of geographical zones/regions of a country that can be identified and characterized by its absence of a specific disease(s). The region must be clearly and effectively delineated by natural, artificial or legal boundaries. The region must have common control policy for the specific disease.”

17. Where country freedom is required but Regionalisation is not accepted by a country, Compartmentalisation provides an alternative to enable continued supply of poultry breeding stock in times of a notifiable disease outbreak. The GB Enhanced Standard has been a collaborative effort developed in conjunction with the UK poultry breeding industry, with involvement from the British Poultry Council (BPC) and the Department for Environment Food and Rural Affairs (DEFRA), and with inspections carried out by Animal and Plant Health Agency (APHA) government veterinarians.

18. Compartmentalisation provides a mechanism for countries around the world to accept stock from an exporting country with an AI or ND outbreak by supplying the importing country’s officials with evidence that the stock is free from disease. The importing officials will have a high degree of confidence of the health status of the imported stock, as the biosecurity programme of Aviagen is sanctioned and audited by government veterinarians (DEFRA and APHA) and flocks are regularly monitored for AI.

19. Aviagen is therefore seeking assurances that as a ‘third country’ the UK will not only be able to continue to trade under regionalisation rules but that any future agreement between the UK and EU does not subject the UK to delays in regionalisation being granted and our present status being diminished.

11 April 2018