GB Border 23 SPS

6. 1.3. The new Sanitary and Phytosanitary goods model for Great Britain

6.1 Background

Import controls are a critical element of all effective biosecurity and public health systems. They protect public health, plant health and animal health and welfare. Controls provide assurance, they allow the interception of non-compliant consignments and they enable the tracing of goods if an incident arises. Controls ensure that consumers have confidence in imported plant and animal products and they underpin our exports to our global trading partners. The threats posed by imported food and feed, and live animals, are ever present and dynamic and our controls will reflect and respond to this, protecting consumers while ensuring they can safely access the products they want.

The UK is party to World Trade Organisation treaties that require a level playing field for Sanitary and Phytosanitary controls across our trading partners. The World Trade Organisation Sanitary and Phytosanitary Agreement recognises the rights of all members to apply necessary controls to protect their public, animal and plant health. Measures must not be applied in an arbitrary or discriminatory way.

It is therefore critical that the Border Target Operating Model retains the mechanisms recognised and applied across the world as the key building blocks for animal, public and plant health import controls. Doing so will provide protection for the UK and ensure our trading partners have confidence in our exports.

To help provide assurance of the robustness of the approach set out within the Border Target Operating Model, we will work closely with enforcement bodies to ensure that is an appropriate level of enforcement for both personal and commercial imports. For imports of animals, animal products, plants and plant products we will encourage a compliance first approach. This approach will actively support importers and the public, by enabling them to move compliant goods into the UK. Backing up this compliance first approach will be robust, intelligence led, enforcement controls on illegal activity. This will help reduce the biosecurity risk posed, both to the public and the environment, from non-compliant goods entering the UK.

Engagement with the Crown Dependencies, the Bailiwick of Guernsey, the Bailiwick of Jersey and the Isle of Man, is continuing, with respect to application of the Border Target Operating Model in their territories, to maintain frictionless movement and trade with Great Britain.

6.2 How we have responded to stakeholder feedback

Stakeholders provided wide-ranging views on the new model for Sanitary and Phytosanitary goods. These focussed both on the need to take caution when implementing novel approaches to biosecurity to ensure they maintain robust controls, and highlighting where more could be done to ease the burden of new processes and requirements on businesses. To that end we have made refinements across the model. Specifically:

• We have revised the timeline for the introduction of the global sanitary and phytosanitary model. Health certification on EU goods will now be required from 31 January 2024, with physical and documentary checks introduced from 30 April 2024 along with the new model for non-EU goods.
• We have published further detail of the risk categorisation of specific commodities. This can be found here for animal products, and here for plant products, and allows importers to search for specific commodities.
• We have set out further detail on the new Trusted Trader pilots, the timeline for these, and details on applying for them.
• We have designed a new Certification Logistics Pilot to support movements of goods from hubs in the EU.
• We have provided further information on how we will support importers using groupage models to move Sanitary and Phytosanitary goods into the UK.

6.3 Overview of the model for Sanitary and Phytosanitary goods

The Scottish, Welsh and UK Governments have worked together to develop the new model for the import of Sanitary and Phytosanitary goods. Although enforcement of biosecurity controls are within devolved responsibility, it is in all our interests to have a coherent border control regime across Great Britain.

Our goal is to create a modern border system with a streamlined and effective global risk-based system of Sanitary and Phytosanitary controls that enables us to respond rapidly to changing risk profiles. This will help us to protect public, plant and animal health and welfare, boost our economic growth, and minimise friction at the border.

We want to improve on the model used by the EU in a number of ways, by introducing;

• A global risk-based, targeted approach to official border controls on imports of all origins;
• Pilots of trusted trader assurance schemes that provide credible evidence to support facilitations and;
• Simplification and digitisation that makes the best use of data.

Sanitary and Phytosanitary goods will be categorised based on the inherent risk (high, medium or low) that the commodity poses to animal health and welfare, food safety and biosecurity, alongside any risk specific to the country of origin. The level of controls applied will be proportionate to the risk, for example the prevalence of pests or diseases and the standard of official health controls.

In developing the global import model for Sanitary and Phytosanitary goods we have balanced the need to protect the UK from biosecurity and public health threats; the need to give businesses and trading partners time to prepare, and so prevent disruption for consumers; and the speed at which the technology and infrastructure can be put in place.

Key to the model is shared governance across England, Wales and Scotland of the new risk-based approach to Sanitary and Phytosanitary controls. This governance and expertise involved will be critical to ensuring that the model responds to emerging threats.

As part of the new model we will pilot new Sanitary and Phytosanitary assurance schemes for authorised Trusted Traders. The pilots will be co-designed with industry over 2023 before they go live from January 2024. There will be separate pilot schemes for plants and plant products and for medium risk products of animal origin and animal by-products. Some high risk food and feed of non-animal origin could be considered for future inclusion.

These pilot schemes will seek to develop assurances that are equivalent to official controls by building on existing systems and data that traders have in place to directly manage biosecurity and food safety risks with added government oversight. All members of these schemes will be held to the UK’s high biosecurity and food safety standards and will be presented with different options for providing the authorities with such assurance, with exploration of a range of benefits to traders in return (e.g. a reduction in the level of Border Control Post checks).

Details of the specific proposals for plant and animal products are set out in the sections below. While these will only be pilot schemes at this stage, the intention is to be as ambitious as possible in their design to maximise their benefits while protecting biosecurity, animal and public health. We would welcome interest from all major food importers and intermediaries in participating in the pilots.

Governance of these pilots will be overseen by a governance structure across England, Wales and Scotland, assuring that the pilots and any scheme which evolves from them will not compromise biosecurity, animal health and welfare, public health or consumer protections. A robust and detailed evaluation of the pilots, that appropriately balances benefits to traders and the assurance of biosecurity and food safety, will be undertaken before any decision to scale them up is taken.

