BTOM latest: Industry expresses concerns ahead of new border rules

Tue 30 Jan 2024
Posted by: Danielle Keen
Trade News
Border Checks

New rules derived from the UK’s new risk-based border check system, the Border Target Operating Model (BTOM), will come into force tomorrow (31 January).

Announced in August last year, BTOM followed multiple delays to the introduction of post-Brexit British import controls, despite the EU bringing in similar checks in 2021 immediately after the end of the post-withdrawal transition period.


The UK government suggests a data-driven, risk-based approach to checks on goods will deliver a responsive system that enhances biosecurity. However, some feel uncertainty is being generated by delays, last-minute changes and a lack of clarity around what’s required of EU suppliers and UK importers.

Ahead of tomorrow’s introduction, the Daily Update brings together the latest BTOM stories.

Just-in-time out of luck?

The Guardian reports that the 24-hour notice requirements for deliveries could significantly disrupt the UK’s just-in-time supply chain model, potentially decreasing the shelf-life of imported EU goods by a fifth.

The warning comes from the SPS Working Group, a coalition of UK industry bodies including the Chilled Food Association, Fresh Produce Consortium and Dairy UK, set up ahead of BTOM’s implementation.

The group wrote a letter to Department of Farming and Rural Affairs (DEFRA) secretary Steve Barclay warning that the notification requirements could cause severe delays to deliveries, meaning that “pre-notification is unfeasible for just-in-time supply” to the UK:

“A one-day delay to exportation can mean a 20% loss of shelf life, ultimately rendering the food unsaleable.”

The letter raised a number of additional concerns about the practicality of BTOM implementation, including a lack of Official Vets (OVs) available to carry out health checks and sign off on electronic health certificates, creating additional delays for medium-risk meat and meat products, as well as a lack of clarity around the fixed cost at border control posts (BCPs).

Costs are currently listed as £10 to £43 “per consignment”, despite the definition of a consignment varying between standard customs procedures and those where sanitary and phytosanitary (SPS) rules apply.

In response, a government spokesperson emphasised the importance of the new border rules to UK food security, and said that the government had “worked extensively with traders to ensure the new controls and requirements are clear and not burdensome”.

Artisan exit?

In addition to delays, the weekend has seen several industries expressing concern that some goods will become entirely unviable in the UK market, including specialist goods.

The Independent reports that producers of chorizo and Parma ham, along with French cheesemakers, would consider vetoing UK exports on the basis of additional “hassle” and extra costs.

The Cold Chain Federation, which represents British importers of chilled and frozen foods, said that, for small exporters of specialist goods, “the extra cost per consignment is likely to be hundreds of pounds” and that consequently some EU businesses “might not bother” with the UK market.

The British Meat Processors Association (BMPA) warned that it’s not just supermarkets and their consumers that could be affected by the changes; this could mark a downwards shift in the UK’s food culture as delis, food markets and restaurants struggle to stock quality products.

BMPA trade policy adviser Peter Hardwick described it as “very, very concerning” and said that “the big fear is that smaller EU firms will find it all too messy and costly”.

Valentine’s disruption

A Commons exchange between Labour MP Daniel Zeichner and trade minister Greg Hands put flowers back in the spotlight, with plants and seeds also subject to classification and corresponding checks under the new model.

Zeichner questioned whether the new rules would blight Valentine’s Day, with a potential shortage of roses hitting consumers by the time the holiday arrives in mid-February.

He shared that the Horticultural Trade Association (HTA) had warned that the process of importing plants from the Netherlands had increased in complexity from 19 steps to 59.

Hands responded that, as roses are still classified as low-risk, disruption would remain minimal and focused on the work the government had done to communicate changes.

However, voices from within the industry have been critical. The Independent reports that Chris Bonnett, founder of Gardening Express, said that “consumers will face the brunt of it all with increased prices”.

Head of the HTA James Barnes warned that the new border system wasn’t prepared to cope with the volume of trade.


Complicating the picture are last-minute changes recently made to BTOM’s implementation. Last week, the IOE&IT Daily Update reported that the Department for Environment Food and Rural Affairs (DEFRA) had moved a range of fruit and veg from the low-risk to the medium-risk category.

This means they’ll require additional documentation such as plant certificates to pass through the UK border, potentially leaving businesses that previously thought they has escaped any additional administrative burden scrambling to get up to speed with new requirements.

The news wasn’t formally announced by DEFRA, which made the revision on the Government Plant Health Portal.

FarmingUK reported that the news has been met with frustration by the Fresh Produce Consortium, with CEO Nigel Jenney saying the news “delivers a severe blow to the industry and will have widespread ramifications”, characterising the government as only recently engaging with industry on the best way of introducing checks.

“To enhance biosecurity and alleviate costs for consumers, it’s imperative to establish cost-effective inspection solutions for SMEs, groupage consignments and fast-track approval for responsible companies to conduct their own official inspections.”

IOE&IT perspective

The Institute of Export and International trade’s (IOE&IT) director general Marco Forgione highlighted that, despite concerns, it’s vital that the new rule come into effect to give businesses greater stability moving forward and justify their preparation. He said:

 “If this is happening, it has to happen – we cannot afford another delay.

 “A delay again would not just undermine the investment that has been made by businesses – waste money, time and effort – but will also undermine the credibility of the UK border.”

Need more information?

IOE&IT is committed to supporting members and the wider trader community to prepare for new BTOM rules.

Free resources to support the trader community include last week’s webinar, which you can watch back here, and the ‘BTOM and Beyond’ whitepaper outlining around 20 rules changes that are due to take effect for UK cross-border trade over the next 12 months.

IOE&IT members can also get more detailed advice on how to manage new SPS rules under BTOM by:

For more information about IOE&IT BTOM support for its members, download this one-page flyer here.