The NFU has pressed the government for answers to 50 'vital questions' concerning the implications of a no-deal Brexit on the farming industry.
The union is probing the government to gain clarity on issues which could adversely affect British farmers if the UK abruptly exits the EU.
The UK is scheduled to leave the European Union in just 50 days time, on 31 October.
Prime Minister Boris Johnson has frequently said the country will leave the bloc 'do or die' and 'come what may'.
But the NFU has reiterated that a no-deal departure would be 'extremely damaging' for the UK farming industry.
One issue the industry has a major concern about is being forced to trade on World Trade Organisation (WTO) rules.
That means farmers will face higher taxes on exports, such as 48% on lamb which is currently traded with the EU at a zero tariff.
Farm groups have also asked that UK food standards are not 'sacrificed' in future trade deals with products entering the country that would be illegal to produce in the EU.
The 50 questions cover issues such as trade and welfare standards, taxes on imports and exports, immigration policy, additional red tape and what will happen to farm payment rules when the UK is no longer part of CAP.
NFU President Minette Batters said farmers are in 'turbulent political times' who still face an 'array of possible Brexit outcomes'.
“There are 50 important questions that need clear answers. For instance, what steps is the government taking to establish a Trade and Standards Commission to ensure farmers are not undercut by product that does not meet our production standards?
“How will the government ensure farmers and growers can recruit sufficient workers in the final few critical months of the year?
“We want a future that sees a thriving food and farming sector not a future where we see Britain’s ability to feed itself fatally undermined.”
The 50 questions
• Citizens’ Rights
When will the government enshrine in law its commitment that the rights of existing EU citizens living and working in the UK will be upheld and protected?
• Seasonal Workers
Will the government increase the number of permits available under the pilot seasonal agricultural workers scheme to guarantee that industry will have access to the right number of workers it will need in 2020 and to enable proper testing of the scheme ahead of full conversion in 2021?
• Trade / Standards
What steps are the government taking to establish a Trade and Standards Commission as pledged by former Defra Secretary of State Michael Gove at NFU conference 2019 to ensure UK farmers are not undercut by product entering the UK market that do not meet UK food safety, animal welfare and environmental production standards?
• Review emergency tariff policy
Will the government commit to swift remedial action to prevent a flood of imports entering the UK market as a result of the UK’s import tariffs being set at zero or too low?
• Management of TRQ volumes
How will volumes of imports be managed under the TRQ system where these exist and what protection will be in place to ensure quantitative limits are not breached?
• Irish border / backdoor imports
How will government guarantee that the tax relief in place over the Irish border will not work solely for the benefit of EU and ROI exporters and to the detriment of UK farmers and leading to a backdoor way for imports to enter the UK?
• Monitoring the market
What is the government doing to implement an effective and dynamic means of monitoring the UK agri-food market, ensuring comprehensive coverage and timely expert analysis of market movements?
• Longer term UK tariff policy
Will the government reinstate the former tariff protections in place prior to a no-deal once a free and frictionless trade deal with the EU is secured? How does it propose to consult the industry and will there be greater transparency and oversight for NFU?
• Trade continuity
What is government doing to secure the outstanding Trade Agreements that are in jeopardy of being lost? Those not signed currently equate to £1.9bn worth of exports with over 2/3rds of the value of our exports under these agreements not secured.
• Day 1 readiness key export markets
What is the government doing to ensure that on day 1 of a no deal exit there is no disruption to our terms of trade with key export markets such as China as a result of the change in the UK’s trading status outside of the EU?
• Goods on market
What is the status of goods that were produced under UK/EU rules that is already placed on the market and will be sold after the 31st October? How will government ensure that these goods are not rejected at their destination? Will a grace period be negotiated with the EU?
• POAO certification
In a no deal scenario, there would effectively be a trade embargo on the export of UK animals and animal-based products (meat, eggs, dairy, etc.) to the EU. This is because the EU requires third countries (which the UK would be in the case of no-deal) to be listed as an approved country for export. What action is government taking to secure the approval of the UK as a country listed for the export of animals and products of animal origin to the EU?
• Phytosanitary certificates
Does the government guarantee that the resources will be in place to ensure that the relevant plant health authorities will be able to issue in a timely and efficient manner the necessary Phytosanitary Certificates for exports of controlled plant goods from the UK, including exports to the EU?
• Availability of vets
Will there be sufficient vets trained and available to perform all the required government Official Veterinary functions?
• Export Health Certificates
Even if third country approval was given every export of UK animals or animal products to the EU would be subject to complex SPS (sanitary checks) that will create delays at the border. The EU rules require that an export health certificate which must be signed by a vet and the product must move through a Border Inspection Post (BIP). What assurances can you give that all the necessary guidance and protocols will be available in time and that no delays at ports will be created as a consequence?
• Veterinary medicines
We import more than 90% of veterinary medicines and pharmaceutical products. Is the government confident that the UK farmed livestock sector will be able to access vital medicines in the short and medium term so that animal health and welfare is not compromised?
• bTB tuberculin test supplies
What steps are the government taking to guarantee an adequate supply of tuberculin to maintain the UK's robust testing regime?
• Animal Disease surveillance
We know that the UK will no longer be able to access the EU's Animal Disease Notification System (ADNS) after we leave the EU. Is the government confident in its ability to maintain its disease surveillance capability, including access to world class science and research currently accessed through international veterinary laboratory networks?
• Delays at Border
What is government doing to minimise the amount of time hauliers are delayed at the border? What is the anticipated time it will take for hauliers to pass through key ports such as Dover?