6.4 Food Security

The resilience and reliability of food supply chains, and ensuring no disruption for consumers, is a key objective of the Government as set out in last year’s UK Government Food Strategy. In implementing this new control regime for the first time on EU imports, we will carefully monitor the range of potential risks, including those that may impact food supply chains and consumers. Where possible we will work with importers to try to manage those risks in a structured way, considering whether there are appropriate contingencies which we can deploy if and when required. We recognise that this new model for importing Sanitary and Phytosanitary goods will require some businesses and their supply chains to adapt their business models. Details of how we will work to support businesses operating different models for the importing of these goods are set out below.

6.5 Navigating this section of the document

The following sections set the detail of how the new model applies to different types of Sanitary and Phytosanitary goods:

• The section on importing live animals, germinal products, products of animal origin, animal by-products and high risk food and feed of non-animal origin explains how to import these goods to Great Britain under the new model.
• The section on importing plants and plant products explains how to import these goods to Great Britain under the new model.
• These sections are followed by details of the timeline for implementing the new model for Sanitary and Phytosanitary goods and an overview of how we will work to support different models of importing such as managing groupage and re-exporting.
• Detailed example user journeys for the import to Great Britain of Sanitary and Phytosanitary goods are set out in Annex C.
• The requirements for moving Sanitary and Phytosanitary goods through Great Britain on transit are set out in section 1.4.

6.6 Importing Live Animals, Products of Animal Origin and Animal By-Products under the Border Target Operating Model

Risk categorisation

• Live animals, germinal products, products of animal origin and animal by-products will be categorised as high risk, medium risk, or low risk. Each category will have a proportionate level of control.
• The categorisation is based on the inherent risk that the commodity poses to animal health, food safety and biosecurity, and public health, alongside the risks specific to the country of origin e.g. the prevalence of pests/diseases and the standard of official health controls. This means a commodity from one country could be in the low risk category but the same commodity from a different country could be in the medium risk category.
• Risk categorisation of Sanitary and Phytosanitary goods by country/commodity combination, has been undertaken by Defra, the Food Standards Agency, Food Standards Scotland and devolved counterparts. The risk categories for imports of live animals, germinal and animal products from the EU and EFTA countries have been published. Risk categories for imports of live animals, germinal and animal products from non-EU countries will be published in August 2023.
• Risk categorisation is a dynamic process drawing on the most current data and reflecting changes in disease status, however, it is not expected that the initial risk categorisation will change, for the majority of commodities. There are a small number of commodities placed in low risk from January 2024 pending further risk assessment. This will provide businesses with stability and avoid the need for frequent operational changes. Where changes in risk categorisation are made, official notification will be made to trading partners. Businesses will usually be given 3 months to implement the change.
• In addition, this framework can be overlaid with an assessment of importer compliance in the case of Trusted Trader schemes (see Trusted Trader section). Other risk considerations, including emerging intelligence, will also inform decisions on categorisation.

Controls that will be applied to live animals, germinal and animal products based on their risk categorisation

Controls will be applied to goods proportionately based upon their risk categorisation:

• Import of consignments categorised as high risk (predominantly live animals, germinal products and goods under safeguard measures) will require pre-notification, simplified health certificates, documentary checks and identity and physical checks at the border. In most cases, live animals will be subject to 100% identity and physical checks. Some exceptions to the requirement for 100% checks for animals are set out below. These include lower check rates for some types of high health equines (e.g. race horses) from low risk countries, some zoological animals and some live aquatic animals.
• Import of consignments categorised as medium risk will require pre-notification, simplified health certificates, documentary checks and be subject to risk-based identity and physical checks at the border. Some will be set at 1% physical and identity checks, although other goods will be considerably higher based on specific risks. A Trusted Trader scheme for medium risk consignments will be piloted.
• Import of consignments categorised as low risk will have minimal routine border controls applied. There would be no requirement for health certification or routine physical border checks, although there will be provision for intelligence-led intervention on low risk products. Provision of a pre-notification data set and commercial documentation will be required for all low risk animal products. Goods classified as low risk would still need to enter via a port that has a Border Control Post designated for that type of commodity.

To ensure that the risk categorisation remains appropriate over time, our surveillance systems at the border and inland will better target low risk and other goods for new and emerging risks. This will be done by:

• Monitoring via horizon scanning surveys while gathering information to detect emerging issues; and
• Targeted surveillance using intelligence/information to follow up leads in relation to specific threats.

Figure 3 sets out the controls which will be required, accorded to each risk categorisation.

The controls reflect the nature of the risk posed. Routine import controls for low risk goods are removed, apart from pre-notification for traceability reasons and other assurances. In the medium risk category there is a tiered approach to the level of checks based on the country/commodity risk assessment. Although this classification remains dynamic and the level of checks may vary, some products are expected to require only 1% identity and physical checks with the higher risk products subject to higher check levels. While low risk animal products will not require routine Border Control Post inspection, they must still arrive through a point of entry with a Border Control Post, as this links to a port health authority or local authority to administer the pre-notification, and if intelligence does suggest that a physical inspection of a low risk consignment is necessary, the port health authority or local authority will be able to conduct this at the Border Control Post.

Our approach ensures we are striking the appropriate balance between protecting the UK from biosecurity risks and facilitating trade:

• A risk-based approach where routine check rates are retained for the highest risk commodities, reduced for most medium risk commodities and removed altogether for low risk commodities;.
• Not all checks will need to take place at a Border Control Post, documentary checks can happen remotely in advance of the goods’ arrival, and few consignments will be selected for identity and physical checks at a Border Control Post;
• Simplified health certificates will be available to our trading partners;
• Consignment check rates can be adjusted to reflect risk. This allows us to keep routine checks at a level necessary to protect biosecurity, animal and public health and respond to changing risk.

