Target operating model - update
02 May 2024Procedures for importing food and drink to the UK have changed, bringing more cost and complexity for some traders
Procedures for importing food, drink and other products to the UK have changed, with effect from 30 April 2024.
This is intended to ensure food safety and biosecurity for the UK, whilst also facilitating smooth movement of goods. Key changes are as follows:
Introduction of documentary and physical checks on medium-risk animal products, plants, plant products and high-risk food and feed of non-animal origin from the EU (except for fruit and vegetables and some movements from Ireland – see later)
Reduction in ID / physical check levels on medium-risk animal products from non-EU countries
Inspections of high-risk plants and plant products from the EU now take place at Border Control Posts (BCPs) rather than at destinations
Removal of health certification and routine checks on low-risk animal products, plants, plant products from non-EU countries
Changes were made in-line with the Border Target Operating Model (BTOM or TOM), which specifies new import procedures for the post-EU period. The latest version of TOM was issued in August 2023.
Except for low-risk plants and plant products, traders are required to pay for the new inspections; fees are known as Common User Charges. These are not subject to VAT but will be reviewed regularly by Defra.
Charges are applied to each product listed in a Common Health Entry Document (CHED), with charges capped at 5 lines – the maximum fee, is therefore £145 per CHED for high-risk products and £50 for low-risk products.
Common User Charges, April 2024
Item
Import to UK
Transit through UK
Low-risk products of animal origin
£10
£10
Medium-risk products of animal origin
£29
£10
High-risk products of animal origin
£29
£10
High-risk food and feed not of animal origin
£29
No charge
Low-risk plants and plant products
No charge
No charge
Medium-risk plants and plant products
£29
No charge
High-risk plants and plant products
£29
No charge
Organisations representing businesses have expressed concern over the impact of the Common User Charge.
Fixed fees will be most impactful for those importing small amounts or making frequent shipments and some or all of this cost may need to be passed on to consumers.
However, government publications suggest that Common User Charges will have limited inflationary impact, adding an estimated 0.2% to food prices over 3 years.
Defra also notes that other aspects of the import process should be fairly cheap due to investment in systems. They also compare the cost of Common User Charges to the economic harm that might be caused by disease.
Looking ahead, the final planned set of changes to border operations will occur on 31 October 2024. At that point, Safety and Security Declarations will be needed for goods arriving from the EU.
In addition, some concessions for EU fruit and vegetables arriving will also end and these items will be subject to more rigorous checking.
IGD Viewpoint
So far, it seems that changes have been managed well by both traders and officials, with limited delays and disruption.
Timelines for TOM have been extended several times and this may have helped ensure smooth transition to the new arrangements. There are still several grey areas, however.
It is still not clear on what basis inspections of goods will be carried out, although the government has promised a “pragmatic approach”.
Nor is it clear what might happen if problems are found – for example, if some goods are found to be unfit for entry to the UK, will checks on those goods be intensified?
Getting this right will be essential. Disease has been identified by IGD as a key risk to UK food supply chain resilience and biosecurity is therefore critical, especially in view of novel risks such as African Swine Fever.
We also do not know what view overseas businesses will take of the increased cost and complexity involved in sending goods to the UK. Should they have a negative experience, they may choose not to participate in trade.