Oval Marks, Traceability and a No Deal Brexit

Over the last few years certification requirements have become more complicated as traceability has become much more important. With Brexit possibly imminent the position is even more opaque.  

Many years ago – when I first started Certification work – I could make alterations to the Certificate to say, for example, that I was signing on the basis of samples examined. Nowadays that would certainly not be allowed. In days gone by, I made the decision to sign on the basis that I would or would not eat the produce myself. Nowadays if the exporter buys in cheese, it has to be from someone who is registered with the local authority as an export producer and who has an Oval Mark to identify them as such.  

Most produce is Oval Marked, but if not, I have to make enquiries from the manufacturer and often get written statements from their veterinary surgeon, to ensure that the product production plant and any intermediate cutting plant or cold store all had either an Oval Mark or proof of standards.

For example, a cold store would be asked for temperature records relating to when the period when the product was stored, and if a cutting plant did not have an Oval Mark then I would have to talk to their manager and vet. So, export certification is not always straightforward. Now with Brexit it is considerably more problematic. 

As we don’t know the basis of the UK withdrawal, we don’t know what the requirements for export to the remaining 27 countries of the EU (Britain’s biggest market) will be. If we drop out without a deal, there will be no soft landing of a transition period, and on November 1st, exports to the EU will require Certification which is currently not required as we are part of the Common Market. 

In this new circumstance there will not only be a requirement for an Export Health Certificate (EHC), but all the stages of production must be registered, and not only here, but listed in the EU as acceptable. This listing will not be achievable overnight, so there will be a period when exports to the EU are virtually impossible. 

Also, with regard to the rest of the world, we will no longer have the protection of the EU, and we may face the same problems with registration of premises and listing as things unfold. If we leave the EU with a deal, there will be a transition period during which all these matters can, and hopefully will, be sorted out. 

In the short term, the old Oval Marks (UK3456EC) will continue to be accepted for EU exports (only if the UK and the EU agree a deal) and for non-EU exports (regardless of the Brexit outcome). I discussed the possible new Oval Mark at this year’s OV Conference and it has not yet definitively been decided how the new Oval Mark will look, or for how long we can use the old one, but you will find out more from us when it is confirmed.

Feel free to give me a call and discuss any of the above in the interim.

Dave

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