Figure 3: Percentage of checks per risk category

Consignment Risk (Country risk x commodity risk)		Example Animal Products	Health Certificates	Pre-notification requirements	(GB) Indicative Checks %			(EU) Checks % (Under the current EU regime)
					Doc	ID	Physical	Check rates (across 5 risk categories)***
High Risk		Live animals and commodities covered under safeguard measures	Export Health Certificate required	Full Pre-notification requirements	100%	100%*	100%*	100% Identify 100% Physical
Medium Risk		Raw, chilled, frozen meat/meat products/ABP for use in animal feed; medium risk fishery products imported as products of animal origin	Export Health Certificate required	Full Pre-notification requirements	100%	1% – 30%**	1% – 30%**	100% Identity 15-30% Physical
Low Risk		Processed, shelf-stable products such as certain composites and canned meat products, certain animal by products for technical use and certain fish products	No Export Health Certificate required	Pre notification data to allow traceability	0%	0%	0%	100% Identity 1-5% Physical

*Certain live animals (e.g. high health equines) may be subject to a reduced level of ID and physical checks dependent upon species but would still be classed as high risk

**Typically 1-30% with many products only requiring 1% identity and or physical checks. However, in some circumstances some products with specific requirements may require up to 100% on ID checks.

***Risk categories won’t be directly comparable, but gives indication of the different approaches taken

Border Checks for Live Animals

Live animals are considered to be high risk consignments and the majority will receive physical and ID checks at the point of entry at designated live animal Border Control Posts at the rate of 100%. However, for certain types of live animals, some facilitations are possible as the risks are lower or other mitigations exist.

Under certain conditions and requirements, some live animals could receive identity and physical checks at their destination instead. It is foreseen that this will apply to ‘zoo animals’ (those covered by the Balai rules) which are headed to an approved listed site and consignments of day-old chicks and hatching eggs where these are headed to an approved site under an expanded Poultry Health Scheme model. Details of the specific criteria, that may include requirements around site conditions and access to data, will be published in due course.

A reduced checks regime is also proposed for certain high health equines and certain aquatic animals. For aquatic animals this will provide for a reduced check frequency of only 10% subject to meeting specific criteria. For equines, we are exploring allowing verified racing equines to receive no routine checks at the border, in recognition of their especially high health status and level of veterinary supervision. This is subject to agreeing a stakeholder data sharing model, which provides the necessary assurance and could ultimately be integrated into the Single Trade Window. For other categories of high health equines, we are also looking to provide reduced checks frequency of 10% for those meeting specific criteria. Further details of this will be published separately following ongoing stakeholder engagement.

Border Control Post checks for live animals from the EU will commence in late 2024 and we will ensure that businesses have enough notice to prepare for the requirement for physical checks at Border Control Posts. Designated live animal Border Control Posts will continue to be published on GOV.UK, and the designation process will remain with the Animal and Plant Health Agency and with the Welsh and Scottish Governments for their respective Border Control Posts.

Border Checks for Animal Products

As the detailed operations of the Border Target Operating Model are developed, requirements and further information about Border Control Posts will be published. Designated Border Control Posts will continue to be published on GOV.UK, and the designation process for England will remain with the Animal and Plant Health Agency for products of animal origin and animal by-products and with the Welsh and Scottish Governments for their respective Border Control Posts.

Details of the operation of inland border infrastructure and the charging for checks conducted at them is set out in Section 3 of this document.

Governance

Technical oversight of the new risk-based approach will be provided via a UK wide panel of risk management experts, chaired by Defra and made up of risk analysts risk managers and policy representatives from the Animal and Plant Health Agency, the Food Standards Agency (which advises the UK and Welsh Governments), and Food Standards Scotland, alongside public health and disease control policy experts from the UK Health Security Agency and from the various governments.

Recommendations on checks rates will be coordinated by the relevant food safety, public health and animal health policy teams and be subject to agreement of the UK-wide Animal Disease Policy Group, the UK-wide Public Health Agencies and UK National Plant Protection Organisation, the Food Standards Agency, DAERA, Food Standards Scotland, and the Department for Health and Social Care and UK Health Security Agency as appropriate.

They monitor new and emerging disease outbreaks and food safety issues worldwide and assess the risk that diseases might come into the UK through trade in live animals, germinal or animal products (legal or illegal), through movement of wildlife, or through movement of things such as insects which may carry a disease. These outbreak assessments help to inform decisions around how to manage or reduce the risks. Emerging trends of food borne illness caused by contamination with bacteria, viruses, chemicals etc are also monitored to manage risks posed by food sources from exporting countries.

If risks increase or decrease and commodities need to move between risk categories, traders will be given 3 months notice so they can adapt their processes as needed, unless urgent protective action is required. The ability to apply emergency control measures on any commodities which pose an imminent risk to human or animal health will be retained.

There are already established mechanisms in place to stop a product from being imported to Great Britain from areas with a known pest or disease outbreak, and this will continue.

Import of samples

Product samples are imported for a range of different purposes across a range of different product types. In some areas, specific derogations from official controls for these movements already apply. These derogations will, where appropriate, be reflected in the implementation of the Border Target Operating Model, whereas in other areas the import processes for product samples will change. The general Border Target Operating Model framework on commodity risk and associated import health requirements will apply to samples for plants/plant products as for other consignments.

For commercial movements of samples of products of animal origin for human consumption (e.g. food samples sent to Great Britain for taste testing), the process for import will align with the standard process for the commercial import of goods outlined elsewhere within this document.

