Below is an update following the latest developments of the UK Governments implementation of border controls for food imports.
Borders Target Operating Model (BTOM):
- The Borders Target Operating Model (BTOM) will manage UK imports from the EU and Rest of World (RoW) of animals, animal-derived products, plants and plant-based products and some foods and feeds.
- The final briefing was published on the 29th August and can be found here.
- There have been delays to the proposed dates, which have been pushed back by 3 months. This is intended to give businesses more time to prepare. Note the new key dates below:
- 31 January 2024 – health certification applies for imports of medium risk animal products, plants, plant products and high-risk food and feed of non-animal origin from the EU.
- 30 April 2024 – documentary and physical checks on medium risk animal products, plants, plant products and high-risk food and feed of non-animal origin from the EU. Simplified imports from RoW based on risk levels.
- 31 October 2024 – safety and security declarations for imports from the EU. Also reduced data for those on the Single Trade Window to avoid duplication.
- Businesses should be preparing for these new milestones and the BRC will be on hand for support. A detailed briefing with links to risk categorisations has been prepared here.
More About the Trusted Trader Scheme and Single Trade Window Which are Part of BTOM:
- 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.
- Expression of interest for the Trusted Trader Scheme is now live here and open until 6 October 2023.
- The BTOM 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 aims to be fully operational by 2025.
What About Movement of Goods to Northern Ireland Ports?
- The 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 deal aims to reduce the number of checks and removes some of the restrictions under the Northern Ireland protocol.
- The movement scheme has been named the Northern Ireland (NI) Retail Movement Scheme (Remos) and contains labelling requirements that will be implemented in to three different phases between October 2023 and July 2025.
Windsor Framework – Legislation and Next Steps, Including Guidance:
- The arrangements for the Windsor Framework were adopted on 24th March 2023 – see here.
- The Windsor Framework detail of arrangements was published on 9th June 2023 – see here.
- Although the framework is politically adopted, it is not in force until 1 October 2023, so not taken effect until later in the year, and therefore existing measures apply.
- The 1st tranche of guidance on the labelling requirements for certain products moving from Great Britain to retail premises in Northern Ireland under the Northern Ireland (NI) Retail Movement Scheme (Remos) was published on 9th June 2023 – see here. The guidance includes more information on the three phases from 1 October 2023 to 1 July 2025 for individual product labels that will require the words ‘Not for EU’.
- A list of commodity codes that need individual labels in phase 1 under the scheme can be found here.
- The HMRC have published a policy paper regarding the duty reimbursement scheme tax information and impact note on the following link. BRC guidance on this can be found here.
- The next tranche of guidance published on 8th September 2023 here includes further information on the Northern Ireland (NI) Retail Movement Scheme (Remos), and also new guidance for moving plants, seeds, used agricultural and forestry machinery, and seed potatoes to Northern Ireland.
- Defra published guidance on the Northern Ireland Retail Movement Scheme (NIRMS), groupage and the movement of mixed load consignments. Please see links to the guidance below:
- 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 (Remos):
The Authorised Trader Scheme as part of Stanley will cease and be replaced by the Northern Ireland (NI) Retail Movement Scheme (Remos), 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 (Remos), 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.
- 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 Accredited 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 Accredited 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.