Brexit – Border Target Operating Model published setting rules for imports

Brexit continues to sit high on CFA’s agenda, with the Association leading in Government engagement on the future of trade between Great Britain, Northern Ireland (NI), the EU and Rest of the World (ROW).

As reported in CFA News #59, CFA continues to lead the SPS (Sanitary and Phytosanitary) Certification WG in Government engagement on the future of trade between GB, NI, the EU and the ROW.

The UK’s Border Target Operating Model (BTOM) for imports has now been published, introducing new SPS certification requirements starting from 31 January 2024 for certain medium risk foods such as products of animal origin (POAO) from the EU. This represents a three month delay to the fourth delayed original implementation date.

There is also a three-month delay to the introduction of identity and documentation checks on medium risk POAO, plants and plant products, to 30 April 2024. The original 31 October 2024 date for the introduction of Safety & Security declarations for goods imported from the EU or other waivered territories remains unchanged.

The aim of the BTOM is to balance the need for imports for food security with the need to protect animal and human health from imported disease. From October, the Windsor Framework (WF) agreed in March will result in POAO imported into GB from ROW not being able to be included in foods sent to NI unless they have been ‘processed’ in GB. The ‘Not for EU’ label starts to be required in October for UK SPSsubject foods not having been certificated with an Export Health Certificate (EHC).

There remain a number of key issues to be resolved, including unclear definitions of ‘consignment’, ‘processing’ and ‘FBO number’ and the lack of a consolidated BTOM and WF timeline of milestones for FBOs to work to. CFA Director Karin Goodburn: “The lack of detail and clarity of terms and repeated delays to publication of the BTOM puts at risk the ability of GB industry to feed NI and how to advise EU ingredient suppliers of new requirements.

“EHCs needed for exportation to the EU are costing GB food industry about £4m a month and are to be required for sending SPS foods from GB to NI through the ‘green lane’ starting in October. EHCs will also be imposed by GB onto EU suppliers in January, potentially resulting in reluctance to supply GB with food. Given that more than half of all food comes from or through the EU, this again creates extra pressure on food supply. “

September 2023

Photo credit: Habib Ayoade on Unsplash