2. Guide to this Document
This document is designed to help UK importers and exporters and their supply chains, the border and logistics industry, ports, and other interested stakeholders including the UK’s trading partners understand the new Border Target Operating Model and related improvements to the UK border occurring ahead of 2025.
This section sets out the principles of the new model for imports before covering the changes to the Safety and Security and Sanitary and Phytosanitary controls regimes in detail. Importers, overseas exporters, and the logistics industry should read this section to understand what actions they will need to take to import their goods, and how those goods will be treated.
This new section sets out the interactions between the Windsor Framework and the Border Target Operating Model. Specifically it sets out further details on the movement of Irish goods directly from Ireland into Great Britain ports. It also sets out further details on the processes at ports when Northern Irish goods move through Irish ports to Great Britain ports.
This section sets out what the border industry and ports will need to do in order to operationalise the model. Ports and the border industry should consult this section to understand what role we anticipate they will play in the model and how we want to work with them to design the detailed delivery plans that will underpin the Border Target Operating Model.
This section sets out the revised timeline for phasing in the model and the milestones stakeholders will need to prepare for. Importers, overseas exporters, the logistics industry and ports should read this section to know when new requirements will be in place. This section also sets out how the revised timeline for implementation of the Border Target Operating Model sits within the larger portfolio of border transformations we will deliver over the coming years.
This section sets out the UK Government’s ambitions to support exporters and outlines specific improvements we have or will implement in the coming years alongside implementation of the Border Target Operating Model.
This section sets out the transformations that the Home Office and Border Force are implementing to modernise and automate the movement of passengers through UK ports. Ports and the border industry should read this section to understand how changes in passenger movements will happen in parallel to changes in how goods move across the border.
3. Section 1: Border Target Operating Model for Imports
4. 1.1. Overview of the new model
4.1 Summary of the new model for imports
In April 2022, the UK Government decided not to introduce further Safety and Security requirements or Sanitary and Phytosanitary controls which apply to animal products, plants, plant products and high risk food and feed of non-animal origin on imports into Great Britain from the EU that had been planned for July 2022 onwards.
Following that decision, the UK and Devolved Governments, in collaboration with traders and the border industry, have developed a new Border Target Operating Model.
The new Border Target Operating Model is significantly different to the model we were going to introduce in July 2022. It brings together policy and process improvement, as well as technology and better use of data to implement a new model for importing goods into Great Britain. This will introduce the best possible arrangements for those importing from the EU, and improve the experience of those importing from non-EU countries. It will do this by reducing the complexity of the UK’s security, biosecurity and public health border controls; reducing the paperwork and certification required, and; aligning the requirements and frequency of physical checks to the risk presented. Where action is required from importers the digitisation of data submission processes will minimise the need to resubmit data.
The collection of Safety and Security data from EU imports presents one of the best post-EU Exit border security improvement opportunities to protect the country. The additional pre-arrival data for EU imports will mean more intelligent risking of cargo, allowing us to have the right people in the right place at the right time to stop illegal goods hitting the UK streets.
In development of the new model we have reviewed the Safety and Security requirements, reducing the data set to its security-critical elements whilst retaining flexibility for those already making declarations.
Border controls are one important part of a robust import system to ensure our food is safe and that we are protected from animal and plant diseases. The new model for Sanitary and Phytosanitary controls will deliver benefits to businesses, while providing robust controls needed to protect the UK’s biosecurity and ensure that consumers have access to high quality and safe food products.
The UK’s Biological Security Strategy, published in 2018 and recently updated, sets out the challenges faced in maintaining our biological security and how those threats are managed. It recognised that one of the most serious risks societies face today comes from outbreaks of disease. Such outbreaks threaten lives and livelihoods and generate significant social, economic and environmental impacts. Large scale disease outbreaks in animals or plants do not respect international boundaries and the threat they pose has grown as the world becomes increasingly interconnected. As a global trading nation, the UK is exposed to these risks, and border controls are a key tool to manage them.
Sanitary and Phytosanitary border controls are based on the provision of data about regulated goods. They provide assurance through certification and enable the risk-based targeting of more intensive checks. The three components of import health controls systems are:
- Pre-notification, which supports action at points of entry, allowing officials to target their activities at shipments posing the biggest risk. The detail allows traceability, enabling animal, plant and public health authorities to identify and respond to an outbreak or emerging threat.
- Health certification provides assurance as it requires authorised officials in exporting countries to certify that the goods have been produced to the safe standards required by the importing country. These are monitored through documentary checks.
