‘BTOM’ border regulations, introduced today, are flawed, says the international delivery expert ParcelHero. These will require health certificates for many EU animal and plant products, entirely undermining the Government’s new ‘Critical Imports and Supply Chains Strategy’.

The introduction of the Government’s much-delayed new border rules, the Border Target Operating Model (BTOM), brings in compulsory health certificates for many food and plant products from the EU that have not previously required paperwork. The rules go against the Government’s own ‘Critical Imports and Supply Chains Strategy’, introduced just this month, claims a leading international delivery specialist.

The critical imports strategy had been welcomed by many UK manufacturers and logistics companies as an acknowledgement of the supply chain pressures facing Britain. However, the international delivery expert ParcelHero says that, while over 100 British companies had input into the new strategy, there is now a growing concern that the plan fails to address the ongoing impact of Brexit on critical imports.

ParcelHero’s Head of Consumer Research, David Jinks M.I.L.T., says: ‘The Government is showing a marked lack of commitment to its own strategy by already undermining one of its key policies: “Removing critical import barriers to support the UK’s business-friendly environment”. Today’s introduction of new BTOM red tape on a wide range of “medium risk” EU plant and animal products does exactly the opposite.

‘From 31 January, 2024, health certificates are now required on various imports of EU and EFTA origin, deemed medium risk. These new requirements will impact importers of animals, plants and plant products. The certificates must be obtained in the country of export prior to shipment and included in Customs notifications before the goods arrive in Great Britain. Small wonder that the international business advisor MHA is warning: “Failure to obtain the correct certification could result in goods being held at border points, leading to potential stock spoilage and delays in the supply chain.”

‘The Government claims the new rules “will reduce the burden of controls on importing businesses.” ‘In fact, far from reducing the burden, the new BTOM regulations, under which these certificates have been introduced, will create new paperwork and physical checks. These changes are being introduced in stages throughout 2024. Unsurprisingly, the plans are already deeply unpopular with some UK importers.

‘All this BTOM bureaucracy is being rolled out to mirror regulations introduced by the EU after Brexit. It’s interesting that the Government’s new critical imports strategy, while referencing Ukraine and the deterioration of global security in the Middle East as key issues, fails to refer directly to “Brexit” even once. A strategy in denial of one of the key ongoing issues impacting critical imports – increased documentation and checks – is bound to be looked on with some degree of scepticism by British industry.

‘It’s not only red tape on food products that is proving controversial, as there are other areas where the Government’s post-Brexit policies are seemingly at odds with its critical imports strategy. Another key critical goods category the strategy identifies is medicines. Yet we are also facing shortages of medical supplies, because of the Government’s own policies. The Nuffield Trust has warned that there is Brexit-related pressure on UK medicine imports from four sources: regulatory alignment and processes, a fall in the value of the pound, new requirements and paperwork at the GB-EU border and heavy-goods vehicle shortages. It’s a view that was endorsed by the Independent Commission on UK-EU Relations in November.

‘It is also concerning that, while the strategy emphasises the importance of removing critical import barriers, it has far less to say about encouraging UK exports, which is the other key link in our global supply chain. As the trade association Composites UK says: “Whilst the report is specific on imports, the UK’s export controls continue to give our members frustration.”

‘Moreover, the strategy says: “Through free trade agreements (FTAs), states can identify and agree to remove tariff and non-tariff barriers to trade and agree joint strategies on measures such as diversification or information sharing.” All very laudable, but it’s a shame it was released in the very month the Government’s free trade discussions with Canada collapsed, threatening significant tariff increases on British-built cars, the UK’s chief export to Canada.

‘On the subject of floundering FTAs, the potential damage to the Northern Ireland Good Friday Agreement created by Brexit also means that US President Biden’s government is in no hurry to ratify a US-UK Free Trade Agreement. While our trade with America has not suffered a similar upheaval to Brexit, there are still significant hurdles surrounding it. ParcelHero’s USA page gives full details on Customs advice, sending food, prohibited items, etc.