BTOM will create a ‘gaping hole’ in UK border

Defra’s post-Brexit border control rules governing UK food imports will erode rather than strengthen the country’s food security and biosecurity, according to the Dover Port Health Authority (DPHA).

In an excoriating letter to the Environment, Food & Rural Affairs (EFRA) Select Committee dated 18 March, the DPHA levels claims of inaccuracy and wilful incompetence at Defra and its new border control plans (BTOM).

Writing to EFRA chair Sir Robert Goodwill, Dover’s head of port health & public protection Lucy Manzano said Defra’s assertion that the implementation of phase one of new imported food border controls (BTOM stage 1 – health certificates required) on 31 January 2024 had gone smoothly is based on inaccurate data.

She said, since 31 January, Defra has reported that from the whole of the GB (covering all ports) just 50,000 sanitary and phytosanitary (SPS) notifications had been received, to which they have provided feedback to only 250 importers. However, Dover Port Health Authority’s imported food data shows that during the same period (20 days), greater than 95,500 SPS controlled goods travelled through Dover alone.

“With this in mind, and the limited number of checks completed, and the restrictive nature of those checks, I think it reasonable to say that the work completed should not be presented as an indication of successful implementation,” she wrote.

Manzano continued to say that Defra’s claim that the introduction of new health certification requirements will strengthen UK’s biosecurity regime is misleading. Currently, rest-of-world imports are already subject to risk-based controls and can’t leave a port of entry until full checks are completed. Yet Defra plans to change this practice for the Short Straits only, allowing rest-of-world food (that is classified as higher risk) to arrive and leave the port without control to be checked 22 miles away in new border control post in Sevington, near Ashford.

“This will not meet the high standards required to protect the nation’s biosecurity,” she wrote. “Instead, this action creates an entirely new and needless risk to GB biosecurity by enabling food to move freely and uncontrolled away from the point of entry and the Port Health Authority at Dover.”

Manzano’s letter states that Defra’s commitment that biosecurity controls are a priority is contradicted by its intention to not open a high-risk food border control point at Dover; move all commercial imported food controls inland (22 miles) to Sevington; allow all controlled food to move ‘uncontrolled, freely away from the border without checks; and cut funding to DPHA to complete African Swine Fever illegal meat import checks by 70 per cent and then down to zero.

“Defra will create a gaping hole in this border that does not currently exist,” the letter said. “Currently there are mechanisms in place to physically hold these goods at existing ports with BCPs until official border checks have been undertaken, after which the goods can be released. The proposed BCP at Sevington will create an open door to enable unchecked rest of world high-risk goods to enter Dover and drive through it (which they haven’t been able to do before) and into GB uncontrolled.”

Manzano’s letter continued to say that Defra’s new border control post at Sevington is not fit for purpose, despite continued warnings from DPHA.

“Unfortunately, it has become apparent that to accept DPHA’s data, Defra would have to accept that the data they have used (despite relentless support from DPHA) to plan and decide their infrastructure outcomes on, remains incorrect and thus Sevington as a single site solution for POAO is not deliverable. Defra’s data has been shown to be incomplete and flawed from the very start of this programme,” she said.

“Sevington was not designed to process Dover’s higher volumes of food traffic (82 per cent of food within scope of a check arrives via Dover). As such it has significant capacity and design limitations.

“The plan until articulated to DPHA on 9 November was that Sevington would only process goods arriving through the Channel Tunnel – not as a combined site for all food arriving via Dover and the Channel Tunnel. Its POAO facilities are not adequate to handle the combined food trade arriving via the Short Straights as has been evidenced to Defra.”