- Physical inspection, usually at a border control post, allows health officials to check that goods match the health certification, to identify any trends of concern in non-compliance and to sample the goods for any pests and diseases.
We only import from countries that we already know are managing their biosecurity appropriately. The exporting countries are audited and their production establishments are inspected by their competent authorities and need to meet specific requirements to export to the UK. At present, goods from the EU enter the UK without certification and checks, apart from those required for the highest risk items, such as live animals, germinal products and plants. The Border Target Operating Model introduces proportionate controls that will protect the agri-food sector and public health. These are vital to avoid diseases that could devastate UK industries and our ability to export.
Case Study: African Swine Fever and Border Controls
An outbreak of African Swine Fever would be a fundamental threat to the viability of our pig industry.
While Britain is free of African Swine Fever, it is widespread in some other parts of the world, including both EU and non–EU countries on the European Continent. Recent routine inspection of retail shops by local authorities in the UK detected frozen, raw and uncooked meat products marked clearly as suitable only for sale in the originating country. Further investigations found these products had been purchased by two importers, linked to over 280 retail outlets in the UK. These products were exported commercially, and properly pre-notified on the UK imports system. Although the products didn’t test positive for African Swine Fever on this occasion the very fact that these products reached the UK presents a serious and immediate threat to the UK pig industry.
These goods would not have made it to the UK if Sanitary and Phytosanitary controls had been in place because they would not have been certified for export by a veterinarian in the originating country.
In developing the new model, our goal has been to design a modern border with a simplified but effective system of Sanitary and Phytosanitary controls. This is a border that optimises the balance between maintaining, or improving, biosecurity, public health and food safety and sets a proportionate regulatory burden. We recognise that some goods inherently carry lower risk, for example highly processed commodities from production systems that we trust, and for these we recognise that appropriate pre-notification and intelligence based checks can provide sufficient protection and balance the relative burdens. Trade partners’ confidence in our animal and plant health standards, including official controls at the border, is essential to our ability to export and to strike new trade deals.
An overview of the process a typical business importing goods into Great Britain will need to go through under the new model is set out in Figure 1. This summarises the key data they must provide, when they must provide supporting documentation and when a physical check of their goods may be required.
Figure 1: Summary of how the Border Target Operating Model will improve the import process
4.2 A cross-government approach to Trusted Trader authorisations
The 2025 UK Border Strategy set out the ambition to create a cross-government approach to authorising businesses for Trusted Trader status (where a trader goes through an upfront assurance process in order to be granted authorisation to use facilitations not available to traders by default) that sees these approaches expanded across different compliance regimes. The Border Target Operating Model seeks to deliver on this ambition, and pilot the incorporation of Sanitary and Phytosanitary controls into our approach to Trusted Trader authorisations.
Currently, the UK Government’s ‘Trusted Trader’ offer comprises over 80 schemes for customs and excise administered by HMRC, such as the Authorised Economic Operator (AEO) scheme, Authorised Consignee/Consignor (ACC) for transit users and Excise Warehousing. Benefits range from reduced checks at the border to the ability to defer customs and excise duty and import VAT payments. For excise authorisations, without the required authorisations and approvals, businesses cannot produce excise products such as beer, tobacco or road fuels.
The existing customs and excise authorisations schemes do not have systemic read across to one another and traders must re-enter information for each authorisation. Further, there is no central platform where a business can manage or apply for schemes they are eligible for. In addition, the Government’s existing Trusted Trader offering is focused on customs and excise authorisations, with few facilitations offered for other controls regimes, such as Sanitary and Phytosanitary controls.
Through the Border Target Operating Model we will create a joined up approach to our Trusted Trader offering.
- HMRC will radically simplify its existing schemes for trusted traders through the Modernising Authorisations project. This will streamline the current suite of customs authorisations and digitise the current paper based application/management process for customs and excise authorisations. Authorisations will be more visible to traders making it easier for them to identify and access those authorisations which are most suitable for their needs. The Modernising Authorisations project will move into delivery in the second half of 2023, with the aim of completing by mid-2025.
- The UK Single Trade Window will provide a gateway for application and management of Trusted Trader status. This will save traders the administrative burden of capturing data multiple times, and the applications and guidance for authorisations schemes can also be held on a single platform. Traders applying for authorisations will have a more straightforward customer journey where data is not requested on multiple occasions. When a trader’s capability and volume of trade grows such that they wish to move away from third party services and undertake customs processes directly, they will be able to access and manage their authorisations more easily. This approach will make it more straightforward to apply for Trusted Trader schemes and will help smaller firms to start importing, thus encouraging them to apply for further facilitations as they become more mature. Traders who hold existing authorisations will be onboarded to the new platform and will be able to review and amend all of their held authorisations in one place and use their data to apply for additional schemes. The UK Single Trade Window is designed so that in the future, new features can be incorporated. In the context of a Trusted Trader scheme, this means that the Trusted Trader offer can expand if further facilitations are developed for traders.
