Policy & Compliance
states the report by parliament’s (EFRA) committee. The BTOM, which showed little comprehension of how trade and data flowed, was always going to be difficult to implement in practice. A fragmented and in certain ways under-prepared government at the frontier had the unenviable task of trying to devise procedures in an effort to implement flawed policies, which doubting traders had to follow. ‘Flawed’ BTOM The committee’s report highlights the fact that the unique location of Sevington “provides opportunities for exploitation by criminals”. In addition, poor IT systems and data gaps are among the main reasons for poor enforcement. The committee regards the operating arrangements as outlined in the BTOM as “flawed”, calling on the existing arrangements to be “reviewed and bolstered”. The report highlights that the current system is failing to provide a “robust, risk-based regime of inspections, is imposing excessive burdens both on responsible law- abiding businesses and local authorities, and may be creating
incentives and opportunities for criminals”. Perhaps the committee’s most damning statement is its comment regarding DEFRA’s unwillingness to publish inspection rates, noting: “We have concerns that they are not being published to avoid highlighting DEFRA’s historic non-compliance with its own targets.” It was highlighted that inspection rates and charging structures varied away from Dover, a situation that could be exploited to avoid costs and circumvent inspections. The committee called on DEFRA to clarify inspection rates, explain the differences between ports and demonstrate how risk-based inspection rates are being met. The agreement reached between the EU and UK on 19 May 2025 to work towards a establishing a common sanitary and phytosanitary (SPS) area was referred to. However, the reader should note that there has been little progress in the discussions; that the UK will have to rely on the present system; states can always withdraw from agreements; and, given the incidence of foot and mouth in the EU, satisfactory controls for all trade will be required.
The committee welcomed the high level of compliance amongst industry operators, indicating the latter’s awareness of their role in ensuring food safety and wider biosecurity. However, the concerns of businesses about value for money and inspection standards, etc, were noted in the report. From an enforcement viewpoint, funding, staffing and system access to enable them to carry out their legal obligations, all concerned the EFRA committee. What’s required The following statement from the committee sums up the situation: “Delivering a border system that is truly effective, efficient and equitable will require sustained investment, meaningful engagement and a commitment to learning from the lessons of the past.” One question that has been asked of BIFA is whether relying on local authorities to conduct checks is still the correct approach? It is this sort of fundamental question that needs considering and resolving. The full committee report can be found at UK-EU trade: towards a resilient border strategy.
“ Delivering a border system that is truly effective, efficient and equitable will require sustained investment, meaningful engagement and a commitment to learning from the lessons of the past –EFRA
December 2025 | 17
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