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International Meat Trade Association

IMTA

To represent particularly UK importers and exporters to the EU of meat with regard to EU policy and to aim to promote the need for international trade for the future benefit of all.

Lobbying Activity

Response to Rules for the uniform application of frequency rates for identity and physical checks

23 Sept 2019

The International Meat Trade Association (IMTA), based in the UK, has represented businesses engaged in the international meat trade since 1895. Currently we represent around 65 trading members (importers and exporters) and around 25 associate members, these are businesses who operate in relevant industries (e.g. customs agents/freight forwarders, shipping lines). Our trading members cover beef, lamb, pork and poultrymeat. Both our trading and associate members will be affected by the draft implementing regulation on establishing rules for the uniform application of frequency rates for identity checks and physical checks on certain consignments of animals and goods entering the Union. We welcome that the draft seeks to establish the frequency rates on physical checks depending on the risk posed. For instance, the new rate of physical checks on poultry meat is 30%, instead of 50% as it was previously. We very much welcome this as being more risk based, however we feel this could have gone further in terms of taking in to consideration consistent compliance. We welcome the risk based approach in bringing frequency rates for physical checks for beef, pigmeat and sheepmeat down to 15% in the moderate risk category from 20% previously. As well as bringing rates for poultrymeat products down to 15% from 50%, this is a significant improvement and much more proportional. Anything that allows more targeted checks means more effective use of resources. Being more risk based is positive but we feel the draft could have gone further in terms of being risk based, perhaps also allowing for lowering of rates based on consistent compliance. Article 4 point 1 says ‘The selection of the consignment for physical checks shall be carried out by the competent authority at random according to the frequency rates established in this Regulation and taking into account proposal by the information management system for official controls (IMSOC) referred to in Article 131 of Regulation (EU) 2017/625.’ From a previous draft we saw that ‘news notifications’ can be made in iRASFF which have informal sources, contain unverified information or concerns as yet unidentified products. We believe there should be clear criteria for verifying such news, to ensure they reflect the facts. We would urge part of the verification criteria to include contacting the country concerned to discuss the contents and to establish the facts. Article 4 point 2 says “Competent authorities may decide to select a different consignment for physical checks instead of the consignment of the same category and origin of goods selected in accordance with paragraph 1.” Can the Commission clarify what this means please? If the vet decides not to check a particular consignment, must they instead check a different consignment of the same category from the same country as the one they decided not to check? Article 5 point 2 includes ‘The Commission shall regularly review the frequency rates of physical checks’, we would like more clarity on what the basis of the review will be and how often the frequency rates will be reviewed. Article 5 point 3 says ‘Member States may submit to the Commission requests for the revision of the categories of goods and frequency rates’. We would like to know more about how this would work, for instance what kind of documentation member states would provide when requesting revisions. Article 5 point 4 says ‘In cases where the level of non-compliance for physical checks recorded in the IMSOC in the last 12 months, for the same category of goods from the same third country of origin, exceeds by 30% the average rate of non-compliance for the same category of products from all third countries, the Commission shall increase the frequency rate of physical checks to the next higher frequency rate laid down in Annex I or to a frequency rate of 50% where the categories of goods concerned are already subject to a frequency rate of 30%. The frequency r
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Response to Tariff quotas with licences

