Key BTOM Checks May Be Skipped If UK Ports Face Congestion

Information obtained by the Financial Times suggests that there’s a chance animal products coming into the UK from the EU might not undergo the required BTOM checks. These checks might be bypassed if British ports get too busy due to the application of the new post-Brexit border rules.


Starting from the end of January 2024, new border rules called the Border Target Operating Model (BTOM) have been put into place. These rules categorise all animal products arriving from the EU into three risk categories: high, medium, and low. Medium- and high-risk meat products now need to have health certificates before they are allowed to enter the UK.

Under these regulations, EU companies sending goods to the UK need to provide health certificates to UK port authorities 24 hours before their shipment arrives. This allows officials sufficient time to review the paperwork.

If the paperwork isn’t checked before the goods arrive, they will automatically be scheduled for a physical inspection. Failure to submit the required paperwork will result in their shipment undergoing physical inspection.

These checks will occur at specific border control posts designated for this purpose. Many of these control posts are expansions of current facilities that already inspect plant and animal goods from non-EU countries.

And some posts have been created specifically for these new regulations. One example is a newly built £147 million facility near Dover in Sevington. This facility will handle all the products passing through the UK’s busiest port.

Only 1 per cent of shipments were initially intended to undergo this process. However, as outlined in a contingency planning document, there’s concern that border control posts may not be fully prepared to conduct these checks by April.

Introduction of Todcof

The growing pressure on British ports dealing with the new post-Brexit border regulations indicates the potential necessity for a backup plan to manage any disruptions or congestion.

This plan may involve implementing measures to prevent delays in transporting goods and ensuring the smooth entry of essential products like animal-derived foods into the UK.

As part of the ongoing implementation of new import measures, meeting the deadlines for these checks might be challenging.

Therefore, a temporary automated clearance process known as the ‘timed out decision contingency feature’ (Todcof) will be specifically applied to medium-risk animal products. This will be on an interim basis” as the government continues implementation of new measures on imports.

The Todcof system would intervene to prevent goods from undergoing physical inspection. Instead, it would indicate that no documentary check was conducted, but the consignment has still been cleared for entry.

This process will allow goods to enter the UK without requiring paperwork checks if there are capacity issues at border control posts.

The Financial Times notes that the documents explaining the process haven’t been reported before and were posted on Portsmouth City Council’s website for the first time.

Organisations React

Different organisations have reacted to the idea of potentially skipping BTOM checks. The Freight Liaison Group, which represents trade intermediaries, seemed unsure if port health authorities could still charge for checking paperwork.

Meanwhile, the Dover Port Health Authority raised concerns about unauthorised meat products entering the UK, stressing the health risks involved. The Department for Environment, Food and Rural Affairs (DEFRA), however, emphasised their strong border controls and confidence in the ability of current and new infrastructure to handle checks effectively. They assured that they’re keeping a close eye on things and have backup plans to support businesses if needed.

This highlights the challenge of balancing trade and safety at the UK border.

What are the next steps?

Things are changing, and we expect more updates in the coming months, especially by April 30th. Don’t worry, we’ll keep you informed every step of the way.

At iCustoms, we’re here to support you with any help and guidance you need as these changes unfold.

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