On 30th April, the UK Government introduced its next phase of border controls under its ‘Border Target Operating Model’ (BTOM), which was published in August 2023. This phase builds upon the customs controls, declarations, pre-notifications and health certifications introduced in January for imports from the EU and focuses on implementing documentary and risk-based identity and physical checks at UK Border Control Posts (BCPs) for goods subject to sanitary and phytosanitary (SPS) checks from the EU, excluding Ireland.
The key changes are;
- ‘Medium’ risk products: from a biosecurity perspective will now undergo identity and physical checks, which test for pests and diseases that could impact the safety of our food and harm the UK’s natural environment. Checks involve visual inspections and temperature readings of goods.
- ‘High’ risk products: will now be checked at the border whereas previously these goods were checked at the destination. These checks will be aimed at identifying public health issues such as salmonella, and build on existing safeguarding measures which identify diseases like African Swine Fever, which is now prevalent in certain European countries and poses a significant risk for UK pig farms.
Separately, the UK Government has also published the BTOM risk categorisations and check rates for imports of live animals, products of animal origin (POAO) and animal by-products (ABPs) from the EU, Switzerland, Norway, Iceland, Liechtenstein, the Faroe Islands and Greenland to Great Britain. The inspection rate (percentage of times a product will be subject to identity and physical checks) depends on the risk category to which it is assigned, and is set out as follows:
- High risk commodities: will be inspected every time the product is imported (inspection rate 100%).
- Medium risk commodities: will be inspected at a rate between 1% and 30%.
- Low risk commodities: will not be subject to routine inspection, but they may be subject to non-routine or intelligence-led checks.
Further information on the inspection rates and associated requirements for the full range of products subject to SPS checks is available via; https://www.gov.uk/government/publications/risk-categories-for-animal-and-animal-product-imports-to-great-britain/target-operating-model-tom-risk-categories-for-animal-and-animal-product-imports-from-the-eu-to-great-britain
Importantly, checks on products entering Northern Ireland will be subject to the provisions of the Windsor Framework, which de-facto, permit Northern Ireland to continue to be part of the EU Single Market and Customs Union as regards agri-food goods. Accordingly, none of the additional checks or controls set out in the BTOM apply to imports into Northern Ireland from the EU.
For imports coming in from Ireland (i.e. Republic of Ireland), the Border Control Posts in Wales are under construction and are unlikely to be functional until the spring of 2025. Accordingly, the implementation of physical checks will be delayed until next year with a date to be confirmed.
In terms of the controls that have been introduced on April 30th, there have been some issues with key systems such as IPAFFS – the system used to manage the import of products subject to SPS controls. There have also been challenges with the extent of coordination between Defra and the HMRC on issues relating to the Automatic Licence Verification System (ALVS) – the system used to match customs and SPS documentation to a given vehicle. Whether these are just teething problems or will develop into longer-term issues remains to be seen.
Overall, it is crucial from a biosecurity perspective for the UK to have a fully-functioning border control system and that the gaps in the system following the UK’s departure from the EU are getting addressed. That said, such controls necessitate the imposition of friction at the border which means additional costs for businesses when importing from the EU. This will create some inflationary pressure and will likely lead to less choice for some agri-food products, particularly those supplied by small and medium-sized enterprises (SMEs).