22 Aug 2019

IMTA, based in the UK, has represented businesses engaged in the international meat trade since 1895. We represent around 65 trading members (importers & exporters) and around 25 associate members, these are businesses who operate in relevant industries (e.g. customs agents/freight forwarders, shipping lines). Our trading members cover beef, lamb, pork & poultrymeat. •It is important to recognise that in the case of oversubscribed quotas the allocation method chosen inevitably artificially impacts on the market. •Whilst we welcome the opportunity to simplify and harmonise quota rules there are some elements in the proposals where there is a danger that existing businesses could be severely affected. We appreciate that it would have been very difficult to carry out an impact assessment on this aspect. For this reason it would seem prudent if elements relating to the reference quantity (Article 9 of DA) could be moved to the IA thus allowing the EU Commission the ability to respond quickly to any inadvertent negative impacts on businesses. An impact assessment would have aided in assessing the potential implications for SME’s for the proposals. •Administration of the frozen beef TRQ (order number 09.4003) in the past has experienced substantial problems and court cases. Since 2004 this TRQ has been administered efficiently and without controversy. We appreciate the modifications the EU has already made by way of derogations for this quota. However, the EU proposal only allows frozen beef to qualify for reference quantity (Article 9(2) of DA), whereas currently chilled beef is also eligible. Imports of frozen beef at full duty are not economic, but allowing the import of chilled beef to be eligible has enabled newcomers to participate in the frozen beef market. We would strongly request that the EU provide a derogation to Article 9(2) to allow chilled to continue to be eligible. •As Article 9 is currently worded operators would not be allowed to use the same CN code import reference for multiple quotas, thereby not allowing the possibility for a company to expand its business. •Paragraph 3 of Article 9 DA (limiting the total volume that a company can apply for to its reference quantity) would not allow the volume of the quota to be distributed in full, thus perpetuating the underutilisation of some quotas. The suspension mentioned on Paragraph 8 of the same article would not allow enough time for the full utilisation of the quota. •Article 10(2) and (3) requires the provision of an invoice. This would complicate the process for the operator and will put a potential heavy burden on member state authorities to check for discrepancies. Member states verification depends on their assessment of risk and there is a danger that processes will not be equal across member states. •The concept behind Art. 10.5 DA is welcome but we would question the loose wording. The article may not be uniformly implemented across the EU and it may also allow cherry picking of the best year by importers as there are often sanitary measures implemented in any given year. This may give an unfair advantage to certain importers. •Our members’ experience of the use of the independence clause in the beef sector in the 2002/3 leads us to question the advisability of applying this mechanism to some of the poultry TRQs. We question the imposition of a 15% limit in Article 9(1) of the DA, which is essentially set at an arbitrary level and would cause a redistribution of business away from existing businesses, essentially stepping into the realm of competition law. If there were no limit set this would negate the need for an independence clause and would substantially simplify the system. •In the poultry sector there is still no mechanism to allow newcomers to participate other than requiring them to import at full duty, which makes it difficult for the newcomer to compete against those businesses already holding quota.
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Response to Tariff quotas with licences

22 Aug 2019

The International Meat Trade Association (IMTA), based in the UK, has represented businesses engaged in the international meat trade since 1895. We represent around 65 trading members (importers and exporters) and around 25 associate members, these are businesses who operate in relevant industries (e.g. customs agents/freight forwarders, shipping lines). Our trading members cover beef, lamb, pork and poultrymeat. •It is important to recognise that in the case of oversubscribed quotas the allocation method chosen inevitably artificially impacts on the market. •Whilst we welcome the opportunity to simplify and harmonise quota rules there are some elements in the proposals where there is a danger that existing businesses could be severely affected. We appreciate that it would have been very difficult to carry out an impact assessment on this aspect. For this reason it would seem prudent if elements relating to the reference quantity (Article 9 of DA) could be moved to the IA thus allowing the EU Commission the ability to respond quickly to any inadvertent negative impacts on businesses. •A number of previously oversubscribed poultry TRQs have been undersubscribed for over a year. Will the EU Commission review Annex 1 of the IA before final adoption?
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Response to Draft Implementing Regulation on the procedures for coordinated performance of intensified official controls at borders

7 Aug 2019

The International Meat Trade Association (IMTA), based in the UK, has represented businesses engaged in the international meat trade since 1895. Currently we represent around 65 trading members (importers and exporters) and around 25 associate members, these are businesses who operate in relevant industries (e.g. customs agents/freight forwarders, shipping lines). Our trading members cover beef, lamb, pork and poultrymeat. We welcome the opportunity to comment on this draft which is highly relevant to our members. The draft outlines that the coordinated performance of intensified official controls​ can end when: (i) an uninterrupted sequence of at least 10 satisfactory results in the coordinated performance of intensified official controls has been recorded in the IMSOC by the competent authorities of the border control posts of the Member States; and (ii) the total weight of the consignments referred to in point (i) reaches at least 10 times the weight of the consignment to which the notification referred to in Article 3(1) relates, or a net weight of 300 tons, whichever is the lowest. If there must be a weight requirement, 5 times would be a more appropriate number than 10. This would be a more proportionate approach and would not compromise protection of food safety. Weights of consignments do vary so if the consignment that triggered the checks was an especially large consignment, it could result in significantly more than 10 satisfactory checks being required in order to obtain 10 times the weight, which creates an unnecessary burden for business even with the ceiling of 300 tonnes. We believe any regulation should be risk-based but as it stands the draft does not seem to be risk-based. We welcome that the draft sets a clear procedure for the ending of imposed checks.
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Response to Enhancing Market transparency in the agri-food chain

