The UK Government will be implementing full border controls for food imports by the end of 2023. This will have a significant impact on imports of food, and it is important your supply chain is ready. Below is an update following the latest developments. We will be on hand to provide briefings and support through our Food and Trade Communities.

2025 UK Border Strategy & Target Operating Model (TOM):

  • This strategy is the UK’s plan to create an effective border, with new technology to make UK borders more efficient. It takes in to account new trading relationships for the UK following Brexit.
  • As part of the strategy, a new Target Operating Model (TOM) is being developed to manage UK imports of animals, animal-derived products, plants and plant-based products and some foods and feeds.

2025 UK Border Strategy – HM Government, December 2020 (publishing.service.gov.uk)

Target Operating Model (TOM) – Update on Draft Publication:

  • The government published details of the draft TOM on 5th of April, setting out proposed plans for importing food and feed into the UK, which come into force 31st of October 2023. A link to the draft can be found here.
  • The Government will be taking comments on it from stakeholders, to refine its implementation and any comments should be sent to the BRC by 10th May 2023 to allow us to collate and submit comments. They have also scheduled a programme of engagement to explain the TOM and provide opportunities to comment. A full list is available here.
  • A briefing document has been put together here by the BRC to share key elements of the TOM. This includes key dates for its delivery, which span across three milestones between the end of October this year and 31 October 2024.

More About the Trusted Trader Scheme and Single Trade Window Which are Part of TOM:

  • The Trusted Trader Scheme is an approach that would allow traders to have less checks on the borders. Instead, checks could be carried out away from the borders, meaning reduced time at the ports, and would allow more streamlined controls. Pilots will be run on this before an evaluation and decision on introducing the approach, and to qualify, traders will need to provide enhanced assurances and evidence that they are meeting regulatory requirements and standards.
  • The TOM will be delivered through simplification, digitisation, and a new Single Trade Window. The Single Trade Window is designed to make it easier to submit data, with the aim of removing duplication of data needed to trade. This new technology will be delivered from 2023 and will be fully operational by 2027.

What About Movement of Goods to Northern Ireland Ports?

The new Windsor Framework (see below) sets out arrangements for the movement of goods to Northern Ireland, with a new system of green and red lanes to protect the UK’s internal market, whilst providing assurances on goods destined for the EU.

The Windsor Framework – New Deal to Replace the Northern Ireland Protocol:

  • Due to Brexit, and political history with Northern Ireland and Ireland borders, the Northern Ireland protocol became part of law and in force from 1 January 2021. Under this protocol, new checks were introduced, even for products remaining in Northern Ireland. This caused extra costs and delays, and restrictions for some products.
  • The Windsor Framework is a new deal aimed at reducing the number of checks and removes some of the restrictions under the Northern Ireland protocol.

Windsor Framework – Adoption and Next Steps, Including Guidance:

  • The Windsor Framework was formally adopted on 24th March by the UK and EU - see here.
  • So now the legislative process can begin to put the framework in to legislation. In a joint statement, the EU and UK agree to work together to adopt the framework.
  • Although the framework is politically adopted, it is not in force until 1 October, so not taken effect until later in the year, and therefore existing measures apply.
  • The BRC are working with members and Defra to feedback on aspects of the Windsor Framework implementation. We are invited to all key Defra and Trade meetings and will keep you updated via our Food and Trade community pages and working groups.

Authorised Trader Scheme to Northern Ireland (NI) Retail Movement Scheme:

The Authorised Trader Scheme as part of Stanley will cease and be replaced by the Northern Ireland (NI) retail movement scheme, which will automatically use the green lane for the movement of goods from Great Britain (GB) to NI.

All 1500 companies currently on Stanley will be automatically moved to the NI retail movement scheme, to ensure simple movement of food retail goods. The scheme is wider than Stanley, and not limited to retailers. It will also apply to wholesalers, foodservice and hospitality.

What Should my Business be Doing?

  • Ensure you are keeping up to date with developments. Through our Trade and Food Community we will be sending details of future border checks.
  • Please see below for a list of online sessions run by Defra giving all impacted sectors the opportunity to understand how the TOM will change the process of importing and exporting to and from the UK. See here.
  • Make sure your European suppliers and importers have visibility of these changes and are preparing for future certification and checks.
  • Consider whether you or your European suppliers and importers should be involved in discussions on the Trusted Trader scheme. These could give you and/or your supply chain an edge.
  • Consider the impact of delays at borders as they are introduced. Although many businesses will be ready, and Government is introducing concessions such as the Trusted Trader scheme and e-certification to speed up the process there may well be delays as the ports begin to handle the increased checks.