Checks on animal products instituted with the introduction of the Border Target Operating Model (BTOM) could be waived should the UK’s ports become overwhelmed, reporting by the FT has suggested today (7 February).
Todcof system
An automated clearance process called the ‘timed out decision contingency feature’, or Todcof, will be applied in the case of medium-risk animal products “on an interim basis” as the government continues implementation of new measures on imports.
The FT notes that the documents outlining the mechanism have not previously been reported, and were posted on Portsmouth city council’s website.
New border rules introduced as part of BTOM’s implementation at the end of January mean that EU firms exporting to the UK must provide health certificates to UK port authorities 24 hours in advance of their shipment arriving – otherwise the shipment will be sent for physical checks.
Completing these checks in time may not be possible, the documents suggest, and to avoid an overwhelming number of physical checks, the Todcof system will note that, while “a documentary check [has] not been undertaken”, the consignment is still “cleared for entry”.
Freight fears
A trade intermediary representative body, the Freight Liaison Group, said that there was confusion over whether a port health authority could still charge for a documentary check. The group argued that industry had not been consulted on the contingency measure and what form it would take:
“If the vehicles get waved through and don’t get processed, are people still going to be charged? If you go to the car wash and they’re too busy and wave you away, you don’t want to still pay for the car wash.”
The Dover Port Health Authority, meanwhile, expressed fears that the system could allow unauthorised meat products into the UK, saying that it “raised serious questions” on the health risks associated with the introduction of the system.
The Department for Environment, Food and Rural Affairs (DEFRA) responded to the story to say:
“We have strict border controls in place to protect our high biosecurity standards — and are confident that existing and new infrastructure will have the capacity and capability to handle the volume of expected checks.
“As any responsible government would do, we closely monitor our borders and have prepared contingency measures to ensure businesses are properly supported.”
The IOE&IT perspective
Trade and customs specialist Laura Williams said she “wasn’t surprised” by the introduction of the measures, stating that the period between 31 January and 30 April, when the next phase of BTOM implementation begins, is “very clearly a dry run from a technical perspective”.
“When you have that many steps right off the bat, there will always be teething problems. I was unaware of the temporary system, and I also have concerns. I would be very surprised if all border control points have an adequate number of staff to cope with the volume. Some may, but there are more popular border crossing points than others.
“Post-delivery checks may be something that DEFRA considers in this environment, which is why it's very important to ensure the information on the Common Health Entry Document (CHED) is correct. I do believe we'll see delays at ports, but we will see areas without full implementation immediately.
“The Institute of Export and International Trade (IOE&IT) is keeping its knowledge base up to date, attending all information sessions from DEFRA and government agencies, and updating our courses and consultancies to reflect this. It's an ever-changing environment, and we expect the hardest step will happen on 30 April. We're here to support businesses in any way we can through those steps.”