19 Jun 2019

The International Meat Trade Association (IMTA), based in the UK, has represented businesses engaged in the international meat trade since 1895. Currently we represent 65 trading members (importers and exporters) and around 25 associate members, these are businesses who operate in relevant industries (e.g. customs agents/freight forwarders, shipping lines). Our trading members cover beef, lamb, pork and poultrymeat. IMTA supports the UECBV response to this consultation, particularly as concerns the potential of the proposal to negatively impact competition and potential negative impacts on the food-chain. IMTA believes trade and commercial confidentiality are extremely important and should not be undermined. It would be beneficial instead to make the best possible use of existing data (public and private sources).
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Response to The Information Management System for Official Controls regulation (IMSOC)

14 Jun 2019

The International Meat Trade Association (IMTA), based in the UK, has represented businesses engaged in the international meat trade since 1895. Currently we represent 65 trading members (importers and exporters) and around 25 associate members, these are businesses who operate in relevant industries (e.g. customs agents/freight forwarders, shipping lines). Our trading members cover beef, lamb, pork and poultrymeat. Both our trading and associate members will be affected by the Implementing Regulation on the information management system for official controls (the IMSOC Regulation) and the annex setting out the format for the Common Health Entry Document (CHED). We fully support the Commission moving towards a Single Window which facilitates trade and means better co-ordination of authorities operating at the border. We also welcome moves towards e-certification, embracing a more modern approach to trade. On Article 19 point 3 (news notifications) we believe there should be clear criteria for verifying news articles, to ensure they reflect the facts. We would urge part of the verification criteria to include contacting the country concerned by the news article to discuss the contents and to establish the facts.
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Response to Legal act to apportion certain concessions between the EU and the United Kingdom (Brexit preparedness)

16 Jul 2018

The International Meat Trade Association represents importers & exporters of beef, lamb, pork and poultrymeat. Predominantly our members are UK based & many also have offices in other parts of the EU. We also represent companies based elsewhere in Europe. Our members currently import in to & have customers in other member states as well as the UK. -In principle we don’t agree that the methodology whereby the shares must add up to 100% is a fair approach. -The flexibility to sell product either to the UK or other member states is an integral part of the market access granted to third countries under the WTO commitments. Whilst using a 3 year period is a convenient mirror of the procedure used for any enlargement of the EU, a member state leaving the EU is not a mirror image given the presence of the single market. Current flexibility to send to the EU27 or to the UK allows importers to respond to market changes & to supply product where it is most required. The EU & the UK are not self-sufficient in meat & need stable sources of imported product from trading partners in order to meet consumer demand, helping balance the market. -Once imported into a member state the product is free to travel within the single market thus post clearance movement of product is common, responding to changes in price differentials between member states for particular cuts of meat. We attach a more detailed response.
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Response to Negotiation mandate for revising an agreement with the US on the import of hormone-free beef

24 Apr 2018

• The International Meat Trade Association represents importers and exporters of beef, lamb, pork and poultrymeat. • Many IMTA members are importers under the hormone-free beef quota from the different eligible origins (Argentina, Australia, New Zealand, USA, Uruguay) and have grown their businesses and customers based on this quota. • The Commission needs to consider the impacts on these businesses and provide further opportunities for comment throughout the negotiation process. • Any changes to the quota must allow companies (both in the exporting countries and importers in the EU) time to adapt.
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Meeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström)

28 Oct 2015 · Trade in the meat sector