Long read

BTOM: Food for thought on a growing problem

By Dan Culverhouse

- Last updated on GMT

The new Border Targeting Operating Model came into force in April of this year. Credit: Getty / PCH-Vector
The new Border Targeting Operating Model came into force in April of this year. Credit: Getty / PCH-Vector
Dan Culverhouse, UK&I managing director of Customs Support, analyses whether the recent relationship ‘reset’ with Europe will help resolve border issues.

Prime minister Sir Keir Starmer’s offer of an olive branch ‘relationship reset’ to the UK’s nearest European trading partners in France and Germany is a fitting visual analogy as an attempt to secure a positive legacy from the divisive discourse of Brexit.

This fresh approach can only work if the branch is grasped in a timely fashion so that the olives don’t risk simply withering on the vine.

Fresh produce, by its very nature, ceases to be so if unnecessary delay denies its distribution and, therefore, its definition. When we talk about ‘farm to fork’ or just in time delivery, supply chain optimisation is key to the end-to-end process from picking to packing, palletising, purchasing and putting on a plate.

If the olive in our analogy represents proactive diplomatic intentions, the move represents growing hope for UK stores and European growers in the wake of the new Border Targeting Operating Model (BTOM), the post-Brexit rules that govern the biosecurity of fresh produce entering the UK.

What is BTOM?

The rules that came into force at the end of April have not only caused disagreements over increased costs and operational viability. While it’s been ‘kicking off’ between Brussels, businesses and bureaucrats, the consequential delays have created a sterile political eco-system where fruit and veg has the potential to simply ‘go off’ on the quayside while waiting for an all-clear certificate.

BTOM classifies all plant and animal products coming from the EU and puts them into three risk groups: high, medium and low.

In its wisdom, the previous UK government placed many fruit and vegetable imports into the medium risk category, meaning multi-page documentation must be provided at the new border points.

With most fresh produce arriving in the UK in mixed loads, questions have been raised around potential delays and how to unpick the consignments in a timely fashion, particularly given question marks over the numbers of inspectors mandated to issue phytosanitary certificates at the relevant competent authority.

The Fresh Produce Consortium (FPC) argues the process will add £200 million in additional import costs, fees that will negatively impact small fruit and veg enterprises and ultimately be passed on to British consumers.

Race to the BTOM

The new rules, as far as businesses on both sides of the channel are concerned, provide a perfect example of a ‘race to the BTOM’ in that no one wins – there is simply no advantage to the UK or the EU if growers can’t get their goods to market in time and shortages and outages cause price hikes in the retail supply chain.

The rules seem to have created more confusion and less resolution for cross-border trade, according to the FPC and the Chartered Institute of Export and Trade (CIET), both of whose members have been at the sharp end of border delays because of the seemingly mixed ‘best practice’ messaging issued by Defra for goods leaving and entering the UK.

According to the CIET in one recent update, Defra advised traders sending goods to consider their choice of border control post (BCP) by reminding traders that “consignments need to enter GB at a point of entry with an appropriately designated BCP”.

However, it also said traders need to send goods to the same BCP they nominated in the Common Health Entry Document (CHED) which accompanies medium-risk and high-risk goods. Consequently, this caused costly confusion when traders selected a BCP not equipped to process their type of goods.

The Netherlands is the one of the world’s largest plant and flower exporters while the UK is the second-biggest importers of cut flowers from that region, another example of confusion growing into a major issue for Anglo-Dutch relations. Lorry drivers from the Netherlands could refuse UK deliveries following a barrage of complaints about conditions and processes at the UK’s BCPs.

Transport en Logistiek Nederland (TLN), a trade body which represents roughly 5,000 transport companies, said that its members reported average waits of four hours at facilities at Sevington, the government-run facility that serves the Port of Dover.

This was in addition to concerns about the conditions for drivers, with Sevington’s waiting room containing nothing but a water cooler and nowhere to buy food.

One TLN member said that a shipment of plants worth £34,000 had been rejected due to damage sustained during the BCP inspection process.

Meanwhile, other TLN members have called for private BCPs to be more up-front about the costs associated with inspections. Some reported receiving bills as high as £800 following a delivery, with no explanation as to which checks were carried out to generate such a high fee.

A brighter future?

As a business specialising in cross border resolutions to optimise supply chain efficiency, our clients look to us to resolve these challenges so that they can focus on their core activity growing their products and their businesses on both sides of the Channel.

Our role is to translate and troubleshoot border challenges on behalf of clients. Transparency is everything and businesses need expertise to optimise supply chains rather than the seemingly Kafka-esque opacity and bureaucratic processes they now face.

Overall, the olive branch re-set is an opportunity to create better cross-channel collaboration in a post-Brexit world where rotting fruit and veg and decomposing plants currently provide an emblematic and unedifying legacy backdrop. Conversely, the BTOMs of this world leave a bad taste.

In terms of language, it’s rather ironic that mandarin is a fruit, a language and a descriptor of a civil servant, a bureaucrat who translates the simple into the unnecessarily complicated. While the fruit is easy to peel, the civil servant can often be thick-skinned and prone to use impenetrable language.

Expertise and explanation in plain speak is a specialism that will always create the right translation to help peel away Whitehall or Brussels jargon. It delivers by keeping the wheels of commerce turning and going beyond the simple and performative posturing of European leaders.

Related topics Regulation & Legislation Trade

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