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New Border Target Operating Model 'a half-baked plan' says FPC Chief

The government has unveiled its new Border Target Operating Model (TOM) as a simplified approach to border inspections that it claims will save companies £400 million per year.

After three years of delays, the Cabinet Office claims it has the "firm intention" to launch the first phase of restrictions in October of this year.


The UK Single Trade Window will be live on October 31, 2024, providing merchants with a single point of contact for all relevant information. This should streamline the procedure and eliminate the need to enter the same information many times.


Health certification is required for medium- and high-risk food goods by October 31, 2023.


Trusted trader pilot begins with "major food importers" on January 31, 2024 and physical examinations begin on the same date, with medium- and high-risk foods.


While the exact dates will be announced later this summer, the present proposal is for a phased rollout that will include an expansion to rest of global commodities in January 2024.


The main difference under the new approach is that most processed, shelf-stable items will be deemed 'low-risk,' which means they will not require export health certifications or routine physical border inspections when entering the UK. This is a departure from the UK's (and the EU's) previous policy of conducting inspections on all foods recognised as posing a danger, no matter how little.


It does not, however, eliminate all border friction on these items. Businesses will still need to notify officials in advance of what they want to import and only go via ports with appropriate border control installations.


There is also much uncertainty about what constitutes a 'low risk' situation. This is due to the fact that low risk is decided not only by the product itself, but also by its origin. "This means that a commodity from one country may be in the low-risk category, but a commodity from another country may be in the medium-risk category," the government explains.


"We are proceeding with a half-baked plan that will harm the industry and hold the government directly liable for fresh product inflation."

The industry is up in arms about this. "Everyone is asking: what does this mean for my product?" asks one manufacturing source. "That's the annoying part. This level of information is required to plan and move forward with this."


The greatest challenge, arguably, is the timing, with the introduction of additional regulations coinciding with the implementation of new labelling rules on meat and fresh milk in Northern Ireland under the new Windsor Framework, making October a daunting month for many companies.


To alleviate some of the strain on imports, the government has proposed a trusted trader system for frequent and dependable importers, which would allow medium-risk products to be imported at their own facilities rather than at a border station.


As it is, such trusted trader programmes exist only to facilitate customs inspections, but the intention is that it will be expanded to include sanitary and phytosanitary (SPS) controls required on animal and plant goods in January 2024 following a trial with "major food importers" in January 2024.


The timeframe appears to be ambitious. The government intends to conduct "an extended period of co-design [with industry] followed by pilots," which it anticipates to last six to twelve months beginning in January.


This would leave the sector facing inspections without access to the system for more than a year, which is an undesirable scenario, as suppliers argue that a trusted trader scheme should be implemented from the outset to avoid major disruption.


Without the system, any products selected for inspection must travel to a border inspection point and may be kept for up to four hours while inspections are performed. "This basically means I've doubled my distribution costs, while the supermarket distribution and wholesale markets expecting those goods simply won't get them in time," explains Nigel Jenney, Chief Executive of the Fresh Produce Consortium.


The most frustrating aspect is that, despite Jenney and others having been in conversations with the government for at least a year, explaining why certain initiatives are necessary, "the UK has backtracked to a highly burdensome administrative process," claims Jenney.


"We are proceeding with a half-baked solution that will harm the industry and hold the government directly accountable for fresh produce inflation," Jenney added.

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