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SPS Border Checks and the Common User Charge: the first week

The 30th April saw the implementation of the largest stage of the Border Target Operating Model (BTOM).   

These highly publicised and anticipated changes introduced checks and associated costs for UK importers of animal, food and plant products. Specifically, from 30th April, medium-risk plant, animal and food products, as well as the high-risk products already subject to checks, will be liable for checks at specifically designated Border Control Posts across the UK.  As well as these checks, all SPS importers are now subjected to Common User Charges, Documentation Check Admin fees and/or inspection fees  dependent on their port of entry.  

The arrival of these measures, however, has not been without some concerns. Ahead of their implementation, an article published by the Financial Times indicated that DEFRA did not intend checks to commence as stated on 30th April, and that the rate of checks would be initially ‘set to zero for all commodities’ to avoid unmanageable queues at border control posts.   

Though DEFRA responded by confirming that ‘the medium and high-risk goods posing the greatest biosecurity risk are being prioritised as we build up to full check rates and high levels of compliance’, the Environment, Food and Rural Affairs Committee released the following statement after seeking further clarify from DEFRA over the ‘phased implementation’.  

“Defra has said that there will be graduated approach to the introduction of checks and that they will be building up to full inspection rates over time, but it is disappointing that they have been unable to provide clear answers on when the measures will be scaled up to their intended capacity.” 

Concerns have also been raised by commercial ports operating the private border control posts that will host the checks. As late as April 28th, port operators were reporting that they remained unaware of the percentage of checks to be carried out and who to bill since they are currently unable to access importer details from DEFRA’s system (notably IPAFFS).   Additionally, the private firms who have invested money in creating the Border Control Posts mandated by the Border Target Operating Model have the difficult task of trying to recoup their costs but ensuring that their prices are competitive and in line with other commercial and government run BCPs. Indeed Tees Global contacted Port Health Authorities across the UK and discovered considerable variability in charges and approaches to the charges.  

Though the new system is only in its first week, initial reports have suggested a mixed reception to their implementation. The Load Star spoke to one customs broker who reported having multiple vehicles held at both Dover and Hull due to IT issues with some reports seeming to indicate that HMRC were having to clear shipments manually. Another source claimed that there were ‘300 HGVs waiting at the Sevington border facility.’ However, HMRC have denied these claims, and we have read verbal accounts praising DEFRA for their support when any issues were encountered.   

We will continue to update traders on the impact of the checks and charges as new information comes to light. In the meantime, any businesses seeking support with SPS imports should contact our specialists at  

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