The UK’s Border Target Operating Model (BTOM) is a new border model designed to preserve and protect biosecurity by enforcing security, control, and safety regulations for imported commodities. Common EU dairy commodity imports are classed under the new risk-based methodology, with many dairy products classified as medium-risk, while shelf-stable dairy and chilled pasteurized milk products are designated as low-risk.
The Institute of Export & International Trade, a trade group that represents both exporters and importers, is concerned about the potential for friction and red tape caused by the new regulations. According to Marco Forgione, director general of the Institute, many dairy products are categorized as “medium risk,” which means that in order to be exported from the EU, they must have an Export Health Certificate (EHC) and be registered in the EU’s TRACES NT system. This method requires the exporter to apply for the EHC via their local authorities, and the certificate must be endorsed by the official veterinarian.
In the UK, the importer must then arrange for a notification in the Import of Products, Animals, Food, and Feed system (IPAFFS) with a Common Health Entry Document (a document that records the results of the checks), which must be referenced in the import entry on the Customs Declaration Service. However, the importer cannot do this until they obtain the paperwork from the exporter, and the pre-notification must be completed 24 hours before the products arrive in the UK.
Due to the intricacy of these processes, some small EU firms may halt or discontinue shipments to the UK, or they may change the method they distribute their products, such as via distributors. The ultimate implementation step, set for October 31, 2024, will require Safety and Security declarations for all EU imports. The most significant risk here is whether the haulage industry will be prepared for these changes, as EU-only hauliers are not currently required to comply with this requirement, and the Entry Summary Declaration (import Safety & Security declaration) is the responsibility of the party operating the means of transport crossing the border.
UK authorities are continually modifying the guidelines, lately reclassifying fruit and vegetables as medium-risk from low-risk, however these commodities are still considered as low-risk at the border, presumably to prevent food shortages given that the UK imports around 45% of vegetables and 84% of fruits. Certain concessions are being adopted, such as decreasing 24-hour pre-notifications to 4 hours, but this is up to each individual Port Health Authority to approve, and it is unlikely to be a ‘blanket decrease’ for all arrivals at all locations.
The UK government is also conducting tests of so-called Trusted Trader programs, which are intended to allow for concessions for medium-risk commodities; however, these schemes will not be operational by April 30. The deadlines in BTOM have been established as of January 30, 2024, although there are still numerous areas that need clarification. Businesses that trade in dairy products should communicate with one another to ensure that everyone understands their duties.
