Trade Insights: What you need to know ahead of the first wave of BTOM changes this January

Fri 19 Jan 2024
Posted by: Danielle Keen

SPS goods in front of British passport and EU flag

January is a period of change for many, as we all look to modify our behavior and achieve our goals. For those responsible for importing food into the UK, it’ll be the beginning of a range of new behaviours as they get to grips with new requirements for importing plant and animal products from the EU.

The Institute of Export and International Trade’s (IOE&IT) resident sanitary and phytosanitary (SPS) expert, Laura Williams, gives IOE&IT members some exclusive tips on what businesses can expect in the coming months, an explanation on the new risk-based categories and a few pointers for staying on-track in this period of change at the border.

What are the changes?

In 2024, the most immediate changes coming into effect begin on 31 January with health certificates being required for medium-risk category products imported from the EU.

This will include animal products, plants, plant products and high-risk food products of non-animal origin.

Importers must be registered on the Import of Products, Animals, Food and Feed System (IPAFFS) in order to notify authorities ahead of goods reaching the border – attaching a digital version of the product’s export health certificate.

A grace period will be given to European exporters ahead of documentary and risk-based identity and physical checks being carried out from 30 April.

Calculating risk

Explaining the emphasis being placed on the medium-risk category, Williams said: “High-risk has already been happening, which is why checks will be focused on medium-risk products.”

“This is where the biggest change is happening and, crucially, it’s also the largest category within classifications: most goods – the majority – fit into the medium category for now.”

Given the danger posed, 100% of high-risk animal products, such as live animals, germinal products (animal embryos or even hatching eggs, for example) and products already under safeguard measure, will require a full raft of checks and documentations.

This includes pre-notification, simplified health certificates, documentary checks, and identity and physical checks at the border.

By contrast its estimated that up to 30% of medium-risk animal products will be subject to identity and physical checks, with approximately 3% of medium-risk plant products from the EU being similarly examined. 

And the category is?

Williams is keen to highlight that product categories aren’t fixed. “The biggest thing that's important to note,” she says, “is that these risks will be changing, they're not static”.

“Based on the information DEFRA gathers throughout the next weeks, months and years, there will be fluctuation within those categories.”

While this means that businesses will need to keep a close eye on whether their products have changed category, it also offers potential long-term benefits as products routinely crossing the border with minimal issues will have their risk-level and corresponding requirements downgraded.

“My personal view is: what we start with this month, in terms of product categorisation, isn’t what we’ll end the year with.

“There will be easements and we will see fluidity in those categories, even in that short period of time.”

Williams believes this will lead to many products currently listed as medium-risk falling into the low-risk category by the end of the year.

“Low-risk products do not require certificates, there are no checks there, so ideally you want to be a product that's moved from a medium- down to low-risk.”

Improved safety

It’s not just businesses that the data-informed, digitised border will benefit. This approach should have applications for ensuring high standards of food safety by enabling a swift response to threats – such as increasing checks for products arriving from areas experience a disease outbreak, for example.

Williams warned that the “UK's approach to risk cannot just depend on the product being brought in, but where it's coming from.”

“This is an overlooked reason as to why BTOM is significant: we've already had these rules and regulations in place for the rest of the world, now we’re bringing our relationship with Europe up to those same standards.”

21st century border

This reflects BTOM’s role within the government’s broader efforts to digitise the UK’s border and create a simpler, more efficient process for the country’s traders.

In addition to being data-driven and reactive to changing risk levels, there are aspirations to build better on the input end of the process, with the government’s proposed ‘single trade window’ enabling traders to lodge all information digitally through a single portal.

In theory, this would facilitate export health certificates being pre-lodged via the ‘single trade window’ instead of creating the need to register for a new system, as is the case for many traders with IPAFFS.

Practical tips

In order to prepare for potential hiccups as the new system gets underway, Williams suggests businesses importing EU food and drink products shore up logistics fundamentals, such as factoring additional time into supply chain to account for a certain percentage of movements being pulled aside for checks.

Cost in another key factor. The introduction of health certificates creates new approval steps in the customs process. “It’s not just the purchasing of the export certificate but the additional brokerage and administration fees,” Williams says.

This applies to brokers negotiating the UK border on your behalf, as well as other milestones in the import journey, such as the new fee incurred for inspection in UK warehouses.

Finally, to better navigate all changes, Williams also recommends ensuring strong lines of communication exist among all links in the supply chain: the business, suppliers, exporters and any other intermediaries involved.

Laura Williams is also one of the panelists on the IOE&IT's Special Interest Group (SIG) for the food & drink industry. 

Keep an eye out for updates on the next SIG meeting, including dates and the theme of the session, here.