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EU/GB border controls update:

Tightening of the rules in the Border Target Operating Model on April 30

On April 30, a tightening of the rules in the Border Target Operating Model (BTOM) is set to come in for GB imports from the EU after a 'bedding in' period. The BTOM mirrors border controls put on UK exports to the EU, put in place after leaving the EU and fulfilling the World Trade Organisation rules.

The UK border controls introduce key elements of pre-notification via the Import of Products, Animals, Food and Feed System (IPAFFS), health certification (both Export Health Certificates (EHCs) for animals and animal products and phytosanitary certificates for plant products), as well as identity and physical checks.

BTOM applies to all goods entering GB, though goods are categorized by risk. The only exception to BTOM is movements to/from Northern Ireland, which are governed by the Windsor Framework. You can check the risk category of animal and animal product imports using this link.

What will we see from April 30?
First, Border Control Posts (BCPs) will become fully operational, with identity (seal) and physical checks on goods entering BCPs or Control Points (CPs) for high- and medium-risk animals, plants, and products. As mentioned above, a pre-notification will be required for goods as they head through a BCP, as well as some additional cost, for example, a Common User Charge for consignments entering GB via government-run BCPs in England and Wales and potentially Scotland in the future.

April 30 will see the tightening of documentary checks for both medium- and high-risk plant and animal products coming into GB. For medium-risk EU animal products entering GB, these will be subject to 100% documentary checks and between 1 – 30 % identity (seal) checks. Identity (seal) checks will be at random, though for those consignments that have a non-compliance on the seal check, a physical check may be conducted. High-risk animal products will see 100% identity checks.

For medium-risk EU plant products, risk-based documentary, physical, and identity checks will take place. Checks are reported to have a baseline of 3% for EU and 5% for non-EU imports.

Though from April 30, there are reportedly more relaxed rules coming in on imports from non-EU countries according to Defra. These include the removal of health certification and routine checks on low-risk animal products, plants, and plant products from non-EU countries. This is also alongside in the reduction in physical and identity check levels on medium-risk animal products from non-EU countries.

So, what does this mean?
Generally, UK meat and dairy producers have broadly welcomed these measures, who feel the playing field is finally being leveled with their EU counterparts. How much opportunity any change in cost competitiveness of EU imports or ease of access may create for domestic producers will likely be limited in the long term by production capacity in both the meat and dairy sectors.

Short term, with these new rules coming in, we could see some initial teething problems for some companies importing EU products into GB from some additional documents, checks and costs required, before finding the 'new normal'. For example, EHCs (and vet signatures) are needed for medium-risk EU animal products heading into GB. This is something to watch closely in terms of volumes entering GB going forward. Document checks are set at 100%, but identity checks are much lower, taking some pressure away from potential waits at BCPs.

Overall, as we saw when additional requirements were placed on GB exporters after the UK left the EU, it is likely that small and medium-sized businesses could feel most impact from these changes, especially for moving multiple products/from multiple pick-up spots. Something to monitor going forward in what we are importing and from where.


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