One of the critical issues surrounding GB’s exit from the EU was the need for new ways of checking freight. Most border checking points between UK and EU countries had been closed since free circulation rules and harmonised border safety checks were introduced in the 1990s. A new system had to be found with basic infrastructure lacking in the UK and key EU ports. In a pragmatic approach, some international health, safety and border checks were not immediately implemented for goods arriving from EU Member States at GB borders.

The TOM aims to produce an up-to-date, state-of-the-art border management service in the UK, which will apply to all third countries, including EU Member States. As the ministerial foreword says:
It will move us closer to our goal of creating the most effective border in the world, by introducing an improved regime of sanitary, phytosanitary and security controls on imports. These controls are essential to maintaining our security and biosecurity and will better protect us and our environment from invasive pests and diseases. Protect public health and deliver food that is safe to eat, whilst maintaining security of supply for consumers, and disrupt criminal activity before it can harm our communities.

Much focus is placed on biosecurity with critical dates for implementing checks on Products of Animal Origin (POAO) and similar items spanning 12 months from 31st October 2023. As well as the biosecurity systems, the TOM is also looking to introduce standard pre-departure messaging safety & security checks on all cargo entering the UK, thereby including the EU in these S&S measures in full for the first time since the EU exit. Increasing checks and security verifications could have a detrimental effect on UK businesses by slowing trade, so there is an acknowledged but fine line between doing enough and restricting business growth that the TOM aims to address.

Feedback and questions around the details provided in the TOM are encouraged, and UK Government highlights four main questions and seeks your views on the following:

1. The new model for Safety & Security controls, their impact on businesses and their implementation
2. The new model for Sanitary and Phytosanitary controls, its impact on biosecurity, animal health and welfare, food safety, and businesses, as well as its implementation
3. What challenges exist for the private sector in meeting the proposed timeline for introducing the new model, and how can specific business models for importing be further supported to prepare?
4. What further detail is needed for businesses to prepare for and implement the new Border Target Operating Model?

Though some have said that it will only really affect the UK importing companies, the changes and infrastructure outlined in the TOM are closely linked to the development of the UK Single Trade Window (STW) - which looks to automate border checks as much as possible, and to eliminate duplication of information having to be submitted to different agents – the complete 2025 UK Border Strategy and the aim for UK exports to reach £1 Trillion annually by the end of the decade.

Many of us are perhaps still coping with fatigue from all the changes made to UK systems and legislation in the last five years linked to the EU exit and COVID-19. Still, this next step must be taken seriously, and, despite the fatigue, we must give it 100% of our attention and focus.