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BIFA expresses concern over several aspects of UK’s new Border Operating Model

Following the UK Government's publication of the Border Target Operating Model (BTOM) yesterday, the British International Freight Association have reacted by saying the changes will mean a very hectic start to the new year for its members.

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Explaining why this will be the case, BIFA Director General, Steve Parker, said:

“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.”

In an official BIFA press release, Parker admitted that the further delay to the overall timetable is actually relatively short. However, he added that BIFA members 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.

This very much ties in with the apparent frustration in industry circles about the UK Government’s repeated pivoting and procrastinating on its goods border plans. There have been claims these delays have resulted in exporters and logistics companies not taking the changes entirely seriously. At the same time, some of the companies who did take the matter seriously, and invested in and prepared for the implementation of certain checks, did so only to learn the checks had been delayed or scrapped.

Parker continued:

“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.”

Moreover, BIFA’s Director General stated that the UK Government’s plan does not address concerns both it and DEFRA have raised:

“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.”

Another issue flagged by Parker is the importance of the Single Trade Window, which hasn’t been developed yet, to the Border Operating Model:

“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.”

Finally, Parker’s statement concluded that the document refers to more dates possibly being pushed back, which in turns sparks more uncertainty for businesses:

“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.”


Photo by Ethan Wilkinson on Unsplash