Animal by-product regulations specifically define ‘trade samples’ as those goods which are moved, with government authorisation, intended for study or analysis for the purposes of a commercial process (e.g. the testing of machinery to be used in production or testing for the development of a new pet food). A single risk category applies to these goods regardless of their nature. As animal by-product trade samples do not need to come from an approved establishment or meet the testing or processing requirements relevant to equivalent Animal by-product consignments EU origin trade samples have been placed in the ‘medium’ risk category.

Animal by-product ‘research samples’ can refer to a range of goods used in the research and scientific fields. Where these animal by-products meet the definition of a ‘research and diagnostic sample’ as outlined in regulation (e.g. they are for diagnostics for the promotion of science in an educational context) and they will not be re-sold for commercial purposes, goods can already be exempted from Border Control Post checks. This currently applies to both EU and Rest of World products and will continue to be the case under the Border Target Operating Model, assuming the same import conditions continue to be met.

Animal by-product research samples that may be re-sold do not benefit from this derogation and follow the process for commercial imports. The relevant process will be determined by the risk category that applies to the goods in question – high, medium, or low (e.g. medium risk goods will require a health certificate, if one is available).

Defra has already published guidance confirming that, where certain animal-by-product samples currently require a facilitation letter for import from the EU this requirement will fall away from 31 January 2024 if the goods are in the ‘low’ Border Target Operating Model risk category. Further, industry specific guidance will be provided.

Personal imports, including luggage, post and parcels

The Border Target Operating Model sets out the default requirement for commercial imports of animal products into Great Britain. We recognise that these requirements may be inappropriate for small quantities intended for personal use. That is why we will announce in October 2023 our future policy setting out any exemptions from commercial controls for small quantities of animal products intended for personal use, imported into Great Britain either in passengers’ luggage or in post and parcels. Post and parcels for personal use may include personal gifts (consumer-to-consumer) or goods which individuals purchase (business-to-consumer) for their own use. Business-to-business post and parcels are subject to commercial import requirements.

Trusted Trader approach for animal products

Data, technology and trusted relationships will be used to deliver robust upstream compliance that allows processes to be moved away from the border and improve flow of goods. Defra, the Scottish Government, the Welsh Government, the Food Standards Agency and Food Standards Scotland have explored how Trusted Trader schemes can play a role in protecting public health and food safety while reducing burdens on industry.

Trusted Trader schemes are a well-established concept outside the field of Sanitary and Phytosanitary controls, for example Authorised Economic Operator (AEO) status for customs which allows simplification of customs procedures and reduced checks. Alongside the core internationally recognised components of the biosecurity scheme, an innovative role for trader assurance will be added.

For animal products we are proposing to pilot a scheme to develop trader assurances, on biosecurity and food safety risks, that are equivalent to official controls. The aim is to build on existing systems and data that traders have in place to allow us to hold them to the UK’s high biosecurity and food safety standards while offering certain facilitations from official controls. Overall, we will need to have the same, or higher, assurance compared to that provided by the standard official controls.

The proposed Accredited Trusted Trader Scheme (ATTS) is a single modular framework which will provide businesses with flexibility and choice in how they engage with the Trusted Trader approach. Businesses will be able to build a package of facilitations that aligns with their specific operational needs rather than needing to engage with a one-size-fits-all solution.

Membership of Accredited Trusted Trader Scheme will provide additional assurance to government and enable traders to demonstrate they have systems in place to manage biosecurity and food safety risks with government oversight. Businesses will continue to be held to the UK’s high biosecurity and food safety standards but will have different options for providing such assurance, with a range of benefits to traders in return.

So long as a business meets the minimum entry requirements to become a member of the Accredited Trusted Trader Scheme, it will have the option of applying for different facilitations on a modular basis; these include conducting checks away from the border, simplifying the certification process for goods moving to Great Britain from a consolidation hub, and sharing supply chain data with the authorities in return for facilitations proportionate to the level of assurance provided by the data. Each individual module will have specific membership criteria, depending on the benefit being granted and the controls the trusted trader is taking responsibility for.

The pilots will be co-designed with industry participants in the run up to any launch date. We will conduct an Expression of Interest process to provide an opportunity for a representative range of businesses to participate in the pilots delivered from January 2024. More detail on the pilots is below.

As it develops, the Border Target Operating Model Trusted Trader approach will be assessed against five high-level principles:

• Protect or enhance domestic biosecurity animal and public health.
• Maintain export markets.
• Minimise burdens and costs to industry.
• Provide benefits to businesses, consumers and government and reduce costs (including running costs).
• Accessible to as many sizes and types of businesses as possible, including small and medium enterprises.

6.8 High Risk Food and Feed of Non-Animal Origin (HRFNAO)

The controls for high risk food and feed of non-animal origin will align closely with those applied to animal products in the medium risk category. Designated Border Control Posts will continue to be published on GOV.UK, and the designation process will remain with the Food Standards Agency and Food Standards Scotland.

Governance of high risk food and feed of non-animal origin will broadly continue to be under the provisions set out in relevant regulations. Retained Regulation 2019/1793 (as amended) sets the temporary increase of official controls and emergency measures governing the entry into Great Britain of certain high risk food and feed of non-animal origin from certain countries. We will carry out a wider review to consider measures that will increase efficiencies in the listing of commodities under the Regulation, so that we can respond quickly to dynamic threats to the border. There will continue to be a legal requirement for the enhanced control measures to be regularly reviewed. The reviews will continue to be delivered through an enhanced risk analysis process by the Food Standards Agency and Food Standards Scotland and provide recommendations to Ministers to establish proportionate measures governing the entry into Great Britain of high risk food and feed of non-animal origin on a commodity and country of origin basis.

6.9 Importing Plants and Plant Products under the Border Target Operating Model

Risk categorisation

Under the new regime controls will be applied to goods proportionately based upon their risk categorisation. Regulated plants and plant products will be categorised into three main risk categories, low, medium and high. The higher the risk category the greater the assurance requirements imposed. There are goods which are not regulated at all, and some which pose such a threat that they are banned by default and may only be imported under a derogation or following specific risk assessment.

