Digital Export Health Certificates: letter to Department for Environment, Food and Rural Affairs

To: Secretary of State for Environment, Food and Rural Affairs, the Rt Hon Dr Thérèse Coffey MP
From: Cabinet Secretary for Rural Affairs, Land Reform and Islands, Mairi Gougeon 

Dear Thérèse,

Digital Borders Programme – eEHC Closedown

I have been made aware of Defra’s recent decision to end the eCertfication for Export Health Certificates (eEHC) private beta testing programme. You will recall we exchanged correspondence on the Digital Borders programme on 7th December 2022 and 13th January 2023. It is disappointing that given the implications of this for Scottish exporters, that you made no attempt to discuss this with me beforehand nor actually inform me yourself of this decision.

Clearly, this is complex work and any system introduced must work for traders – you may recall that Scottish Ministers repeatedly warned of the complexities involved in Brexit and in becoming a third country for trading purposes. Stopping the current eEHC testing programme does not help simplify the ongoing bureaucratic arrangements that are now in place because of Brexit for some of our most important food exporters here in Scotland.

Scotland’s aquaculture and fishing sectors, which make up a significant proportion of the UK’s total seafood exports (Scottish salmon is the third largest UK food export by value) have been the hardest hit by Brexit and continue to face additional administrative and logistical burdens and costs, jeopardising competitiveness and supply chains.

You will be aware of industries’ ongoing frustrations about this, as well as with other programmes which form part of the UK Government’s 2025 Digital Borders Strategy. In your letter of 13th January, you stated that you hoped a comprehensive timeline for the project would be shareable soon. We are now seven months on; no timeline has been offered, and businesses now have further uncertainty in which to operate and to make investment decisions. This is unacceptable. The Scottish Government repeatedly warned the UK Government that our forced exit from the EU would be damaging to Scottish export businesses. Sadly, three years on, this remains the case and industry continues to face damage inflicted on it by UK Government decisions. This delay also further accentuates the uneven playing field between imports and exports.

I would, once again, encourage you to press your Ministers and officials to dedicate sufficient resource to the Digitisation work to ensure it progresses at pace. I would also reiterate my request to provide a realistic and accurate timeline that can be shared with businesses to enable them to plan and prepare for the future.

As I said in my previous letter, outwith rejoining the EU and the single market and businesses having barrier and cost free access to the EU market, Digitisation has the opportunity to make the single biggest positive impact on industries’ ability to export. We therefore must see some progress with moving towards a fully operational and functioning eTrade system to give businesses in Scotland, across the UK, and in all sectors, the best chance to succeed in the challenging times we operate in.

I look forward to receiving your response.

I am copying this letter to:

• The Rt Hon Kemi Badenoch MP, Secretary of State for the Department of Business and Trade
• The Rt Hon Alister Jack MP, Secretary of State for Scotland
• John Lamont MP, Parliamentary Under-Secretary of State for Scotland
• Lesley Griffiths MS, Minister for Rural Affairs and North Wales, and Trefnydd, Welsh Government
• Jayne Brady, Head of the Civil Service, Northern Ireland

Yours sincerely,

Mairi Gougeon