• Animal Welfare disposal arrangements
What steps are the government taking to ensure that farmers are not made to pay for and arrange for the disposal of unmarketable livestock, particularly in the intensive pig and poultry sectors?
What is government doing to ensure that UK organic certification bodies will be authorised to export high quality organic products to the EU?
What is government doing to ensure that there will be no trade embargo in the sale of certified UK hops to the EU?
• EU Marketing Standards
What steps is the UK government taking to minimise delays at the border as a result of EU marketing rules applying to UK exports?
When will the Import Product, Animal, Feed and Food System be available for the pre-notification of animals entering the UK from 3rd countries after 31st October?
• Sugar Beet Seed imports
What steps will government take to guarantee that farmers will be able to source sugar beet seed supplies, 100% of which is imported from the EU?
• Seed /Ware potatoes
When will the UK be authorised to export seed and ware potatoes to the EU?
• Seeds/ propagating material
What steps is the government taking to guarantee that UK exports of seed and other propagating material will be accepted by the EU?
What guarantees will be available for our hauliers that they will be able to secure the required number of ECMT permits that are limited by the EU?
• Tariff Barriers
The EU is the UK’s main trading partner. In 2017 Defra stats show that 60% of UK food, feed and drink (FFD) exports were to countries within the EU. In a no deal scenario, exports to the EU from the UK would face the same tariffs as goods entering the EU from third countries without a preferential trade agreement, the Common Customs Tariff (CCT). These are particularly high in relation to many agricultural products. This would be a dramatic change from the current situation where UK goods are traded within the EU tariff free. What is the UK doing to address this with the EU and secure a zero for zero tariff agreement?
• Tariff costs
What financial support will be available to UK farmers to offset the cost of additional new tariffs on exports to the EU?
• Priority at border
Will the government guarantee that live animals and perishable fresh produce will have priority for swift passage at the borders? What actions are the government taking to ensure that delays at ports don't create animal welfare concerns beyond the control of the haulier / animal owner?
• Non-tariff barriers
What support will government provide to cover Export facilitation costs, for example funding the process of signing EHC, BIP inspection and haulage / increased ferry charges?
• Lamb exports
We export >30% of total UK lamb production to the EU, the equivalent of approximately 4.5million sheep each year. What action is the government taking to address the catastrophic disruption in the lamb sector facing EU tariffs of 46%?
• Carcase balance
The UK exports more than £1.2bn worth of beef, pork, lamb and poultry to the EU. In the event that the EU applies its full external tariff on UK exports, this would equate to £647m new taxes on our products. What compensation will be made available to UK livestock farmers?
• Grain and flour exports
UK annual exports of grain, flour and malt have averaged £413m over the period 2014-2017, the UK is set to have a large exportable surplus this year. The additional tariff that would be due would be up to £226m and further losses would be expected given imbalance on the domestic market. What compensation will be provided to UK arable farmers?
What steps will the government take to create the right conditions for a thriving biofuel industry in the UK, specifically to introduce a requirement for a 10% mix in ethanol (known as E10)?
• Enhance export opportunities
How does the government propose to expedite the growth of UK exports to countries beyond the EU? What resources will be made available to enhance the Great British campaign?
• Enhance fiscal environment
To ensure UK farmers can remain resilient in the face of severe economic disruption and continue to provide a significant proportion of our domestic food requirements, what steps will government take to adjust the capital allowance regime, allow tax deductions to incentivise investment in structures, plant and machinery, and deliver high quality broadband and mobile connectivity to 100% of rural areas?
• Common rule book
Is the government committed to maintaining a common rule book with the EU for agri-food, in order to minimise friction at the border?
• Delay non-urgent government initiatives
Will the government commit to pause all non-urgent government initiatives, including consultations and calls for evidence on matters not relating to immediate pressing Brexit priorities?
• Pause BPS phase out
Will the government commit to address the uncertainty arising as a result of leaving the CAP? Defra's timetable for commencement of the phase out of BPS in 2021 should be paused by at least a year and longer if the UK's future relationship with the EU is not resolved with adequate time for the industry to prepare.
• Confirm operating rules for BPS 2020
Will the government urgently confirm the rules relating to the operation of BPS 2020 as soon as possible, in particular the greening requirements and basis of payments?
• Forthcoming scheme year operation
Will the government confirm the rollout of Countryside Stewardship application process for agreements starting on 1 January 2021 as well as clarify the position for rolling over existing HLS agreements that were either rolled forward for 2019 or coming to an end in 2019?
• Operational programmes for POs
Does the government commit to guaranteeing funding for producer organisation programmes up to and beyond 2020?
• Shared prosperity fund
Does government agree that Local Enterprise Partnerships (LEPs) should introduce a specific rural support programme for their respective rural areas once the current measures under the EU RDPE end December 2020 as an integral part of the Shared Prosperity Fund objectives? The details for this must be developed expediently to avoid any hiatus in funding support for rural areas.
• Drive low carbon solutions
Will the government commit to maintain funding for catchment sensitive farming partnerships and increased funding for Countryside Stewardship and ELMS trials?
What steps will the government take to minimise issues arising from the disposal of waste, particularly relating to product affected by delays at the ports?
Can government guarantee that information has been provided to food processors on how product labelling will change and how will government guarantee that consumers are not misled or confused unnecessarily?
• Public procurement
What steps are government taking to ensure that food purchased for public procurement meets UK standards and what is being done to mandate the use the government Buying Standards and Balanced score card within all government procured contracts?
• Domestic Marketing funding
Will government commit funds to develop a strategic domestic marketing campaign to support British standards and produce, to ensure customers are aware of the high-quality products British farmers produce?