The new model moves away from the default EU level of 100% checks for plants for planting and produce with an identified pest or disease risk. This will reduce to 3-5% (for most produce with exceptions where specific risk factors apply) and 5-100% (for plants for planting in Great Britain) depending on risk. This approach, developed following a public consultation at the end of 2021, recognises that plants are inherently higher risk compared to fresh produce, but recognises the intended use of plants (e.g. end use or commercial propagation/production).

This new Great Britain-focused risk-based import inspection regime aims to ensure that impacts from plant health checks are at the appropriate level to the degree of risk posed by different categories of commodities and that the phytosanitary regime remains appropriate to address the biosecurity risk which Great Britain faces.

Controls that will be applied to Plants and Plant Products

The default for plants, plant products and other regulated products listed in Annex XI, Part A of the retained EU Regulation 2019/2072 (“the Phytosanitary Conditions Regulation”) will not be 100% checks but rather between 3-5% for most medium risk products and 5-100% on the highest risk products. Where specific risk factors apply, in relation to specific products from specific origins, the frequencies will be adjusted as appropriate. Items listed in Part C of Annex XI do not require phytosanitary certificates to enter Great Britain and do not require phytosanitary inspection. They are excluded from being part of a risk targeted inspection regime.

The precise rate of checking within a specific risk category will be based on an assessment of the specific risk factors linked to the pathway concerned.

To ensure that the risk categorisation remains appropriate over time, low risk goods will be subject to robust surveillance for pests that are currently controlled and for new and emerging pests. This will be done through:

Monitoring to detect new and emerging issues; and

Targeted action in response to intelligence/information to follow up leads in relation to specific threats identified.

Monitoring via surveys will detect new and emerging issues. In addition, targeted surveys in response to intelligence or in relation to specific threats will continue in line with current plant health regulations. Any surveillance of low risk goods will be carried out at the most appropriate locations and times, and may include incidental checks alongside inspections of high and medium risk goods and checks downstream of the border at premises being visited for other plant health purposes.

Further information relating to the risk category of plants and plant products that enter free circulation in the EU and are exported from there can be found on the Plant Health Portal.

The risk categories for goods from non-EU countries will be published in August 2023 on the Plant Health Portal.

The new Border Target Operating Model will significantly reduce the number of identity and physical checks while ensuring resources are focused on consignments presenting the greatest biosecurity and public health risks. It will allow us to focus resources on consignments presenting the greatest risk to the UK, and will also enable us to expand the scope of our control regime to include the large volume of plant and plant products imported from the EU. Figure 4 shows how the new regime will compare to the regime intended for implementation in July 2022 (which would have mirrored the EU approach).

Figure 4: Rate of checks under the Border Target Operating Model compared to the current EU regime Checks for Plants and Plant Products

Risk Category	Plant / product	(GB) Checks %			Indicative Checks % Under the current EU regime
		Doc	ID	Physical	Check rates (across 5 risk categories)**
High Risk	Plants for planting – woody and/or for commercial production	100%	100%	100%	100%
	Plants for planting – non-woody and for retail sale as outdoor plants	100%	30%	30%	100%
	Plants for planting – non woody and for retail sale as indoor plants	100%	5%	5%	100%
Medium Risk	Plant products – identified risk linked to a trade	Generally: 5 (RoW*) and 3 (EU)	Generally: 5 (RoW*) and 3 (EU)	Generally: 5 (RoW*) and 3 (EU)	100 (reduced frequency for around 60 trades)
Low Risk	All other regulated plant products	0	0	0	1

*In some circumstances some products with specific requirements will be subject to a higher rate of checks and specific set of processes

**A more detailed breakdown of the frequencies of plant health import inspections under the current regime is set iut in Annex E for reference

Whilst Border Control Posts will be the location of checks for some plants and plant products, others will be checked at Control Points. Control Points are inland inspection facilities where checks of plants and plant products can take place under customs supervision. Goods moved to a Control Point are under customs control and cannot be opened until the inspector (or authorised operator) is present.

Border Control Posts and Control Points must meet specific minimum standards, including inspection areas, storage/detention areas and unloading areas with appropriate cover. These are designed to provide a bio-secure environment until goods have passed plant health checks. Border Control Post and Control Point premises must be customs authorised as a temporary storage facility. This latter approval is managed by the Border Force National Frontier Approvals Unit (NFAU) or through HMRC.

Governance

Inspection frequencies and the risk categories will remain responsive to risk and assessed threats. The cross-government Imports Threat and Horizon Scanning sub-group (which reports to the UK Plant Health Risk Group) will monitor import and interception data, and the UK Plant Health Risk Group will have authority to change inspection rates, for example in response to interceptions of pests or new threats emerging. These groups represent all governments in the UK through the Plant Health Provisional Common Framework. This may result from time-to-time goods moving between the different risk categories based on the risk they pose. In the event a good is re-categorised, traders will usually be given a minimum of three months notice, but in most cases more, before those changes are applied.

Interception data will be available on the UK Plant Health Interception Notification System. The Plant Health Advisory Forum will be informed of proposed changes to inspection frequencies before their introduction.

Whether further safeguards are needed is continually monitored and scientific processes assess the changing threats to plant biosecurity. Regulations associated with tree and plant imports are frequently reviewed and updated as part of this process.

If a significant plant health threat is identified, the inspection rate will be adjusted immediately. Adjustments will ensure a close link between the assessed risk and the inspection rate, and criteria would be based on, for example:

• Incidences of non-compliance with phytosanitary requirements in comparison with the number of consignments;
• The nature of any non-compliance, for example if pests that pose a significant concern are detected, this will lead to a higher level of checks than if pests of low risk are reported.

