The long-delayed implementation of the next phase of the EU Brexit trade deal with Britain will deliver more costs for Irish exporters, with safety and security controls, and sanitary and phytosanitary controls at British borders applying to imports of live animals, germinal products, animal products, as well as plants and plant products.
Similar requirements were introduced in Ireland and the rest of the EU for British goods at the end of Brexit transition period in January 2021, and the British will now introduce theirs on a rolling basis from the end of next month.
Import customs declarations will have to be declared for goods imported directly from Ireland across the Irish Sea to Britain.
The new requirements will add significant new administrative burdens and costs particularly on Irish agri-food exporters, while hauliers will have to produce export health certificates for designated high and medium risk goods.
The British market remains very important for Ireland and accounted for almost €5.5bn in Irish food and drink exports last year.
CSO figures show the introduction of post-Brexit border controls at Irish ports led to a significant reduction in imports from Britain, because exporters had not done their preparations. It took a while for imports from Britain to bounce back.
We do not envisage a similar dramatic fallout for Irish exporters at the end of January, but everything possible must be done to plan for the British controls.
From an Irish exporter perspective, it is reasonable to query the readiness of the competent authorities to assist traders by issuing the required export health certificates in a timely and efficient manner.
The Department of Agriculture advises that "it is vital that businesses engage with their supervising competent authority to bring their certification ask within core business hours".
The volume of new export health certification will mean that the demand for these services will multiply, creating potential issues for dispatching goods.
Here's some idea of the complexities: A 24-hour pre-notification of imports from Ireland into Britain will have to be registered on the so-called UK Import of Products, Animals, Food and Feed System.
The registration has to be carried out by a British-based agent prior to the arrival of the goods at Irish ports, including Dublin or Rosslare which handle the bulk of Irish trade with Britain.
Moreover, hauliers will need to register for a Goods Vehicle Movement Service, with a Movement Reference Number in order to generate a Goods Movement Reference, or GMR, code.
And the people responsible for the loads are required to make import notifications for the movement of animal products into Britain from Ireland.
Hauliers will need to provide a GMR for all trucks and trailers moving directly from Ireland.
Ferry operators in Dublin and Rosslare have been advised not to allow trucks to board ferries moving from Ireland to Britain without a valid GMR. That means that unless drivers have received customs clearance they will not be released from the port.
It is not expected that the additional costs will deter potential export growth but it still presents some challenges. The most important issue for business is certainty of the rules and that when implemented that there will be a level playing field.
Irelands’ exporters are well placed to be prepared for the changes, albeit they know that after so many false starts, there is a certain air of apathy within supply chains about the new requirements.
It is prudent for all businesses in the export of agri-foods to ensure they are suitably prepared and attend webinars hosted by the Department of Agriculture and by others to understand the classification of high, medium, or low-risk goods.
Firms will also have to know who is responsible for registering the export details on the British system that generate the GMR numbers for hauliers to board the British-bound ferry.
Brexit is continuing to deliver red tape and additional costs that will ultimately be paid for by the consumer, but at the heart of the UK-EU Trade and Cooperation Agreement is the pledge to develop a meaningful relationship to help reduce the need for even more checks at British and EU ports.