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David Wells Chief Executive, Logistics UK

Pressing forward with the Border Target Operating Model

While the Government has released its final version of the Border Target Operating Model, worrying gaps in the detail remain, says Logistics UK's David Wells.

The Government is planning several changes to border processes as part of its Border Target Operating Model (BTOM), which will see new security and Sanitary and Phytosanitary controls apply to imports from the EU.

On 29 August 2023, the Government confirmed a three-month delay to phase one and two of the model before publishing the final version of the BTOM. As a result, the first phase will now go live on the 31 January 2024 and includes 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, as well as full customs controls for non-qualifying Northern Ireland goods.

Phase two, 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, has been put back to 30 April 2024. The date for the final phase, the introduction of Safety and Security Controls on imports into Great Britain from the EU and Rest of World, remains unchanged and is therefore due to take effect from 31 October 2024. This date is also expected to see the introduction of the UK Single Trade Window.

Previously, I have made the point that adaptation of business operations and models, including developing, testing, and operationalising new IT systems will take a minimum of six to 12 months once all the required details are published and that if implementation is delayed, any new date must take into account the adaption time needed. As a result, while members have welcomed a delay to the original published timeline, this is caveated by that fact that despite the final version being announced, not all of the details and guidance required has been published.

Significant gaps still remain, including how the import controls will work for the Short Straits between northern France and Kent; how it will work for operators grouping multiple shipments into single loads, as different products and shipments will have different risk categories and controls; what Common User Charge the government will impose at its Border Control Posts; and publication of the government’s assessment of the state of readiness among EU suppliers and the veterinary workforce.

Given the level of concerns about the impact on inflation, Logistics UK is also calling on government to provide its modelling to evidence its assertion that the cost increases of BTOM will be only 0.2 per cent over three years. In the opinion of Logistics UK, there is little value in giving businesses extra time if they are not also given all of the details they need to plan and prepare.

It is vital that government now listens to calls from industry urging that the remaining guidance is published immediately, and at minimum, with absolutely no delay to the timeline published. SME operators are the backbone of the UK economy, and many operate within the more complex groupage model. It is groupage operators carrying multiple mixed loads, often of lower value, who will be most impacted by a Common User Charge on every consignment.

SMEs are also disadvantaged, compared with much larger operators, when it comes to proposals for Trusted Trader Schemes given the thresholds of access, levels of investment, resource and records required. It is therefore critical that government engages meaningfully with SMEs, and groupage operators in particular, to road test proposals against real life supply chain challenges.

While the final version of the Border Target Operating Model contained some progress, there is still much to be done before the first implementation date in January 2024. With further roll out of the Windsor Framework next year, 2024 will be a year of significant change and challenge for UK traders with expectations of a General Election also in the mix.

It is clear that action is needed to remove and reduce the friction on UK/EU trade when it comes to SPSS goods. One way of achieving this is for the UK and EU to agree a new Veterinary Agreement. Logistics UK again called for this in our submission to government ahead of the Autumn Statement. In the midst of all this change, Logistics UK will continue to do all we can to represent and advocate for our members and the transport and logistics industry.

For more information, please visit: www.logistics.org.uk

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