UK Government Publishes Target Operating Model - IMTA Press Release
The UK Government’s long-anticipated draft Border Target Operating Model (TOM) has finally been published. Though we welcome the continued commitment to the proportionate, simplified and digitised delivery of import controls we are concerned about the timeframe outlined in the draft where crucial details are still missing. Six months is not a long time for introducing health certification for the EU, especially when the simplified certificates are still yet to be published. At a time when the cost of living is front and centre, it is imperative that controls are delivered in a way that is as efficient and effective as possible to avoid too many additional costs to businesses and consumers.
IMTA has been working with government officials and submitting members views on various consultations relating to the new 2025 UK Border Strategy. We are now gearing up to support another government consultation process in relation to the new Sanitary & Phytosanitary (SPS) elements proposed: a new global risk-based approach; simplified and digitised health certification; and trusted trader schemes, whilst assisting members to understand how these will impact meat trading. With the TOM due for final publication in June 2023 we have deep reservations about the effectiveness of the government’s intended consultation period of just 6 weeks and whether it will really take into consideration the views of industry. Despite food industry’s active collaboration, there has not been sufficient ‘co-design’ of the initiatives contained within the TOM so far. Also, for these initiatives to work in reality rather than just in theory there must be sufficient pilots and testing of the different elements of the TOM proposals. It is not clear how effective the pilots testing conducted so far has been either.
We anticipate challenges to meet the implementation time frame proposed, between 31 October 2023 and 31 October 2024, especially for the new requirements to be implemented in the next six months. For meat traders, the phased controls approach means that from 31st October 2023, imports of “medium risk animal products from the EU”, such as raw, chilled and frozen meat, also meat products, will require a simplified version of health certification, which will be a challenge for supply chains. For the second phase, from 31st January “documentary and risk-based identity and physical checks” will be added for “medium risk animal products” from the EU, with imports of rest of the world “starting to benefit from the new TOM”. The current indication is for 100% documentary checks and between 1% and 30% for identity and physical checks, dependent on a new commodity and country combined risk assessment, which requires further clarification. For these checks we would be interested to see the government’s modelling of volumes versus capacity (e.g. of border control post staffing). Finally, on 31st October 2024, Safety & Security (S&S) declarations for imports from the EU will come into force, with fewer fields, reduced from 37 to 24 mandatory and 13 remaining fields being optional.
Katie Doherty, IMTA’s CEO says, “the government should be mindful of the changes which will impact importers from non-EU countries, as well as those importing from the EU.” She adds that “engagement should be focused on ensuring the TOM delivers for all stakeholders: for the government, by ensuring the UK’s biosecurity and borders are safeguarded; for the whole food supply chain, by consulting with firms of all sizes and points in the supply chain; and for consumers, by ensuring the delivery of safe and nutritious food.”
Rosana Verza, IMTA’s Policy Director indicates that “although IMTA welcomes the announcement of a reduced dataset for imports and that the UK Single Trade Window will allow for removing duplication across different import documents such as S&S, SPS, and customs declarations, we will continue advocating that the use of technology needs to be done in a tested way, and in consultation with stakeholders to ensure food safety, biosecurity and that it works in the real trading environment.”