Target Operating Model: Impacts for the food industry

Date : 13 April 2023

The Government has published the Target Operating Model (TOM), setting out how trade will operate between the UK and the rest of the world.

IGD Viewpoint

The Target Operating Model is an important step forward to the UK’s border regime following the UK’s exit from the European Union. The plan for the model is ambitious, and if successful will provide a bio-secure border for the UK whilst supporting business need for a smooth border operation.

The ambition is welcomed, as is the period of consultation in the coming weeks. However, the plan details significant changes to IT and physical infrastructure. Given the importance of importing to the UK’s food system, it is critical that the implementation is carried out effectively.

While the plan is detailed, it is likely to be difficult to cover off all eventualities. In the cases of EU Exit, the NI Protocol and the Windsor Framework, businesses have had specific issues or questions which official outputs have not initially covered. Any plans will need to be able to react quickly to unforeseen impacts. Businesses can support by providing detailed feedback by 19 May.

The plan sets out a period of engagement with overseas suppliers, however, it is not certain that they will be willing to engage. These businesses are likely to require a lot of support and help from their UK partners.

The effectiveness of change will be tested in the first days and weeks at border checkpoints. Preparation, training and focus from all parties will be critical.

What Is the Target Operating Model

In April 2022, the UK government opted to delay the final phase of its planned border implementation covering sanitary and phytosanitary (SPS) goods moving from the EU to the UK.

In the period since then, the government has been working on the Target Operating Model, a long-term border plan aiming to balance the need for a secure border with the needs of business for a simple border system.

The draft plan for the Target Operating Model proposes a new approach to importing food and goods into the UK.

The model is split between customs changes that apply to all goods being imported and goods that require SPS controls, this applies to food and non-food goods.

For the customs checks that apply to all goods, the new model will look to reduce the Safety and Security data requirements, making it easier to submit data through a UK Single Trade Window and improve the use of data by the UK Government to reduce duplication.

Certain movements such as outbound freeport goods, outbound transit and fish from UK waters landed in non-UK ports will have Safety and Security requirements removed entirely.

For goods that have SPS controls, there will be a new global risk-based approach with simplified and digitised health certificates, piloting trusted trader approaches.

Central to the plan is the UK Single Trade Window, providing a single digital point for both importers and exporters to provide the necessary data to trade, apply for licences and achieve authorisation for trusted trader schemes.

How will the Target Operating Model change food supply chains?

The food industry is likely to be most impacted by the changes to the SPS checks. Other industries such as horticulture are also heavily affected by these changes. It is welcome that the complexity of the food supply chain is recognised in the document with the government offering support wherever possible.

SPS goods will be categorised by a new approach focusing on the inherent risk that the commodity poses alongside any risk posed by the country of origin.

For example, commodities that are produced in two distinct countries may have different risk profiles. It is important to note that the regime will recognise the EU as a single entity.

The risk model will be dynamic, and risk categorisations will be subject to change in response to changing health risks.

There will exist emergency safeguarding measures to allow an immediate response to emerging threats or outbreaks.

The industry will benefit from reduced checks on medium and low risk products alongside simplified export health certificates and electronic phytosanitary certificates for the import of plant and plant products.

Trusted trader schemes will develop assurances equivalent to official controls so that biosecurity and food safety risks can be managed on trusted trader premises.

Three trusted trader schemes will be piloted to support those importing SPS goods:

  • The Authorised Operator Status will focus on plants and plant products
  • The Accredited Trusted Trader Scheme and Technology Assurance Scheme will be focussed on Products of animal origin and animal by-products

How will the Target Operating Model be implemented?

The Target Operating Model will be introduced in a phased approach. There is a firm intention to meet these milestones and businesses should begin to work with their supply chains to prepare.

From 31 October 2023:

  • Export Health Certificates and phytosanitary certificates will be required for medium risk animal and plant products that are imported from the EU.

From 31 January 2024:

  • Identity and physical checks will be introduced for medium risk animal, plants and plant products as well as high risk food of non-animal origin from the EU.
  • Medium and low risk products of animal origin will see reduced checks.
  • Lower risk plants and plant products will no longer require pre-notification.
  • Inspections of high-risk plants and plant products will move to Border Control Posts or Control Points.
  • Pilots for trusted trader schemes for animal products will begin.
  • Pilots for plant and plant products Authorised Operators will begin.

From 31 October 2024:

  • Border Control Posts will come online throughout 2024. Checks of live animals will be carried out at these locations.
  • Safety and Security declarations for EU imports will be in force from 31 October 2024.
  • The UK Single Trade Window will remove duplication across different pre-arrival datasets.

What happens next?

The plan for the Target Operating Model at this stage remains a plan and the government intends to gather feedback from stakeholders.

There will be a period of engagement activity until 19 May, commencing with an all-stakeholder call on 19 April. To sign up for these sessions please click here.

The engagement will be centred around four key questions:

  • What are your views on the new model for Safety and Security controls, their impact on businesses and their implementation?
  • What are your views on the new model for Sanitary and Phytosanitary controls, its impact on biosecurity, animal health and welfare, food safety, businesses, as well as its implementation?
  • What challenges exist for the private sector in meeting the proposed timeline for introducing the new model, and how can specific business models for importing be further supported to prepare?
  • What further detail is needed in order for businesses to prepare for and implement the new Border Target Operating Model?

Businesses are encouraged to provide feedback to the above questions through the stakeholder sessions or through written feedback via the online portal, by e-mail to [email protected], or by post to Borders Group, Cabinet Office, 100 Parliament Street, London SW1A 2BQ

Simultaneously, DEFRA will be carrying out significant engagement across Europe to ensure businesses exporting to the UK are prepared for the changing regime.

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