Pilots will be used to establish the final membership criteria but as a minimum, Accredited Trusted Trader Scheme members will be required to: 

• Be a registered business in the UK for customs purposes;
• Have a record of pre-notifications, initially since January 2022 (other than companies importing solely from the island of Ireland).

Depending on the modules of Accredited Trusted Trader Scheme that a business wishes to engage with, further requirements may apply including:

• Be registered or approved by their local authority, the Food Standards Agency or Food Standards Scotland as a food business or registered with, or approved by, Animal and Plant Health Agency as an animal by-product business
• Have no adverse Sanitary and Phytosanitary compliance history
• Have no adverse customs compliance history
• Have a named responsible person/s for the identification, management and monitoring of risks
• Implement government-produced standard operating procedures to ensure equivalent assurance of public health and biosecurity safeguards
• Have bio-secure premises and infrastructure
• Provide end-to-end supply chain assurance; and
• Have suitably trained staff who can act independently.

It is fundamental that the Accredited Trusted Trader Scheme is co-designed by government and industry, so ambitious businesses will be part of these pilots with a view to making the co-designed model available to all businesses who wish to apply and meet the criteria, if the pilot is successful.

Pilots will need to be fully risk assessed and reviewed as they progress, to ensure the measures in place are providing equivalent assurance in practice. They will look to build upon industry practices in developing requirements for assurance, with the final scheme design finalised after these pilots take place. These assurances are essential for the pilot schemes to operate, and, in all instances, final decisions will be taken prior to when we go-live, depending on whether governments believe the pilot can operate safely under pilot conditions.

The pilots will consider:

• Overall system – What is a business’ overall strategy for complying with import conditions? How does it review its system? How does it plan to agree variations with the competent authority?
• Traceability – How does a business trace a product from primary producer through to retailer?
• Supplier assurance – What level of consistency does it have in the supply chain? What does it ask for in terms of assurance, and how does it verify?
• What are the requirements for accreditation for premises?
• What data/certificates is it collecting and how much of this does it share with the competent authority?
• How does the trader deal with non-compliant consignments?
• How does the trader deal with other notifiable events?
• How will the trader work with officials to allow audits?
• Criteria for membership, fees and dealing with non-conformity to scheme rules.

The pilots will be built around four key phases:

1. Core framework policy development.
2. Application and onboarding phase for businesses involved in the pilot.
3. Pilot development working in partnership with devolved governments, the Food
4. Standards Agency, Food Standards Scotland, and industry participants.
5. Piloting and evaluation.

January 2024 – Certification Logistics Pilot

This module of Accredited Trusted Trader Scheme focuses on streamlining the certification process for animal products, allowing an Export Health Certificate to be used from the point of origin of the goods (e.g., a manufacturing site), without the need for re-certification at a consolidation hub in the EU prior to dispatch to Great Britain, so long as the Trusted Trader can provide acceptable assurances regarding the biosecurity integrity of the goods in the interim, throughout transport, storage, and any limited manipulation that is permitted.

This represents a change from the requirement for goods to be re-inspected by an official veterinarian at a consolidation hub, if they are unloaded and reloaded for transport to Great Britain. The change could potentially save businesses substantial time and administrative resources and expedite the overall movement. This facilitation will also help to alleviate pressures facing the official veterinarian workforce, and the associated challenges this creates for the import industry. Delivery of this pilot is dependent on EU official veterinarians being willing to certify goods in this way.

The pilot, beginning in January 2024, is focused on reducing the logistical constraints for specific business models. HMRC will engage with businesses which meet the required criteria, to co-design and carry out the initial pilot from January.

Some businesses have already been identified, and others who wish to be involved can apply through an EOI, issued in September 2023. If the first stage of the pilot is successful, HMRC may then look to expand the pilot and will run a selection process for other businesses to register interest in taking part later in 2024.

April 2024 – Checks Away From Border Pilot

This module of Accredited Trusted Trader Scheme would allow frequent importers of products of animal origin and animal by-products to reduce the need for routine physical checks at the Border Control Posts by taking responsibility for carrying out checks at other locations, to ensure the protection of biosecurity, animal and public health, whilst being closely regulated by government. The checks carried out by the Trusted Trader at their own site will not necessarily replicate the Border Control Post model but will provide equivalent biosecurity and public health assurance to government.

This change has the potential to substantially enhance operational efficiency for businesses. Conducting checks at an appropriate location away from the border will contribute to smooth border flow. In turn, this will reduce delays at the border, improving the efficiency of the overall supply chain. It will also enable businesses to better plan and manage logistics by offering more predictable and consistent timelines, thereby enhancing overall operational predictability.

Further ATTS Modules

Further modules are being considered as part of the Accredited Trusted Trader Scheme, one of these will consider how supply chain data and technology already utilised by businesses could be drawn upon to provide biosecurity and public health assurances. This will build on the findings from the ‘Ecosystem of Trust’ pilots. Initially, it will be considered whether a module could be designed which draws upon environmental sensor data from devices which record the temperature, humidity and carbon dioxide levels, as well as smart seals, which can track unlocking events and location, to determine whether journey assurance evidence can be utilised as part of sanitary/phytosanitary controls.

The precise benefits associated with this module would need to be determined as part of the co-design and pilot phases, but HMRC initially envisage a proportionate reduction in the level of checks based on the assurance secured via the relevant technology.

Over time, there is scope for the technology module of Accredited Trusted Trader Scheme to be expanded to utilise technological advancements as they become available, to provide further benefits to traders, and when the Single Trade Window has full functionality.

The timelines for this module (and any other additional modules) are still being considered and will be finalised based on the output of the co-design period. Where possible, HMRC will look to initiate pilots for additional benefits from April 2024 in line with the ‘Checks Away From The Border’ pilot. Initially pilots of additional benefits may be limited in scope, for example; working with businesses piloting the use of temperature control data to collect an initial data set to act as a baseline for equivalent assurance.

Evaluation Approach

Official oversight, verification and audit is critical in the pilot phase. The high-level framework for the Checks Away From Border pilot, for example, could cover:

1. Supply chain information - Where the products come from, how they are produced, and by whom, etc.
2. Production assurance - Rules/regulations for producers to uphold (auditing), sampling and testing of products, etc.
3. Pre-arrival checks - For example; at a hub in mainland Europe.
4. Assurance during transit - Temperature trackers, digital seals, etc.
5. Checks at destination - Including who undertakes them and the qualifications they hold/training they have undertaken.
6. Relevant data utilisation and sharing to inform compliance levels and identify non-compliance.

The objective of pilots will be the evaluation of how the Trusted Trader can fulfil the assurances listed above to be able to access Accredited Trusted Trader Scheme benefits, while maintaining the required standards.

Information on how businesses can apply to take part will be released following publication of the Border Target Operating Model, through an ‘Expression of Interest’ process, which will run following publication of the final BTOM.

An extended period of co-design is anticipated, followed by the pilots, which we expect to run for 6 to 12 months.

The pilots will then be formally reviewed, and a full scheme will follow, if successful.

These proposed Trusted Trader schemes will form an important part of a cross-government approach to Trusted Trader schemes, ensuring that they are both beneficial and accessible to industry.