Exporting Recreational Fishing Bait to the EU: achieving continuity & growth

We are writing to you on a subject of critical importance to a significant part of the recreational angling business in the United Kingdom and associated industries because there are recreational angling bait manufacturers in your constituency and there may be local jobs at stake for your voters.

The bulk of this letter has gone to Ministers and with your support there is a good chance that together we can secures jobs and livelihoods amongst your electorate.                             

It has come to our attention that UK companies in the recreational fishing bait sector are facing major barriers to exporting to their established markets in the EU, threatening current sales channels, future growth opportunities and manufacturing jobs and profits in the UK. 

The Angling Trades Association represents a number of leading companies in this sector, including the manufacturers of key British brands of fishing bait products for the recreational angling market.

A number of these companies are working directly with the Angling Trades Association in seeking to engage with relevant government departments, particularly at Defra, to assist in overcoming the barriers to export into the EU for UK manufacturers since January 1^st 2021.   

Context

• UK brands in the recreational angling bait sector together provide over 500 UK jobs and represent more than £30 million of annual export turnover into the EU.

• The bait sector is an important and interlinked part of the wider multi-billion £ angling trade that includes tackle manufacture and supply and angling tourism, all of which provide valuable export revenues for UK industry.

• British bait manufacturers have identified the EU as open for considerable future export growth with excellent opportunities for market-leading brands from the UK, providing that smooth EU market access can be maintained.

• Bait manufacturing companies operate under the UK Feed Hygiene Regulations and the Animal By-Product Regulations which currently in the UK still reflect EU Regulations, and consider effective but proportionate Sanitary and Phytosanitary (SPS) controls to be necessary and important for safeguarding UK/EU trade, food/feed safety and bio-security.

• The threats and potential for missed export opportunities outlined here are common to the major companies in the UK-based bait industry.

The UK EU Trade and Cooperation Agreement – impact on EU sales

UK exporters in the recreational bait sector face immediate challenges resulting from the new trading arrangements with the EU.

• Full customs Sanitary and Phytosanitary (SPS) controls now apply to commercial exports of recreational fishing baits containing processed animal by-products moving between the UK and EU (and, from April 2021, between the EU and UK).

• Businesses operating in this sector are unable to obtain clear, practical and accurate information from UK authorities as to the precise requirements for exporting to the EU and are experiencing serious difficulties in acquiring information from EU sources.    

• These non-tariff barriers present impediments to export success in a UK business sector composed primarily of SMEs.  New certification requirements are onerous, time consuming, and therefore costly, with the proposed documentation not reflecting the nature of sector’s products, their production processes or the food/feed safety risks they present. This is because:

• These products are not intended for use for fish entering the human food chain and are for use in ‘catch and release’ recreational angling scenarios.
• These products are manufactured by SME’s in the UK and EU in small production batches and are often ‘made to order’.
• UK manufacturers have large ranges of specialist products in consumer-ready packs produced from a similar range of input materials, many of which originate from the EU in the first place.
• The level of microbiological testing required for certification of these commercial exports is impractical, given their product and production profiles.  
• When an Export Health Certificate (EHC) is required, there is not currently a relevant template document available specifically for the export of recreational fishing bait from the UK to the EU or from the EU to the UK which accurately reflects the products and their associated risk.
• Export Health Certificate 8333 for Processed Animal Protein, proposed to members for adoption by DEFRA, has unworkable microbiology testing requirements. These are as follows:
• The current testing requirement is for 10 separate microbiological test results for every product in a consignment.
• For example, if an exporter ships 1 pallet containing 40 different bait products (not destined for the human food/feed chain) 400 tests are needed.
• Conversely an exporter shipping 26 tonnes of fish meal (one large consignment, single product, extensive food/feed chain exposure) would be required to carry out 10 tests.
• Contrasting these scenarios, comparable testing costs are:
• Fish Meal shipment – 26 pallets (1 product, possible shipment value £39,000) = testing £65
• Recreational Bait shipment – 1 pallet (40 products, possible shipment value £2500) = testing £2600

• Inspection, testing and certification by an Official Veterinarian (OV) costs approximately £130 per visit, adding to operational business costs. This is prohibitive for regular direct exporting of B2B consignments, and wholly non-viable for B2C exports.

• Currently there is a shortage of Official Veterinarians meaning inspections are not conducted in a timely manner, impacting delivery timescales, contractual commitments, and weakening the reputation of our business and its UK counterparts in this sector. Testing and certification requirements add 10-14 days to the delivery time. EU customers will not accept this. Pre the Trade and Cooperation Agreement (TCA), clients received consignments within 3-5 days from ordering.

The way forward

To protect current UK exports to the EU and exploit sector sales growth opportunities for our businesses and members, it is essential that workable SPS controls are instituted for recreational fishing bait supplies. We propose:

• Relevant UK authorities (Defra) work closely with the ATA, UK exporters, EU-based competent authorities and importers to agree and communicate simple, clear and workable conditions and/or documentary requirements for UK bait products to be exported into the EU.

• Where an EHC is required by EU importers, the creation of a bespoke EHC (potentially an amended version of 8333EHC if appropriate) and the development of accompanying ‘Notes for Guidance’ for exporters and OVs, detailing clear, workable requirements commensurate with the risks posed by recreational bait products in the non-food chain sector. This would recognise a reduced need in the level of product testing required for multi-Stock Keeping Unit (SKU) consignments.

• In the longer term, where an EHC is required, the creation of a proportionate and practical recreational bait-specific EHC for baits containing Animal Based Products with defined ingredient restrictions and workable testing requirements (for example based on routine establishment testing and/or aggregate sample testing);

• Measures are improved to accept baits manufactured by establishments approved for export between the UK/EU, who can then be certified to ship across the UK/EU border (identified by TRACES number);

• The requirement for manufacturing/production sites to be registered and audited under the relevant UK/EU Feed Hygiene and Animal By-Product regulations, with registration numbers to be included on any EHC.

Through the introduction of proportionate and workable certification measures, the UK Government would facilitate the growth of recreational bait exports to the EU. This would benefit sector SME’s enabling them to service the existing and growing angling community, stimulating jobs and economic growth opportunities.

Conversely failure to act will result in UK job losses, downsizing of businesses, reduction in UK GDP and tax take, and probably the movement of businesses out of the UK into the EU.

The measures proposed are considered, practical, and with support could easily be implemented at limited cost to UK institutions and Government departments.

The ATA would welcome the opportunity to discuss this proposal in detail and would be happy to work with you and policy officials to drive and implement change which will lead to the ongoing success of UK SME’s, and our continuing success as an export nation.