Inspection rates will also be reviewed annually by the cross-government Imports Threats Group (made up of technical plant health experts from across the UK). Given inspection frequencies are linked to fees, more frequent changes would add uncertainty for businesses. A horizon scanning regime will be maintained to provide an early warning system for new and emerging plant pests and diseases.

• Details of the operation of inland border infrastructure and the charging for checks conducted at them is set out in Section 3 of this document.

Personal imports, including luggage, post and parcels

The Border Target Operating Model sets out the requirement for commercial imports of plants and plant products into Great Britain. We are considering whether any of these controls can be disapplied to small quantities intended for personal use and will announce the outcome shortly.

Delegated Authority Approach for Plants – Authorised Operator Status

Under the Authorised Operator Status (AOS), it is proposed that a trader, with appropriately trained personnel and internal control systems, can achieve authorisation, meaning their level of expertise is sufficient to perform physical and identity import checks. However, authorisation needs to be piloted to evaluate feasibility, both for the trader’s operational competency and biosecurity risks. The aim is for this to be a Great Britain-wide scheme. Conversely, the pilot may demonstrate non-feasibility and consequently a decision made for AOS not to proceed.

Responsibility for performing physical import checks will be delegated to private operators who meet the eligibility criteria. The criteria will include having their premises designated as a Control Point, for which there are a set of infrastructure requirements, and require in-depth systems audits of processes.

The Animal and Plant Health Agency and SASA will be responsible for auditing Authorised Operators. The training will be tailored to the goods the Authorised Operator imports. Competence will be determined through formal sign off by the Animal and Plant Health Agency/SASA and there will be regular refresher training for Authorised Operators.

Although there will be a cost for training and audit aspects of the scheme, Authorised Operator Status brings the potential for a number of benefits to be realised, subject to a successful pilot;

• Authorised Operators (AO) will have flexibility to conduct inspections at their business premises (designated Control Point) at a time that suits them, not having to await Plant Health Service’s attendance.
• This will result in produce being entered into free circulation as soon as customs and plant health checks are completed, thus reducing the AO’s “time to market” window.

6.11 Simplification and Digitisation of Health Certificates

For the import of animal products to Great Britain we have simplified export health certificates, removing unnecessary detail. The new simplified export health certificates for products of animal origin and animal by-products have now been published. This simplification maintains the control needed and reduces opportunities for administrative error by reformatting the certificates. Guidance about attestations have been removed from the certificate itself into an annex. Rest of World trading partners will be able to use the simplified export health certificates once the rollout to EU countries is completed.

Simplified health certificates are available for EU and Rest of World traders. These can be found here.

From January 2024 we will extend the current use of PDF Export Health Certificates for live animals to imports of animal products from the EU and EEA/EFTA countries. We will accept PDF versions of digitally signed Export Health Certificates to be attached to IPAFFS pre-notifications for POAO imports without the need to send the original paper certificate with the consignment. These certificates will need to be created directly in either TRACES or within an EU / EFTA / EEA Member State’s National SPS Export System, where they can be electronically verified against the original certificate, for example through the use of embedded QR codes. We will publish in the summer a list of non-TRACES Member States that can use PDF versions of Export Health Certificates. We are also developing a digital solution to allow the direct cloning of Digital Export Health Certificates from exporting countries where the capability is available, starting with Live Animal Export Health Certificates from November 2023 from countries using TRACES in the EU. This will reduce the time taken for traders in Great Britain to complete import notifications in IPAFFS. It will improve the checking of notifications as a higher level of assurance will be provided by being able to verify a notification through an assured and trusted source. Certificates will be made available automatically in Great Britain systems when uploaded by the Official Veterinarian or official in the exporting country. Third party software will not be required for importers to access these certificates.

The rollout of this fully digitised certification relies on take up and agreements with our trading partners. We expect to be able to deliver digitised certification for imports of plant and plant products from Summer 2023 for the Netherlands and EU Member States that use TRACES as an export platform, and animal products from EU Member States that use the Trade Control and Expert System (TRACES) from early 2024. A timeline for the rollout of digital certification is below. Digitised health certification will be extended to non-EU trade partners over time subject to negotiation and as trade partner readiness allows; further details will be provided as developments are confirmed.

Timeline for Implementing the new Sanitary and Phytosanitary model

• Controls for the highest risk goods are already in place and the new Sanitary and Phytosanitary model will be phased in over time, starting first with critical controls to protect the UKs biosecurity, animal and public health. For goods moving from the island of Ireland, refer instead to Section 2 of this document.

From 31 October 2023 we will:

• Accept submission of simplified export health certificates for Rest of World trade. The new simplified export health certificates for products of animal origin have been published and certificates for animal by-products will be available shortly. This simplification will maintain the control needed and reduce opportunities for administrative error by reformatting the certificates. It will also move guidance about attestations from the certificate itself into an annex.

From 31 January 2024:

• Introduce simplified export health certificates and phytosanitary certificates for medium risk animal products and phytosanitary goods imported from the EU.
• Begin sample documentary checks on medium risk goods from the EU, but there will be no new routine controls undertaken on these goods at the border, so initially there will be no charges for documentary checks or holds for inspection.
• The removal of pre notification requirements for low risk plant and plant products from the EU.
• Introduce pre-notification requirements for EU Sanitary and Phytosanitary goods that enter Great Britain via West Coast ports.
• We will begin Certification Logistics Pilots and Accredited Trusted Trader Pilots Schemes as outlined above.

