Delayed five times, the UK’s post-Brexit system of import controls on food and animal and plant products such as meat, fish and dairy arriving from the EU is finally due to be launched on 31 January 2024. Three months later, the second phase of the new Brexit Border Target Operating Model (BTOM) covering imports from the rest of the world will kick in.
At least, that’s the theory.
Previous starting dates have been postponed for reasons offered up by ministers ranging from the impact of Covid to the Russian invasion of Ukraine. More recently, the cost-of-living crisis and inflation have also been thrown into the mix even though EU states managed to implement corresponding controls on UK goods arriving at their borders immediately after we left the EU.
Brexit border delays
In a rare apparent moment of honesty, Jacob Rees-Mogg of all people appeared to admit the real reason for the UK continually kicking the can down the road when confirming the latest delay last April while still minister for Brexit opportunities. Describing the delay as good news for consumers in the context of the cost-of-living crisis, he said enforcing the post-Brexit checks “would have been an act of self-harm”.
Rees-Mogg is, of course, no longer a minister but his prophecy could soon become a reality with at least some of the new costs faced by EU exporters negotiating the UK’s new trading barriers with our nearest neighbours likely to be passed on to consumers.
So, what does it all mean for those tasked with implementing the BTOM?
Border Target Operating Model
At ports like Hull, spare a thought for the people having to manage the biggest shake-up in the way we import food and animal and plant products in 30 years.
Inspectors at the Hull and Goole Port Health Authority will carry out both documentary and physical checks using two state of-the-art border control posts at Hull’s King George Dock and Killinghome on the Humber. They were built at huge expense with the intention of becoming operational in July 2021 but have remained largely unused thanks to the ever-changing political goalposts.
Between them, Hull and Killingholme typically handle nearly 150 million kilos of EU food every year. At the moment, none of it is subject to any import checks or charges but that will change from February.
Having previously recruited staff to cope with the anticipated extra workload only to be forced to then make them redundant because of the delays, the current approach is a cautious one. Sally Johnson, the authority’s chief report health inspector, is planning to hire a number of temporary staff until the full impact of the new regime is known while required veterinary work is being contracted out.
Paying for Brexit border checks
It’s a chicken and egg situation. Income from new inspection charges will cover the extra staffing costs but until goods start arriving in bulk, stop-gap funding is coming from the government to pay their wages. However, in true muddled post-Brexit style, this particular pot of cash from the Department for Environment, Food and Rural Affairs (DEFRA) runs out soon.
In a new report, Johnson said a “multitude of outstanding operational and financial uncertainties” associated with “developing areas of policy and readiness concerns” remain:
“Critically, the funding to underpin operational requirements associated with the new regime will be stopped almost immediately on the new regime going live. DEFRA recognise that the short timescales now involved mean that there will be issues with recruiting and training staff to operate at full capacity by 30 April 2024.”
Now on the Brexit frontline, port health authorities still fulfil their original remit by controlling infectious disease affecting passengers and crew on vessels arriving in the UK; checking food safety, sanitation and hygiene on board ships; monitoring dockside pollution; as well as inspecting food imports to minimise the risk to public health. Yet they remain something of a Cinderella service within the wider local government world and their work is almost unknown to the general public.
The Hull and Goole authority dates from 1887 and is mainly funded by a simple annual levy paid by three local councils based around the estuary. As such, financing a major recruitment drive at short notice is no easy task.
Brexit impact on trade with the EU
Meanwhile, EU producers will be weighing up the cost of continuing to ship their goods to the UK as they face a raft of new charges and paperwork.
Under the BTOM, the requirement to carry out physical checks on low and medium-risk goods is being reduced to just 1% of all imports. However, high-risk products from the EU will still be subject to 100% documentary, identity and physical checks. At the Humber ports, that will equate to a £370 charge per high-risk consignment whereas, at the moment, there are no checks or charges at all.
Even low-risk food and animal origin products from the EU will be subject to charges for the first time. Consignments of up to six tonnes will be subject to a minimum inspection charge of £49.36 per load with an additional £8 being levied for every additional tonne above that.
The new charges are in line with those already imposed on non-EU imports.
Little wonder Rishi Sunak described his Windsor framework deal as “unbelievably special” for Northern Ireland, hailing the province’s continued unhindered access to the EU single market as “exciting” even if appearing to miss the irony of it all.
For the rest of us, however, the latest economic equivalent of shooting yourself in the foot is almost upon us.