After a couple of years of waving through EU imports of meat and animal products with no dockside checks, the UK government is about to apply a sharp twist to food pricing this year. It will start charging businesses a fixed charge on all shipments passing through government-run Border Control Posts. Referred to as the Common User Charge (CUC), it was put out for consultation over three weeks in July last year. While the CUC will be a single fixed payment, there are uncertainties over inspection charges for food shipments that would be billed by BCP operators*. These can total hundreds of pounds for a large container.
On January 31 2024, DEFRA brought into force a number of measures for each of the three risk categories (https://www.gov.uk/government/publications/border-target-operating-model-information-leaflets-for-businesses/technical-questions-and-answers-about-sanitary-and-phytosanitary-controls-sps#risking-approach).
These are as follows
From 31 January 2024, DEFRA has introduced:
- health certification on imports from the EU and European Free Trade Association (EFTA) of medium risk animal products and the introduction of health certification on imports from the EU, Lichtenstein and Switzerland of medium risk plants and plant products
- health certification on imports from the EU and EFTA of high-risk food and feed of non-animal origin
- import pre-notification and health certification when moving EU and EFTA animal products or EU, Switzerland and Lichtenstein plant products from the island of Ireland, to align with the rest of the EU (for example, any goods other than qualifying Northern Irish goods from Irish ports directly to Great Britain)
As of April 24,
From 30 April 2024, DEFRA will be adding:
- 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
- existing inspections of high risk plants and plant products from the EU will move from destination to Border Control Posts
- beginning to simplify imports from non-EU countries – this will include the removal of health certification and routine checks on low risk animal products, plants, plant products from non-EU countries as well as reduction in physical and identity check levels on medium-risk animal products from non-EU countries
What will DEFRA deliver?
2.1 How are checks within a port or airport’s perimeter organised, and who does what and has accountability to make it happen?
Within the curtilage of a sea or airport, the port operator will direct the movement of consignments. At the Border control post (BCP), APHA will undertake checks on live animals, or plants and their products. The Port Health Authority/Local Authority will undertake checks on animal products and High-Risk Feed or Food Not of Animal Origin (HRFNAO). The port operator will not release a consignment from the port until they have been informed that it has been cleared by the relevant inspection authority.
2.2 Will BCPs be ready? Do they have sufficient capacity?
Defra is confident that existing and new BCP infrastructure will have sufficient capacity and capability to handle the volume of expected checks outlined in the BTOM, with robust, dynamic, and effective operational measures ready to call upon if needed. Defra will continue to work with existing BCP operators to ensure they are prepared, and the Government has built new infrastructure at critical locations. Operators have not expressed concerns regarding under-capacity, we are therefore not anticipating queues but will continue working closely with operators to address any concerns they may have.
Where previously we traded as equals with EU member states, we now have to fit in with the 30 or so national legal systems that we used to navigate seamlessly as an EU member state. Significant changes since becoming a third country include an obligation to use solid wood and premium grade packaging materials for shipping goods. In the weeks leading up to Christmas, the cost of solid wood and other materials required by shippers of third country importers went up by 4%. Previous, less costly options, are no longer available since becoming a third country.
- Dover is a particularly complex administrative structure, run by a trust granted à royal warrant by James 1 in1606. The modern Dover east dock facilities were built on reclaimed land. It is operated on behalf of the people of Dover by the district council. DEFRA is trying to reclaim funding for food safety checks since 2022. The department argues that the disputed three million pounds should be recovered from the owners of illicit pigmeat that is uncovered by customs searches. Dover District Council does not think much of this ill-considered non-answer to its problem.