Policy & Compliance
government’s definition of an operational system and trade’s. Once government has delivered an operational system, commercial software developers will need additional time to develop the relevant systems to operate in conjunction with the STW. It is the latter date on which the true operational start date should be based. More concerning, although statements in the BTOM indicate that this issue is being addressed, is that in the demonstration model all data was manually input. This has been addressed in the sense that frequent reference is made in the BTOM to providing an Application Programming Interface (API) to software developers, which is to be welcomed. But how the STW is going to interact with Community Service Provider (CSP) systems which control payments and inventory systems is less clear. This raises the possibility of government’s attempts to improve one element of border flows having a negative impact on other processes, particularly inventory control and release. Publicly, BIFA has raised questions regarding the present arrangements for inspecting freight at Port Health Authority (PHA) manned Border Control Posts. Members have expressed concerns, which have been re-stated in public about payment procedures to secure cargo release from potentially multiple different local authorities, all with different charging levels. BIFA believes that there needs to be a centralised portal linking the different PHAs to simplify payment arrangements. One area of particular concern is that there is still a lack of clarity regarding the provision of inland Border Control Posts in Kent for goods entering via the port of Dover or Eurotunnel. The BTOM states: “A decision will be published soon on the future of both Sevington and Bastion Point Border Control Posts.” BIFA has publicly criticised this indecision and also the Common User Charge, which it is proposed to charge for each consignment eligible for Phytosanitary checks entering via the Port of Dover or Eurotunnel. The suggested charge is between £20 and £43 per consignment; however, there needs to be yet another consultation on the level of charge. Also there needs to be resolution as to how and when the fee will be collected. The logical point is when the IPAFF (Import of products, animals, food and feed) system declaration is made, but then government will have to introduce a mechanism to remit monies to the relevant PHAs. BIFA’s last and biggest criticism of the BTOM and STW, because they appear to be closely linked, is that it is a missed opportunity. Government performance at the border is frequently criticised; one particular complaint is the slow response time compared with authorities in other jurisdictions when resolving issues. This problem has a variety of causes but the difficulty in contacting officials in person to resolve a problem, is cited as a significant issue. It is important at this stage to point out that whilst compliance with the controls set out in the BTOM will be mandatory, the use of the STW, at this moment in time, is voluntary. If nothing else, it is clear that government is still actively trying to improve how the frontier operates. The BTOM is a policy document, not an operational handbook – and one of our main aims will be to clarify how these policies will work in practice.
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moved directly from Ireland via Irish ports to Great Britain. All ports will be required to apply full Customs controls to non-qualifying goods and goods such as excise goods moving from Ireland to Great Britain, meaning that these goods must have a valid declaration and be Customs cleared to be able to proceed to their destination. Government intends to implement the model through two major milestones: 31 January 2024 i. The introduction of pre-notification requirements (except for low-risk plants and plant products) and full Customs controls. ii. The introduction of health certification on imports of medium-risk animal products, plants, plant products and high-risk food and feed of non- animal origin from the EU. From 31 October 2024 i. The introduction of documentary and risk-based identity and physical checks on medium-risk animal products, plants, plant products and high- risk food and feed of non-animal origin from the EU. ii. The requirement for Safety and Security declarations for imports into Great Britain from the EU or from other territories where the waiver applies will come into force from 31 October 2024. Alongside this, a reduced dataset for imports will be introduced. In conclusion, certain elements of the document are forward thinking and set a clear direction of travel, particularly relative to the STW. However, this is a potential weakness because many of our future frontier processes appear to be reliant on a system still in its design phase and thus unproven in the real world. Having seen the Great Britain Safety & Security system in operation via the STW, there are elements to commend it, certainly for the small user. However, the mistakes of CDS are being repeated because once again access is via the Government Gateway – which caused significant problems when the first mentioned service was introduced. This time the issues may be multiplied because data filing by more than one trader is envisaged – leading to the question how will this be facilitated? Also, given the history of IT projects, the timelines for implementing an operational STW are very ambitious. We have to be cautious to differentiate between
“ In conclusion, certain elements of the document are forward thinking setting a clear direction of travel, particularly relative to the STW
16 | October 2023
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