Govt publishes final BTOM

The Cabinet Office has today (29 August) published the government’s final post-Brexit Border Target Operating Model (BTOM) for food products coming from the EU.

The first stage of the UK’s new border model, originally set for October, is now delayed until January 2024, with physical checks and other requirements coming in throughtout the next year.

The final version, announced after industry feedback given following the publication of the draft model in April, confirms that fresh fruit and vegetables arriving from Europe will not be subject to pre-notification requirements or UK border inspections.

The Cabinet Office said: “Having listened to the views of industry, the government has agreed to a delay of three months for the introduction of remaining sanitary and phytosanitary controls, as well as full customs controls for non-qualifying Northern Ireland goods, which will now be introduced from January 2024.”

The final BTOM confirms implementation of import controls through three major milestones:

• 31 January 2024 - The introduction of health certification on imports of medium risk animal products, plants, plant products and high risk food (and feed) of non-animal origin from the EU.
• 30 April 2024 - The introduction of documentary and risk-based identity and physical checks on medium risk animal products, plants, plant products and high risk food (and feed) of non-animal origin from the EU. At this point Imports of Sanitary and Phytosanitary goods from the rest of the world will begin to benefit from the new risk based model.
• 31 October 2024 - Safety and Security declarations for EU imports will come into force from 31 October 2024. Alongside this, we will introduce a reduced dataset for imports.
• The final Border Target Operating Model also confirms that new checks and controls will be introduced for Irish goods moving from Ireland directly to Great Britain. In accordance with the Windsor Framework, Northern Ireland businesses will retain unfettered access to their most important market in Great Britain, whether moving qualifying NI goods directly from Northern Ireland or indirectly through Irish ports. A full timeline for introduction of these controls is set out within the Border Target Operating Model.
• In developing the Border Target Operating Model the Government has been mindful of the small potential impact on inflation and has taken into account its firm commitment to bring the rate down. The estimated impact of the Border Target Operating Model on headline inflation is expected to be minor, standing at less than 0.2 per cent across three years.

Nigel Jenney, CEO of the Fresh Produce Consortium, said the FPC welcomed the publication of the final Border Target Operating Model. He told FPJ: “It’s clear: Government has acted upon our long-standing concerns and will now implement a unique border approach for the benefit of consumers and industry. This focused risk-based approach will reinforce UK biosecurity and promote self-regulation to minimise supply chain disruption.

”The several major changes secured by FPC include - EU edible fresh produce will not be subject to pre-notification requirements or UK border inspections. This decision will prevent additional border costs of approx. of £250m annually being incurred by the sector and subsequently hard pressed consumers. 

”We anticipate a similar-risk based approach to be announced shortly for Rest of the World fresh produce and anticipate a reduction in some border controls and associated bureaucracy. 

”This fundamental change of the UK Government’s approach has been years in the making and the FPC team has been at the forefront of developing solutions which promote biosecurity and minimise the impact on responsible companies. 

”However, key challenges remain. This is a bold step forward to achieve our ambition to become a world-leading destination of choice, promoting imports and exports of fantastic fresh produce, flowers and plants.

”Ultimately, where relevant and particularly for the cut flower and plant sector, we need effective inspection solutions for SME’s, groupage consignments and the immediate approval of responsible companies to complete their own official inspections.

”In the meantime, we look forward to receiving confirmation that the proposed Common User Charge strategy will be abandoned by Government.” 

Nichola Mallon, head of trade and devolved policy at business group Logistics UK expressed concern over timings: “Will three months be sufficient time for government to provide the necessary technical detail and guidance that businesses will need to change processes and adapt to the changes outlined by the new trading arrangements?” she asked.

”Logistics UK is studying this final model carefully to see if it addresses the concerns expressed by our members and contains the level of operational detail and assurances they, and their EU suppliers, need to make the changes required in that time frame,” she said. ”With so much to adapt to, and such a short time frame available, it is imperative that logistics businesses are given all the detail they need in the initial plan.

 “Government needs to provide certainty for business on all the details of the new Border Operating Model, and a workable timeline which will allow sufficient planning and implementation time for those responsible for the UK’s supply chain. After so much time, and so many delays, logistics businesses are losing confidence in the government’s ability to provide workable solutions to enable the new trading arrangements to be implemented. Our members need all the detail for how border arrangements are to work, and time to implement the changes - if not, the lack of certainty puts the UK’s supply chain at risk.”

Marco Forgione, director general of The Institute of Export & International Trade, welcomed the ”innovative approach” set out in the final Border Target Operating Model. “The shift to risk based, digital insights and targeting will ensure the smooth flow of goods and maintain strong security and biosecurity controls,” he said.

“The Border Target Operating Model should not be looked at in isolation. There are several other key initiatives taking place as part of the Border 2025 strategy aimed at making the UK border one of the most effective and efficient. This approach has the potential to convert our borders into engines which support economic growth. In addition we encourage Government to move as fast as possible to implement the findings of the customs initiatives announced at the Spring Budget.

“What’s really important is that UK businesses and those trading into UK markets prepare for these changes. The Border Target Operating Model helps to redress some of the commercial disadvantages that UK businesses have been facing.”

Read the published final BTOM here