FEFPEB Statement: Preparing for a “No Deal” Brexit

In the absence of an agreement by the end of March, the UK’s departure from the European Union will mean that ISPM-15 requirements will come into effect, immediately. FEFPEB, in a release from 22 February,  called for a one-year phase-in period in general, and a two-year phase-in for pallet pools.

Wooden pallets and packaging move the world, with 85% of all transport of goods worldwide on or within Wood Packaging Material (WPM). Supply chains cannot work without wooden packaging and therefore any major disruption to the circulation of wooden pallets and packaging has immense repercussions on the trade of goods between countries.

In case of a “no deal’ Brexit post 30 March 2019, the United Kingdom will be regarded as a third country and the consequence will be that all WPM moving between EU and UK must meet the requirements of ISPM 15. If the UK will be leaving the EU without a deal, it does not change the plant health risk between the EU and UK and FEFPEB therefore strongly advocates maintaining the current situation, no ISPM 15 requirements for flows between EU and UK. This would be the best solution for WPM and logistics in general if the EU (and the UK!) are willing to approach this issue from the phytosanitary perspective.

FEFPEB is however aware of the broader scope and the enormous legal and political impact of Brexit. If it is therefore decided that WPM moving between EU and UK must be ISPM 15 compliant after 30 March 2019, FEFPEB calls for a pragmatic implementation and controlling policy, in order to allow an orderly transition period and thereby avoid a disastrous disruption of trade post-Brexit.

A phase-in period to increase and adapt the Heat Treatment capacity of the industry would be of the essence. We estimate a realistic requirement of one year in general and two years for the pallet pools, with many millions of wooden pallets in circular economic re-use models in circulation and palletized goods already in the supply chain. Costs for investments in HT capacity are substantial.

Phytosanitary checks by the NPPO’s will continue to be carried out in the EU and UK on a risk-targeted basis, a pragmatic approach for WPM must be possible, given the low phytosanitary risk of WPM used in EU-UK flows. The UK government has already indicated that it will take such a pragmatic approach (reference the attached statement of 19 February 2019). FEFPEB continues dialogues with the EU and UK partners to ensure uninterrupted transport with WPM, deal or no deal Brexit.