UK TOM operating model

It should be noted that Northern Ireland remains under EU trade conditions, although changes to these procedures are formulated within the Windsor Framework.

One of the critical issues surrounding GB's exit from the EU was the need for new ways of checking cargo. Most of the border crossings between the UK and EU countries had been closed since the introduction of free movement rules and harmonised border security checks in the 1990s. A new system had to be found with the basic infrastructure that the UK and key EU ports lacked. Out of pragmatism, some international sanitary, security and border controls were not immediately implemented for goods arriving from EU member states at UK borders.

TOM aims to create an up-to-date, state-of-the-art UK border management service that will apply to all third countries, including EU member states. As the ministerial introduction reads:

"This will bring us closer to our goal of creating the most effective border in the world by implementing a streamlined regime of sanitary, phytosanitary and import security controls. These controls are essential to maintain our safety and biosecurity and better protect us and our environment from invasive pests and diseases. Protect public health and provide food that is safe to eat while maintaining a safe supply for consumers and prevent criminal activities before they harm our communities."

Much of the focus has been on biosecurity, with critical implementation dates for inspections of products of animal origin (POAO) and similar elements spanning 12 months from 31 October 2023. In addition to biosecurity systems, the TOM also intends to introduce standardised pre-departure notices of safety and security checks on all cargo entering the UK, thereby fully involving the EU in these safety and security measures for the first time since leaving the EU. Increasing the number of security checks and verifications can have a detrimental effect on UK businesses, slowing down trade, so there is a confirmed but fine line between doing enough and limiting business growth, which TOM aims to address.

Feedback and questions on the details outlined in the TOM are encouraged and the UK Government is highlighting four main questions and asking for views on the following topics:

1.  The new model of safety and security controls, their impact on the business and their implementation
2. The new model for sanitary and phytosanitary controls, its impact on biosecurity, animal health and welfare, food safety and enterprises, and its implementation
3. What challenges does the private sector face in meeting the proposed timetable for the introduction of the new model, and how can specific import business models be further supported to prepare for this?
4. What further details do companies need to prepare for and implement the new Border Target operating model?

While some have argued that it will really only affect UK importing companies, the changes and infrastructure outlined in the TOM are closely linked to the development of the UK's Single Window for Trade (STW) - which aims to automate border clearance as much as possible, and eliminate the duplication of information that needs to be passed to different agents - the UK's complete border strategy by 2025, and the target for UK exports to reach £1 trillion a year by the end of the decade.

Perhaps many of us are still struggling with the fatigue of all the changes made to UK systems and regulations over the past five years related to the EU exit and COVID-19. However, this next step needs to be taken seriously and given 100% of attention and focus despite the fatigue.