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Government announces delays to final stages of implementing border controls
Jacob Rees-Mogg, the Minister for Brexit Opportunities and Government Efficiency, made a written ministerial submission to parliament on 28 April 2022 detailing further delays to the implementation of the final stages of import controls on EU goods entering the UK. The statement reads: “It would therefore be wrong to impose new administrative burdens and risk disruption at ports and to supply chains at this point. The remaining import controls on EU goods will no longer be introduced this year – saving British businesses up to £1 billion in annual costs.” In a subsequent conference call with trade, the minister re-iterated that the main drivers for the change of policy were the increased cost of living and the disruption resulting from the war in the Ukraine. Unchanged policies Many Members have been commenting for some time that whilst the UK has left the EU, we are still following most of its Customs policies and procedures. For ro-ro it has been noted that, if all the controls were introduced, three separate systems would have to be utilised to declare standard goods – CHIEF/CDS, GVMS and S&S GB. On behalf of its Members, BIFA has been asking government to consider using the data, for instance, in the pre-lodged Customs declaration as satisfying the requirement to submit an import safety and security declaration in the ro-ro environment. Effectively the UK is pausing the introduction of the next phases of the planned frontier controls with the EU to allow the review of procedures applied to global traffic – this will include both EU and rest-of-the-world trade. It is believed that this review will lead to the development of new policies which, when introduced, will be different to those envisaged in Effectively the UK is pausing the introduction of the next phases of the planned frontier controls with the EU to allow the review of procedures applied to global traffic
the Border Operating Model. These new procedures will be designed for all trade. The minister states: “This new approach will apply equally to goods from the EU and goods from the rest of the world. It will be based on a proper assessment of risk, with a proportionate, risk-based and technologically advanced approach to controls. This includes the Single Trade Window, which will start to deliver from 2023, the creation of an ecosystem of trust between government and industry, and other transformational projects as part of our 2025 Borders Strategy.” The 2023 date is significant, because that is when the new Customs Declaration Service (CDS) is due to be fully deployed to trade for both import and export traffic. Some, including BIFA, have already suggested that the new system should be the cornerstone of the Single Trade Window. From a purely operational viewpoint, BIFA Members have to be aware that the controls already introduced will remain in place. However, the following controls, which were planned for introduction from July 2022, will now not be introduced: • A requirement for further sanitary and phytosanitary (SPS) checks on EU imports currently at destination to be moved to Border Control Post (BCP). • A requirement for safety and security declarations on EU imports. • A requirement for further health certification and SPS checks for EU imports. • Prohibitions and restrictions on the import of chilled meats from the EU.
of both Houses of Parliament in due course. In autumn 2022, the government has undertaken to publish a Target Operating Model, which will set out the new regime of border import controls as part of the 2025 Borders Strategy. This is an ambitious timeframe and it is to be hoped that government will remember one key lesson from EU Exit: to consult with those who currently make the frontier work and devise policies based upon what will actually work in practice. Whilst technology is important, the human element and market structures also have to be taken into account when formulating policy. It is to be hoped that unlike certain processes included in the BOM, such as those relating to the haulier having to file the import safety and security declaration, all the new policies will be of a practical nature that can be quickly implemented by the current supply chain participants. Timeframe challenges Also, given the ambitious nature of this schedule, one point that springs to mind relates to any additional legislation that might be required and how the time will be found to draft and pass it through parliament within the relevant timeframes. BIFA will ensure that its Members’ views are presented to government in any consultations, but some of the issues are complex and will take time to resolve. If there is one plea to make to this government, it would have to be that this will be the last time for the foreseeable future that such significant change is imposed. What this sector needs, at a domestic level at least, is a period of stability to enable it to recover from various significant events in the last five years.
The Border Operating Model will be updated to reflect this, and a copy will be placed in the libraries
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June 2022
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