From this week, British exporters of composite foods to France will have to submit some paperwork in French. This was supposed to start on 1 January but the British had to plead for an extension. I suppose this was to enable exporters to hunt around some competent keyboarders proficient both in French and in export lingo. The penalty, if they get it wrong and a form is presented in bad French to a French customs official, is that the lorry full of custard or puddings or whatever could be turned right back to … hmm… Kent!
Composite food
Composite food is defined as food that has plant or animal-based food mixed in with it. So fresh chicken or frozen lamb is not composite, nor is fresh cauliflowers. But a packet like a frozen pie, or a pudding with milk in it, is composite. So how important to the UK is this export of composite food?
I had a quick look at the trade tables (x 000s each figure) for composite food (Code 210420) in the World Integrated Trade data. In 2021, the UK exported some $24,583 of this stuff. Mind you, some EU countries exported more: Germany at $64,606 and France at $49,725. Grrr – just like the French to be better at food trade!
English strengths
If the French are so good with food, just what exactly are the English successfully exporting to France? I have an inkling, because I have a francophone grandson, and he is very fond of custard, which can be bought in Brussels under the name of ‘crème anglaise’. You can also be almost sure that a food is really native to England if the French still have to use the English name: pudding (‘pouding’); muffin; crumpet.
I went along to a local shop, here in Kent, to photograph some of the convenience puddings on their shelves. It is this sort of instant sugary creamy dessert that appeals, I guess, to French working families as much as to English, regardless of the health advice to cut down on such food and eat fresh where possible.
What are the rules?
The regulations regarding EU trade in composite foods found online state:
“The risk posed by composite products to public and animal health depends on the types of ingredients and on their storage conditions and packaging. Shelf-stable composite products that do not contain processed meat as an ingredient and do not need to be transported or stored under controlled temperatures pose the lowest risk as regards animal health and microbiological food safety.
“This is the case for dairy and egg products contained in shelf-stable composite products that have undergone treatment during their manufacture, such as sterilisation or treatment using ultra-high temperatures to eliminate the risk. Risks for animal health and microbiological food safety are mitigated where composite products are securely packaged or sealed.”
So that’s OK. Most ‘pouding’ fits into that and should be mitigated. But the next paragraph shows a red flag:
“However, chemical food safety risks are not reduced by treatments that make composite products shelf-stable”
The following paragraphs then explain that the procedures have to be certified as coming from a third country with an accepted certification process. Then comes this clause:
“Certain shelf-stable composite products not containing processed meat, exempted from official controls at border control posts in accordance with this Regulation and entering the Union from third countries should be accompanied by a private attestation provided by the importing food business operator.”
So, a “private attestation” is needed, from the agent of the food importer (that is, in France). That explains why it might be necessary to submit the attestation forms in French. Turn up with English attestation, and get turned back.
She sought them here, she sought them there
The article in The Grocer that alerted me to all this states at the end that Defra has made translated versions of the forms available online, but I could not find these. Furthermore, I suspect the problem is not the translation of the form’s questions, but of the answers – the exact origin of the cocoa butter for example, which may have been harvested in one country, processed in another and then made “shelf-stable” in a packaged pudding in the UK.
What I did find in my brief photography of the fast-pudding shelf is that the trade is very international. One brand is entirely produced in New Zealand. Another is produced for a Swiss company but from an address in Greece and in the UK. Another gives nutrition information in both English and Norwegian. So, it is not only French attesters who will be in demand.
Communicating with your custard customers
I find it very odd that the English pride themselves in being a trading nation, yet at the same time complain of being poor language-learners. With regard to learning French in Kent, it does not help that Brexit visa rules have made it more difficult to get French language assistants in local schools, but that is another story. Meanwhile: bonne chance avec le pouding.
