The decision as to how and when the UK might impose tariffs on imports from the EU in the event of a no-deal Brexit is a sovereign matter for the UK Government.
As part of my Department’s Brexit planning, my Department has carried out a detailed analysis of the implications for Irish agri-food exports in a scenario whereby the UK applied the EU’s existing tariff schedule on imports.
The detailed analysis was carried out by my Department using agri-food trade data, broken down into twenty four categories, identified and agreed by my Department and the CSO. The EU’s MFN (Most Favoured Nation) Tariff Schedule was then applied to this export data. This tariff schedule includes both ad valorem tariffs and tariffs per weight/unit of product, as set out in the EU’s TARIC database. The imposition of tariffs is not a linear exercise, and the possible tariffs that could be imposed vary both within individual categories and the sector as a whole. A calculation of tariff rate equivalents based on actual value and volume of trade in 2016 was completed, and is summarised in the table attached.
This analysis found that the estimated cost of potential tariffs for the sector as a whole is €1.7 billion, based on Irish agri-food exports to the United Kingdom of €4.8 billion in 2016.
There are a number of important caveats which must be considered when examining these results, including:
- Tariff data used, is based on a TARIC database extract at 31 December 2016, with the exception of those commodities where tariff rates had changed during the years 2014, 2015, 2016;
- This analysis represented over 90% of agri-food exports to the United Kingdom between 2014 and 2016.
- This analysis does not take account of any possible tariff rate quotas (TRQs), nor does it account for non-tariff barriers (NTBs) to trade, including transport delays and additional administrative costs.
- The analysis does not include the impact of any changes to the Euro-Sterling exchange rate.
- In respect of live animal exports, the average tariff rate equivalent is 8%, however in 2016, 67% of total value of live animal exports were not subject to tariff. The estimated tariff on total live exports which are subject to tariffs is 24%, and for exports of live bovines the tariff rate equivalent is approximately 40%.
Additionally, for some sectors further analysis is ongoing due to the complexity of the tariff calculations, namely:
- While raw forestry products do not usually attract third country duties, processed wood based products such as MDF, and OSB are subject to ad valorem charges based on declared value.
- For Cereals and Cereal Preparations products, almost half of the top 20 commodities are subject to duties which are calculated based on complex compositional data of the ingredients used.
Third country duties for individual product lines can be found on the TARIC website using the eight digit combined nomenclature (CN) code:
http://ec.europa.eu/taxation_customs/dds2/taric/taric_consultation.jsp?Lang=en
Tariff rate equivalents of agri-food sector commodities, 2016
|
Total Exports to the UK 2016
|
Est Duty as a % of the declared value
|
Total Est cost of tariff equiv.
|
Dairy
|
€857,279,000
|
49%
|
€422,547,000
|
Beef
|
€1,113,448,000
|
70%
|
€780,521,000
|
Sheepmeat
|
€52,027,000
|
75%
|
€38,996,000
|
Pigmeat
|
€408,182,000
|
22%
|
€90,595,000
|
Poultry
|
€217,308,000
|
55%
|
€118,817,000
|
Live Animals[1]
|
€259,200,000
|
8%
|
€21,123,000
|
Eggs
|
€10,877,000
|
19%
|
€2,035,000
|
Other Meat & Meat Preps
|
€46,949,000
|
18%
|
€8,543,000
|
Fruit and Vegetables
|
€239,155,000
|
14%
|
€33,439,000
|
Fish
|
€64,262,000
|
14%
|
€8,900,000
|
Beverages
|
€301,642,000
|
5%
|
€14,250,000
|
Cereals & Cereal Preparations
|
€339,582,000
|
14%
|
€47,813,000
|
Animal Feedstuffs
|
€211,769,000
|
8%
|
€17,272,000
|
Misc. Edible Prods & Preps
|
€118,234,000
|
10%
|
€11,839,000
|
Vegetable Oils & Fats
|
€7,557,000
|
9%
|
€666,000
|
Sugar, Sugar Prep & Honey
|
€44,467,000
|
30%
|
€13,216,000
|
Coffee, Tea, Cocoa & Spices
|
€242,241,000
|
17%
|
€41,021,000
|
Crude Animal & Vegetable Material
|
€31,695,000
|
1%
|
€382,000
|
Animal Oils & Fats
|
€10,293,000
|
1%
|
€85,000
|
Oilseeds & Oleaginous Fruit
|
€11,164,000
|
0%
|
€15,000
|
Forestry[2]
|
€176,544,000
|
0%
|
|
Animal Skins & Furs
|
€35,477,000
|
0%
|
|
Flax, Wool & Animal Hair
|
€5,142,000
|
0%
|
|
Cotton
|
€34,000
|
0%
|
|
Totals
|
€4,804,528,000
|
|
€1,672,074,000
|
[1] MFN tariffs on Live Bovine exports (excl. breeding), which are charged at 10.2% + 93.100 DTN are considerably higher than estimated duty for the sector. The estimated tariff rate equivalent of these commodities is approximately 40% tariff rate equivalent.
[2] While Raw forestry products do not attract duties, processed wood products such as MDF do, these are usually charged at 7% ad valorem.