Responding to today, planning for tomorrow

This article was published in TCS&D Magazine February/March 2021

The road to the Brexit withdrawal period ending on 1^st January 2021 has been long, at times contentious and frequently gruelling for us all. At the Cold Chain Federation we’ve spent years seeking clarity on changes to regulations, influencing new policy, studying the extensive but incomplete and last minute guidance, anticipating and highlighting areas of concern, and providing advice to our members on how to prepare for an eventuality that was constantly evolving. This work continues hour by hour, in support of the resilient and dedicated cold chain professionals valiantly battling to keep the nation’s food moving in the midst of the dual challenges of Brexit and Covid.

A clear picture of what the UK’s new post-Brexit relationship with the EU will really mean for the cold chain either in the coming months or in the longer term, is still some way off. Although the worst-case scenario of No Deal thankfully never came to pass, storage facilities, hauliers and their customers are still faced with significant disruption and permanent change. The visual of lorries queueing for miles at Dover on 1^st January was avoided because businesses sensibly reduced planned journeys but even with low numbers being sent to ports, goods vehicles travelling from the UK to the EU and to Northern Ireland are being held up and turned back on a daily basis.

Common reasons for disruption include pre-notification on the EU’s food imports system (TRACES) not completed, the driver not being able to produce a paper copy of the required Export Health Certificate or scanning the wrong barcode, and typos in the EORI number. When the new rules are enforced on goods imported into the UK too in the spring, there will be a raft of new challenges with which to contend.

I hope that, in time, the current uncertainties and disruptions will be followed by new opportunities, new relationships and innovation. But in the meantime, we must respond to the fact that many of operative models we relied on just a few weeks ago for the movement of temperature-controlled goods to the EU and Northern Ireland, must change. This is particularly a shock for our customer base, many food exporters believed politicians when they said we would have frictionless trade and to the last assumed the deal would remove the need for paperwork. Now many are going through something akin to the stages of grief. I know cold chain businesses have been on the receiving end of anger, denial, and depressed inertia from their customer base. As we get further into the year, it is the businesses which have already reached acceptance which will be the quickest to get on the front foot with post-Brexit requirements and realities.

An immediate and crucial change for logistics businesses is the need to know the INCOTERMS for each and every consignment going to the EU. INCOTERMS, not previously required for UK-EU trade, set out whether the buyer or the seller is responsible for the completion of each export or import requirement and associated paperwork. Not only does the haulier need to know where to access the information needed to fulfil their own requirements and paperwork, knowledge of a consignment’s INCOTERMS is particularly important to resolve disruption for a driver that has been caused by an error in a buyer or seller’s paperwork.

A likely cultural change for our industry, at least in the short term, will be the loss of flexibility to respond to live information once a vehicle has begun its journey. New paperwork needs to be completed in advance of a consignment leaving its depot, and it is without a doubt advantageous now for some documents to be sent to customs agents in advance. Changing a vehicle’s destination, for example, after the documentation has been completed will most likely result in the driver being held at port until the paperwork is corrected, or being turned away.

But as the new rules and requirements bed in, the Cold Chain Federation along with our colleagues representing other industries affected by these changes, are working hard to find solutions to challenges as we go. Groupage is a prime example – at time of writing, vehicles containing meat and dairy goods from multiple customers are being emptied by health authorities at EU ports so that each pallet can be checked against the relevant, separate paperwork. The risk of disruption and delay is very high. Trials for better approaches are underway, such as sealing the vehicles or the pallets after they have been signed off by the Official Veterinarian, for the seal to be checked at EU ports rather than the goods themselves. 

As businesses focus on managing the enormous changes they are experiencing, the Cold Chain Federation is working hard to keep Ministers honest on the medium and longer-term outlooks too. The UK’s post-Brexit trade strategy seems to be very thin at the moment. Having left the trading bloc of the EU, managing our trade is now a core job of our Government. From today, helping businesses trade needs to be a key responsibility of every Government Department but as yet we have heard very little about how UK food businesses will be supported in the context of new trade relationships.

I hope that soon in 2021 we will be into a ‘building back better’ phase, having survived the worst of Covid alongside the early Brexit challenges. Be assured that the Cold Chain Federation is making the case to Ministers that they need to have a clear and shrewd trade strategy and, crucially, they need to tell us what that plan is.

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