Protection from low-cost imports of agricultural goods in the UK could be sharply reduced in the event of a No-Deal Brexit. The UK Government published a proposed tariff schedule on 13th March which sets out the level of tariffs which it will apply to imports to the UK if it leaves the EU without a deal and therefore is no transition period. In these circumstances the UK would be operating under World Trade Organisation (WTO) rules not the EU framework. The tariff scheme would only be temporary, lasting for 12 months, after which the Government would introduce a more long-term tariff regime, following consultation. Over the coming days we will be looking into the tariff schedule in more detail, (which runs to 1,477 pages), but the key elements include:
- Cereals, Eggs, Fruit and Vegetables – No import tariffs will apply to these products. This means unlike the current situation where these sectors receive protection from the EU’s tariffs, these markets will be open to all global exporters. By contrast, UK exporters will face tariffs if they export to the EU now.
- Sheep Meat – No change to the existing EU tariff rates or tariff rate quotas (TRQs). This means UK imports of sheep meat from New Zealand and Australia will continue to be imported tariff-free under existing TRQs. But imports from the EU to the UK (21,400 tonnes carcass weight equivalent in 2018) would now face a tariff – this would have the most effect on the Republic of Ireland. Looking at exports from the UK under a No Deal, which are currently tariff free to the EU, these would face the same tariffs as any other country without preferential access. In 2018 95% of all UK sheep exports went to the EU, approximately 80,000 tonnes. The sheep meat tariff remains at 12.8% +€171.3/100kg.
- Beef – The import tariff rate for fresh or chilled boneless beef will be cut from 12.8% + €176.8/100kg to 6.8% +€93.3/100kg. There will also be a TRQ of approximately 230,000 tonnes which allows tariff-free access to the UK from any country, including the EU. This is in addition to the 55,000 tonnes of pre-existing EU TRQs which the UK has agreed to take under the split of current EU TRQs (see December Bulletin), following Brexit. However, in 2018, the UK imported 380,000 tonnes of fresh, frozen or processed beef, which means in the region of 95,000 tonnes will be subject to the new UK import tariffs. In 2018, of the 380,000 tonnes, 340,000 was imported tariff-free from the EU with the vast majority coming from the Irish Republic. About 30,000 tonnes would have been imported from non-EU countries at a reduced tariff under the pre-existing EU quotas.
- Dairy – The UK has announced reduced import tariffs for butter and some cheeses compared to current EU levels. The UK will apply €60.5/100kg for butter and a tariff of €22.1/100kg for cheddar. The EU rates are €189.6/100kg and €167.1/100kg for butter and cheddar respectively. The existing rates on milk, cream, powders and yoghurts will be cut to zero.
- Poultry Meat – Two new TRQs will be set up; 166,196 tonnes for fresh and chilled poultry meat and 79,510 tonnes of frozen, the tariff for these will be set at zero. There are tariffs for the out-of-quota lines, but these are considerably lower than the EU currently applies to 3rd country imports.
- Sugar – The tariff for out-of-quota raw cane sugar will remain at €33.9/100kg. But there will be a TRQ of 260,000 tonnes, for which the duty will be set at zero.
- Fertiliser – All imports to the UK will be subject to a 6.5% tariff.
Below is a summary table outlining the tariffs that importers would face when bringing products into the UK from abroad (either EU or non-EU) as well as the tariffs that UK exporters would face when trading with the EU. Based on previous information published last year, the EU’s Common External Tariff also represents the upper limit of tariffs that the UK could impose on other WTO members (i.e. its “bound” level of tariffs). However, as pointed out above, the UK can apply a lower level of tariffs (in this case for an initial one-year period) as long as these tariff levels are below the bound rates and are applied equally to all WTO members. A summary, of the new Tariff Rate Quotas (TRQs) are also outlined.
Commodity | EU Common External Tariff (€ per tonne) | EU Total Tariff Rate Quota (TRQ) (tonnes) | TRQ available to UK (tonnes) | In-TRQ Tariff (€ per tonne) | UK No-Deal Import Tariff (% and/or € per tonne) | Additional UK No-Deal Import TRQ |
Feed Wheat | €95 | 3.1Mt | 2.39Mt (see Note 1) | €12 | €0 | n/a |
Quality Wheat | Complicated formula based on US price | 300,000 | all | - | €0 | n/a |
Feed Barley | €93 | 307,105 | all | €12 | €0 | n/a |
Oilseeds | None | n/a | n/a | n/a | n/a | n/a |
Sugar (Raw Cane) | €339 | 780,925 | 253,977 | €0 | €339 | 260,000 |
Skim Milk Powder | €1,254 | 68,537 | all | €0 | €0 | n/a |
Cheese (Cheddar) | €1,671 | 29,716 | 15,005 | €210 | €221 | n/a |
Beef Carcasses (fresh/chilled) | 12.8% + €1,768 | 188,354 (see Note 2) | 117,503 | various | 6.8% + €933 | 230,000 |
Lamb Carcasses (fresh/chilled) | 12.8% + €1,713 | 281,190 | 200 | €0 | 12.8% + €1,713 | none |
Pigmeat | €536 | 87,176 | 71,469 | various | €71 (fresh carcasses) | n/a |
Poultry Meat (cooked, processed and uncooked) | €1,024 (fresh poultry cuts) | 806,850 | 67,760 (all poultry species and cuts) | various | €618 | 245,706 |
Note 1: includes 2.38Mt available to “other countries” (excluding US and Canada) and 0.1Mt available on an Erga Omnes (available to everyone) basis.
Note 2: relates to all beef.
There is one important point to note; to uphold the Government’s commitment to there not being a hard border on the island of Ireland, the tariffs will not apply to trade between the Republic of Ireland (ROI) and Northern Ireland (NI). It seems highly likely that a large volume of ROI produce will subsequently find its way onto the GB market. The Government has stated that if it is found that trade flows shift, i.e. from ROI through NI to GB for the purposes of tax avoidance, HMRC would investigate, but quite how this would ever be policed in practice is unclear.
The combination of lower import tariffs, relatively generous TRQs, and likely ‘leakage’ of ROI produce into GB markets at zero tariff rates, means significant lower protection for the farming sector from low-cost imports. It appears the Government has, not surprisingly, prioritised keeping food prices low rather than helping the UK farming industry.
These new tariffs will only apply if we leave the EU with no deal and to imports to the UK. Without a trade deal, exports to the EU would have to pay the EU’s own tariff rates, which in many cases are higher, making UK exports to the EU more expensive and less competitive.