From 30 April 2024, a new global risk-based import regime for both EU and non-EU goods will be implemented. Specifically:

• The new checks at the border on medium risk EU origin goods will be introduced (except at West Coast GB ports).
• All goods to which import health controls apply will be required to enter via a point of entry that has the relevant Border Control Post or in the case of plants or plant products a Control Point designation for those goods.
• Health certificates and routine checks at the border will no longer be required for low risk animal products for import from non-EU countries with the exception of intelligence-led interventions on low risk animal products.
• The requirements for import controls on certain low risk plants and plant products from non-EU countries will start to be removed, where supported by risk assessments. Health certificates and routine checks at the border will not be required for such products.
• Medium risk animal products will be subject to reduced levels of intervention at the border with identity and physical check levels being lower than now for imports from non-EU countries.
• The introduction of Common Health Entry Documents (CHEDs) for all live animal, HRFNAO and animal product imports from the EU is required to support the introduction of identity and physical checks from the end of April 2024. CHEDs will replace the Import Notifications (IMPs) currently required for live animal, HRFNAO and animal product imports from the EU. There is currently no HRFNAO of EU origin listed so this requirement refers to where HRFNAO from outside the EU has been placed on the EU market and not been subject to any further processing. CHEDs for live animal and HRFNAO imports from the EU will be implemented by the end of November 2023, with CHEDs for animal product imports from the EU implemented by the end of January 2024.

From 31 October 2024 we will introduce check requirements for EU SPS goods that enter Great Britain via West Coast ports^{[footnote 3]}. We will also further simplify traders’ management of Sanitary and Phytosanitary requirements, with the introduction of the UK Single Trade Window that will remove duplication across pre-arrival datasets where possible.

6.12 Supporting different business models for importing groupage loads of Sanitary and Phytosanitary goods

Groupage involves transporting multiple consignments, each with its own health certificates, on a single lorry or container. This can include consolidating consignments at a hub or gathering them from various pick-up points before exporting. It can also refer to different goods that meet the same core requirements being combined into a single consignment with a single health certificate. Businesses importing Sanitary and Phytosanitary goods into Great Britain through groupage will need to plan ahead, taking into account that different goods may have distinct requirements.

Groupage of animal products

In the first instance, the Border Target Operating Model will facilitate continued groupage movements by delivering a risk-calibrated regime:

a. Low risk animal products will not require an export health certificate to enter Great Britain and will not be subject to routine border checks by default. This will simplify the treatment of groupage loads containing low risk products. 90% of all Sanitary and Phytosanitary commodities have been categorised as low risk; this supports the continuation of groupage as a viable business model.

b. Medium risk animal products will be subject to reduced levels of intervention at the border with identity and physical check levels being lower than now (for imports from Rest of World).

c. High risk animals and animal products are rarely moved using groupage but would always be subject to certification and border checks.

Where products do not require an export health certificate, the complexity of securing a certificate for groupage loads will be removed. Where products are subject to no routine, or reduced levels, of identity and/or physical checks at the border, the risk of a compliant consignment in a mixed load being detained for checks will be reduced.

To support this approach, we have classified animal products based on their risk levels, with a comprehensive summary now available here for imports from EU and EFTA countries. A similar list will be published for non-EU countries in August 2023.

When Export Health Certificates are necessary, it is recognised that obtaining multiple Export Health Certificates for different consignments within the same load can pose logistical challenges and potentially increase costs for traders handling smaller consignments. To help address these issues, we have developed several strategies to facilitate importing medium risk animal products under the Border Target Operating Model. The primary goal is to streamline the process while upholding rigorous biosecurity and public health protection standards. Guidance will be available before 31 January 2024.

Groupage of animal products: Simplified operational models

We have simplified our previous groupage guidance to focus on two primary operational models: the “Consolidation Hub” and the “Multiple Pick-up “ models. These models can be referenced by traders as part of their operational planning.

• The “Consolidation Hub” model is designed for businesses dealing in large volumes, allowing the collection of individual consignments at a single hub, thereby simplifying certification.
• The “Multiple Pick-up “ model is suitable for businesses with smaller volumes, supporting the collection of individual consignments from multiple locations, with certification at each pick-up point.

We have also revised the official seal requirements for both operational models to ensure fairness and equal treatment of groupage loads. Great Britain authorities will only require official seals for animal products where they are mandated within the Export Health Certificate. Unless otherwise specified by the Export Health Certificate or the Competent Authority, traders will be free to implement their own measures for secure transportation and to differentiate individual consignments within a groupage or mixed load.

Groupage of animal products: Streamlined certification and use of schedules to facilitate groupage

In our efforts to simplify groupage imports, we have implemented streamlined Export Health Certificates. These revised certificates, accessible here, uphold the required Sanitary and Phytosanitary biosecurity controls while being shorter in length. To further assist groupage, they include ‘inclusive ‘and/or’ statements as opposed to the exclusive ‘either/or’ statements that were included in previous Export Health Certificates. This means that products that meet different conditions can be certified together onto a single Export Health Certificate where previously this was not the case. For example, egg products that have been subject to different forms of treatment to mitigate the risk of Highly Pathogenic Avian Influenza can now be certified together on a single Export Health Certificate as long as they meet all other requirements of the certificate (e.g., dispatched from the same EU approved premises).

Groupage of animal products: Enhancing Flexibility for Notifiers

We are exploring increased flexibility for notifiers to submit dynamic data beyond specified pre-notification periods, to help reduce logistical pressure. The first facilitation will be the allowance of “Groupage” to replace vehicle registration details on Export Health Certificates for individual consignments. This eliminates the need for businesses to provide vehicle registration details for each consignment within a groupage or mixed load at the point of certification.

There are limited exceptions to this allowance – when the Export Health Certificate or associated guidance mandates means of transport inspection, it is imperative to have the transport/vehicle details certified in the Export Health Certificate by the relevant Certifying Officer (CO). Furthermore, during the pre-notification process in the IPAFFS system, actual transport/vehicle details must be accurately provided. Failure to adhere to this requirement may lead to failure in documentary checks.