- As set out in the detail of the new approach to Sanitary and Phytosanitary controls, we will work with industry to pilot new Trusted Trader authorisations for Sanitary and Phytosanitary goods. These pilots will explore whether it is possible for businesses to demonstrate compliance and provide the necessary assurance to manage biosecurity, animal health and welfare, and food safety risks.
- In addition, we worked with industry, through our Ecosystem of Trust pilots, to test the most advanced border model we can conceive of, where tech, data and policy come together to result in near frictionless movement across the border for Trusted Traders. The pilots tested technology and data insights that can provide assurances to government about the movement of goods, allowing it to deliver more facilitated trade and benefits to industry. We will use the evaluation of these pilots to determine how these approaches can be integrated into the future Border Target Operating Model.
The user journey map in Figure 2 shows how we believe the system should ultimately function, including input and output from the user, the UK Single Trade Window service, and the underpinning departmental systems.
4.3 Benefits and costs of the Border Target Operating Model
We believe the Border Target Operating Model represents one of the most intelligent and data-driven border models in the world. During the engagement period on the draft model we engaged with importers and their supply chains about the potential costs of the model. In parallel, we have also published the full risk categorisation for EU goods which provides a more robust basis for estimating costs. This has seen many goods categorised as low risk, meaning that they do not require certification or routine checks at ports, ensuring that the cost of importing them remains low. This ensures there will not be a significant impact on inflation from the introduction of the Border Target Operating Model.
Based on engagement with stakeholders and improvements we have made to the model we have updated our analysis of the impacts on the new model to produce new estimates and costs and benefits.
Benefits of the new model
Including the further improvements to the model we have made based on stakeholder feedback, compared to the original import model that would have been introduced in 2022, we believe this new model will reduce costs to businesses by around £520m per annum by reducing the complexity and volume of paperwork associated with importing.
The Border Target Operating Model delivers significant benefits by protecting the UK’s environment, farming industry and citizens from a range of threats.
Security controls prevent the entry of a range of illegal and dangerous goods into the UK that support criminal gangs and harm citizens. This imposes costs on the UK in the form of crime and healthcare costs. We estimate that introduction of new security controls to imports from the EU could lead to significant benefits including an increase in seizures of class A drugs by up to 4000 kg each year.
Figure 2: Proposed model for delivering a cross-government approach to trusted trader authorisations through the UK Single Trade Window
The risks from inadequate biosecurity controls are significant and dynamic. There are also significant disease hazards associated with a wide range of imported commodities: a recent UK-wide Salmonella outbreak caused by chicken products originating from the EU, resulted in over 1000 confirmed cases of illness (with potentially as many as 4000 additional cases which were not confirmed/reported) and cost an estimated £7.7m. Biosecurity measures also reduce the risk of importing diseases, including zoonotic diseases, which are responsible for c.75% of new and emerging infectious diseases in humans (including those with pandemic potential). While the costs of new disease outbreaks cannot be quantified directly, previous outbreaks have had severe economic impacts. The 2001 outbreak of Foot and Mouth disease cost £13bn in 2021 prices, of which £4.5bn were costs to Government and £8.5bn were costs to the private sector. Similarly, Ash Dieback arrived in the UK in 2014 and has a predicted cost of £15bn over the next century.
Costs of the new model
As stakeholders informed us during the engagement period, introduction of robust controls on EU imports will inevitably result in new processes and so costs for importers. These costs are already experienced by UK businesses exporting to the EU, since the EU has already implemented full import controls on UK goods. Costs will depend greatly on how businesses adapt their business models and supply chains to integrate the new controls regimes. However we estimate these new costs of the model at £330m p.a. overall, across all EU imports. This represents c.0.13% of the overall value of EU goods imports to Great Britain, with an annual value of c. £259 billion.
The design of the new Border Target Operating Model has focussed on reducing burdens for businesses, and many Sanitary and Phytosanitary goods have been classified as low risk. Consequently, our modelling suggests the impact of introduction of the new model on the costs of food and drink will not be significant, representing less than a 0.2% increase in total over 3 years. The consequences of a major outbreak of a plant or animal disease on the economy could be far more severe.