Logistics UK and the British International Freight Association have been reacting to the recent announcement of the new Border Target Operating Model which sets out new controls to protect the UK against security and biosecurity threats and create a world-class border system for trade in goods.
Nichola Mallon, Head of Trade and Devolved Policy at business group Logistics UK said: “Will three months be sufficient time for government to provide the necessary technical detail and guidance that businesses will need to change processes and adapt to the changes outlined by the new trading arrangements?
“Logistics UK is studying this final model carefully to see if it addresses the concerns expressed by our members and contains the level of operational detail and assurances they, and their EU suppliers, need to make the changes required in that time frame. With so much to adapt to, and such a short time frame available, it is imperative that logistics businesses are given all the detail they need in the initial plan.
“Government needs to provide certainty for business on all the details of the new Border Operating Model, and a workable timeline which will allow sufficient planning and implementation time for those responsible for the UK’s supply chain.
“After so much time, and so many delays, logistics businesses are losing confidence in the government’s ability to provide workable solutions to enable the new trading arrangements to be implemented. Our members need all the detail for how border arrangements are to work, and time to implement the changes – if not, the lack of certainty puts the UK’s supply chain at risk.”
Hectic New Year Start
Meanwhile, the British International Trade Association says it will mean a very hectic start to the new year for its members.
BIFA Director General, Steve Parker says: “Our members will already be in the process of moving all export declarations from CHIEF to CDS by 30 March 2024 and will now need to make sure they are ready for the delayed introduction of remaining sanitary and phytosanitary controls, as well as full customs controls for non-qualifying Northern Ireland goods, which will now be introduced from January 2024. Then from April 2024, will also have to implement checks on medium risk animal products, plants, plant products and high risk food (and feed) of non-animal origin from the EU.
“This further delay to the overall timetable is actually relatively short. Those BIFA members that are actively involved in handling the movement of the types of products imported into the UK for which Sanitary and Phytosanitary (SPS) checks; safety and security declarations; and health certifications are required will be hoping that they will see a return on the time and money that they have invested in staff and resources to meet the original and five times revised implementation timetable.
“Those members, along with the trade association, have been cautious with any government announcements setting out new dates and an implementation timetable for the BTOM, and will continue to be so, as uncertainties remain.
“Whilst we need to thoroughly review the document in order to gain a comprehensive understanding of how it will impact on the work of the freight forwarding and logistics companies that BIFA represents, a few things are clear.
“The BTOM does not address fundamental concerns raised by BIFA with DEFRA regarding the suitability of using the present Port Health Authorities to handle international trade.
“Whilst certain parts of the August 2023 version of the BTOM are an improvement over its previous incarnation, the trade association notes that that there are references to the Single Trade Window (STW) which is still very much under development. It is important to emphasise that the implementation of the BTOM is reliant on the implementation of a workable STW, as the two programmes are dependent on one another. After the STW has been developed additional time will be needed to link commercial IT systems to the STW.
“In view of the fact that large IT projects are often delayed there has to be concerns regarding the envisaged timetable.
“Some comments in the document state that certain elements of the BTOM have not been finalised and that the timetable may be changed at a later date. In Kent, for example, clarity is essential for traders of SPS goods, but the document states that: ‘The provision of Inland Border Control facilities in Kent for goods entering the UK through the Short Straits (Port of Dover and Eurotunnel) is being reviewed.’ This uncertainty is not helpful for traders involved in this particular trade and makes it difficult to finalise decisions on routing and ensuring regulatory controls are complied with on such shipments.”
