Representing members engaged in the international meat trade

IMTA Statement on the BTOM

by Mej Del Rosario | 29 January 2024 at 12:25

After successive delays, the first stage of implementation of the Border Target Operating Model (BTOM) is upon us. Government has been adamant that another delay is not on the cards: at 1 minute past midnight on Wednesday 31st January the UK will roll out new requirements on imports from the EU. IMTA is working hard to support members with the change with briefings and troubleshooting support.

The previous delays were given to allow business and government more time to prepare. Businesses have been working furiously to get ready, but preparations have been hampered by the ongoing absence of certain key information, or the release by government of detail at too late a stage.

Three key outstanding questions remain:

  1. What are the details of 24-hour support being planned by government to support traders with the changes?
  2. Do EU certifier capacity assessments take into account in-country location and daily availability of certifiers?
  3. With a requirement to pre-notify one working day in advance from 31st January what are companies who are unable to do this due to geographical or other constraints advised to do?

Pre-notification is a particularly important issue and has been voiced by many in the industry. The requirement to pre-notify imports of meat from the EU one working day in advance is completely unworkable. Members have cited a range of reasons including for shipments from EU border countries like France and Netherlands where goods are loaded less than 24hrs before transport; in case of system crashes; for chilled goods with limited shelf life; and Monday crossings where vehicles set off over the weekend. Individual Port Health Authorities may provide derogations in some cases from April 30th but until then government cannot reasonably expect just-in-time trade with the EU to cope and for food supply to continue if this 24hr requirement is imposed this week.

We understand that for certain member states the translations of crucial Export Health Certificates (EHC) were only uploaded to TRACES in the last few days, leaving very little time for EU vets and companies to prepare to issue them starting 31st Jan.

Katrina Walsh, IMTA Strategy Director, commented:

“None of these barriers to preparedness are due to lack of engagement or commitment of UK traders. Members have sought to make arrangements for readiness in good faith. We now call on government to be clearer on the approach between now and April 30th when the next set of requirements come in. A pragmatic and educational approach is crucial, government must detail what this entails in order to maintain a level playing field and ensure food supply. Companies seeking to serve the UK consumer must know where they stand.”

Government must also recognise that the April 30th deadline, at which physical checks and sampling of EU imports begin, and changes to imports from the Rest of World take place, is looming large. Members need the following questions answered without delay:

  1. What will be the frequency of ID and physical checks on EU and Rest of World imports?
  2. What will happen to product on a groupage load if one consignment on the truck is required to attend a Border Control Post for checks? Will product be unloaded and allowed to proceed?
  3. Which Border Control Posts will provide a 4hr derogation to prenotification and in which specific circumstances?
  4. Have CDS, ALVS, GVMS and IPAFFS system links been tested sufficiently, to avoid delays?
  5. How will the driver messaging system work and will it be available in a range of languages?
  6. Is UK lab capacity sufficient to handle volume of checks on EU product from April?
  7. How much will the Common User Charge (CUC) be?

IMTA will continue to work with members to ensure that industry is prepared for the April phase of import controls. IMTA will also continue to represent members’ interests to government to ensure that controls can be implemented as smoothly and efficiently as possible.

IMTA is a UK trade association, representing predominantly UK companies importing and exporting meat. Our goal is the facilitation of the trade in meat ensuring UK consumer choice, food security and carcass balance through import and export. IMTA provides leading trade expertise on UK trade policy including on customs, tariffs, quotas, rules of origin, WTO, trade agreements, SPS conditions and market access.