The first phase of the Government’s Border Target Operating Model (BTOM) finally started to come into effect on 31 January.
Uncertainties and concerns over BTOM’s implementation for EU-GB trade were the catalyst for a letter sent to Steve Barclay, EFRA Secretary of State from the SPS Certification Working Group. In the letter the Group, which comprises some 30 trade and professional organisations (representing £100bn of the UK’s food supply, production and distribution chain, enforcers and port health), detailed 16 different concerns, and proposed solutions around four issues: BCPs, groupage, EHCs and Authorised Operator Schemes. Concerns included the lack of details regarding awareness of EU suppliers of the new rules, detail on customs charges, BCP locations, fees, product scopes and opening hours – despite their starting operation of physical checks at the end of April.
The letter sparked national and international media interest with journalists from the UK print and broadcast media, and internationally, all covering the story in some detail. 
CFA DG Karin Goodburn chairs the Group and explains: “The major issues are lack of EU supply chain and system readiness for and flexibility of the new EU-GB requirements, which largely mirror those that have been required for GB-EU since 2021. The system is not designed for fast moving short shelf life just-in-time foods and needs to be redesigned to facilitate trade.
“Government colleagues are doing their best to work through the issues. However, time is not on our side and we are frustrated by the lack of attention being given to major faults in the system that could be corrected, e.g. lack of EU Member State 24/7/365 certifier provision, EHCs (and their translations) available for EU suppliers, tightening of the target APHA enquiry turnaround time and of prenotification windows, wider scope of groupage arrangements taking account of sophisticated electronic traceability from EU source to GB end product. Sadly, it points to a lack of understanding of our industry which will, if not addressed, put even greater pressure on food supply and food price inflation, which affects us all.”
The SPS Working Group is in regular contact with relevant Government departments to seek solutions and clarity however, at the time of, writing it has received no response from the Secretary of State.
The full letter, and background, can be found here.
Photo: Rocco Dipoppa on Unsplash
April 2024