In 2020, the government promised "the world's most effective border" by 2025 and published a roadmap towards delivering it. Since then we've had nothing but delays and now we seem to have a Potemkin border, one that looks nice on paper but is really just a facade. Eight years after the referendum, four years on from leaving the EU with a withdrawal agreement, and three years after the end of the transition period the UK government a few days ago finally got around to starting to implement checks on goods and food products coming in from Europe. The EU began on day one, 1 February 2021.
I’m really not sure why it takes us so long to build border control posts, whether it’s planning, money, lack of political will, or what it is but we just seem appallingly bad at creating any sort of infrastructure.
A start date for these checks has already been delayed five times, which itself says a lot about Whitehall’s inability either to be sufficiently pessimistic and forecast schedules you can rely on or commit to spending enough money to get the job done. I appreciate things are often difficult to predict accurately but five dates have had to be abandoned and each time new ones are set, only to be delayed again, and again and again. We have become an international joke.
Whitehall clearly had little faith we could get a border - let alone the world's most effective one - working properly in one go so it was designed to be phased in over nine months. The Border Target Operating Model (BTOM) confirmed the plan was to implement controls through three major milestones:
31 January 2024 - The introduction of health certification on imports of medium-risk animal products, plants, plant products and high-risk food (and feed) of non-animal origin from the EU
30 April 2024 - The introduction of documentary and risk-based identity and physical checks on medium-risk animal products, plants, plant products, and high-risk food (and feed) of non-animal origin from the EU. At this point, Imports of Sanitary and Phytosanitary goods from the rest of the world will begin to benefit from the new risk-based model
31 October 2024 - Safety and Security declarations for EU imports will come into force alongside the introduction of a reduced dataset for imports
So, a few days ago we got phase One where imports were supposed to arrive with health certificates and the result can be seen in this tweet in response to Lord Frost:
I spent 5 hours of my life queuing at Sevington Inland Border Facility this morning, thanks to your shit show of Brexit. The staff (who were great) couldn’t cope with the increased demand so the drivers were all released without full custom checks being completed.
— Charlie Watt (@Ginger_Elvis88) February 1, 2024
The BCP at Sevington in Kent - 22 miles from the port of Dover - was overwhelmed and had to just let traffic through without any checks.
It was as I suggested the other day, a bit of a damp squib. It was obvious this would happen if there were too many trucks and too few staff. The next problem will come at the end of April when documentary and risk-based identity and physical checks on medium-risk animal products, plants, plant products, and high-risk food (and feed) of non-animal origin will start.
The industry is already warning that this could reduce the shelf life of food products because of delays and is bound to raise costs.
A group representing 30 trade bodies covering £100 billion of the UK's food supply chain has claimed that the new rules from April requiring importers to notify authorities a day before they arrive in the UK was “unfeasible” and could mean that some European businesses decide to stop supplying the UK.
Now the FT has seen internal government documents that confirm the BCPs "may not be able to complete 100 percent documentary checks before a consignment's arrival in GB."
In this case, a process known as TODCOF or “timed out decision contingency feature” will apply to medium-risk animal products “on an interim basis.” I think this means they won't be checked.
Apparently, the government had assumed that if goods arrived before their documentation had been verified, they would be automatically routed for physical inspection with an expectation that this would apply to only 1 percent of consignments. Now the contingency planning document seen by the FT warns the system could be overwhelmed "because border control posts by April might not be ready to complete the required checks in time."
The TODCOF system would then apply to avoid routing goods for physical inspection and to indicate that “a documentary check had not been undertaken but the consignment was cleared for entry”.
The FT quotes industry experts who claim the mechanism simply reflects the reality of imposing border checks on plant and animal products that were designed for long-haul exports, not the high-intensity traffic of cross-Channel trade that developed during the UK's membership of the EU single market.
Peter Hardwick, trade policy adviser for the British Meat Processors Association, said the mechanism was “clearly a sticking plaster”.
I imagine if anyone in Whitehall had forecast in 2020 that it would take three years to build checkpoints for imports at Dover, nobody would have believed it possible but that is exactly how it's turned out. Now it seems even the 31 January 2024 date should also have been delayed but it would have been too embarrassing for ministers, so checks had to begin despite reservations on the part of various trade bodies and experts.
Remember, in 2018 Dominic Raab was reported saying: “I hadn’t quite understood the full extent of this, but if you look at the UK and look at how we trade in goods, we are particularly reliant on the Dover-Calais crossing.
“And that is one of the reasons why we have wanted to make sure we have a specific and very proximate relationship with the EU, to ensure frictionless trade at the border … I don’t think it is a question so much of the risk of major shortages, but I think probably the average consumer might not be aware of the full extent to which the choice of goods that we have in the stores are dependent on one or two very specific trade routes.”
The average consumer may soon become aware I think.
At least we have made a bit of progress, going from no border at all to having the world's most ineffective one. Roll on 2025.