Groupage of animal products: specific Trusted Trader pilots

We will launch the Certification Logistics Pilot in January 2024. This pilot aims to remove the cost burden associated with re-certification of groupage loads prior to dispatch from an EU consolidation hub. If the first stage of the pilot is a success we may look to expand it more broadly.

We understand that groupage movements continue to be a concern for stakeholders involved in the movement of medium risk animal products and we intend to continue to work closely with them in the run up to 31 January 2024 to test further facilitations – including concepts that will benefit traders undertaking multiple-pick up and multiple-drop off models.

Groupage of plants and plant products

For plants, a single phytosanitary certificate can already cover a range of different plants and plant products, they are not commodity specific. This means that a single certificate can cover an entire consignment, irrespective of how many different plants and plant products it contains. The composition of a groupage load of plants and plant products can change during the transport vehicle’s journey without impacting on the phytosanitary certificates issued to other consignments within the load. The composition of the individual consignments must not change after the phytosanitary certificate has been issued. This model is commonly used for non-EU imports, including those moved by Roll on Roll off (RoRo) ferries transiting the EU.

When one product within a consignment requires a physical check and the others do not this may mean that the entire consignment must be diverted for a check. We will work with importers and logistics firms who move mixed consignments to ensure complexity and cost is minimised under the new model.

6.13 Re-exports of Sanitary and Phytosanitary goods

Stakeholders’ views were sought on the impact of the new import controls on exports and on re-exports. Under the new model, certain low risk Sanitary and Phytosanitary goods that are imported to Great Britain will not need a health certificate. However, for goods that originate from outside the EU, an official veterinarian may currently be placing reliance on the information within a health certificate that accompanied the goods into Great Britain when certifying goods for re-export.

Therefore where EU and ROW origin Sanitary and Phytosanitary goods are being re-exported, and no health certification is required for import into Great Britain, certifiers will need to obtain the relevant supporting information. This can either come from a veterinarian in the original country of export or, where permitted, be based on commercial documentation. Discussion with stakeholders to date has not indicated significant concerns about obtaining certification for the re-export of low risk goods (noting that this is already occurring for the re-export of EU origin goods).

Recognising that this nonetheless represents additional complexity, guidance to assist certifiers is being developed and will be released according to the schedule outlined in Annex H.

6.14 Other Import requirements for Sanitary and Phytosanitary goods

There are specific import controls on some products that stem from specific aspects of UK legislation or our membership of international conventions covering the movement of these goods. The Border Target Operating Model does not propose changing these controls.

Convention for the International Trade in Endangered Species of Wild Fauna and Flora (CITES)

Species covered by the Convention for the International Trade in Endangered Species of Wild Fauna and Flora (CITES) will need to continue to meet existing import requirements.

Labelling

Pre-packaged food or caseins sold in Northern Ireland must include a Northern Ireland or EU Food Business Operator (FBO) address. If the FBO is not in Northern Ireland or the EU, include the address of your importer, based in Northern Ireland or the EU.

From 1 October 2023, pre-packaged food or caseins sold in Northern Ireland that have been moved to Northern Ireland from Great Britain through the Northern Ireland Retail Movement Scheme may instead have a Great Britain, Channel Islands or Isle of Man address. Further information is available on GOV.UK.

You can continue to use an EU, Great Britain or Northern Ireland address for the FBO on pre-packaged food or caseins sold in Great Britain until 31 December 2023.

From 1 January 2024, pre-packaged food or caseins sold in Great Britain must include a UK, Channel Islands or Isle of Mann (‘British Islands’) address for the FBO. If the FBO is not in the British Islands, include the address of your importer, based in the UK.

Organic goods

The grace period in legislation which has exempted organic goods from the EU, European Economic Area and Switzerland to provide a Certificate of Inspection remains in effect until 31 December 2023. COI requirements for organic goods of other origins remain as they were before the end of the transition period. We will communicate shortly the arrangements which will apply in the future.

Timber

Imports of timber and timber products from the EU will remain subject to due diligence checks to ensure the goods have not been illegally harvested as set out in the UK Timber Regulation.

The UK Timber Regulations (UKTR) apply to imports into Great Britain and to timber placed on the market within Great Britain. The primary objective of the UK Timber Regulations is to tackle illegal logging and to create a demand for legally harvested timber. The UK Timber Regulations prohibits the placing of illegally harvested timber and timber products on the Great Britain market and requires operators, those first placing such products on the Great Britain market, to exercise due diligence. Those who trade in timber and timber products after they have been placed on the market are required to keep records of who they buy timber products from and any traders they sell them to. This enables timber and timber products to be traced.

Fishing documentation – Illegal, unreported and unregulated fishing (IUU)

Illegal, unreported and unregulated fishing documentation (catch certificates, processing statements and evidence of storage) must be sent in advance to the relevant port health authority, or local authority in Scotland, for imports of fish and fishery products. Certain exemptions apply as outlined in Annex I of the UK’s IUU regulation. These requirements are wholly separate, and in addition to, Sanitary and Phytosanitary requirements.

These documents are required now (including for imports from the EU) and must be sent by email (or provided physically if the port health authority/local authority requests) to the relevant authority in advance of the consignment’s arrival. In the future these documents will need to be uploaded to our system, the Import of Products, Animal, Food and Feed System (IPAFFS), but we will provide notice in advance of this becoming a requirement.

Port health authorities and local authorities charge a fee to recover costs for checking these documents (or, if deemed necessary, performing a physical inspection), and these fees are set by individual authority.

Importers will need to check the timescale requirements for submission of documentation with the relevant authority. The minimum timings outlined in the legislation are 72 hours in advance for imports by sea, 4 hours for rail or air, and 2 hours by road.