The UK’s Border Target Operating Model (BTOM) – post-Brexit Britain’s new border model, comprising a set of security, control and safety rules for import goods – is finally being phased in, starting Wednesday, January 31.
Which dairy imports from the EU fall into each of the risk categories within the new risk-based system?
Medium
Chilled or frozen dairy products that contain raw milk (e.g. Roquefort)
Infant formula, follow-on formula, FSMP and baby food
Low
Non-raw dairy products, frozen or chilled (e.g. cheese and butter made with pasteurized milk)
Ambient dairy (e.g. UHT milk)
Information correct as of January 30, 2024. For revisions, check gov.uk
This means that imports of animal products, live animals, plants and other agri-food products will be subject to Sanitary and Phytosanitary (SPS) checks, a new control mechanism designed in line with global border requirements to maintain and safeguard biosecurity. Additional customs procedures will also start to apply to EU imports at later dates, and goods have been categorized according to three risk categories:
- low: unlikely to be subject to routine documentary or physical checks and only require a commercial document from the supplier;
- medium: more likely to be subject to physical and documentary checks, must have a health certificate, the importer must notify the UK authorities before the goods arrive in Britain, and after April 30, the goods must travel through specific border control points; and
- high: physical checks are mandatory, plus the requirements for a health certificate and a pre-arrival notification.
Many dairy products – such as cheeses that contain raw milk – are considered medium-risk, while shelf-stable dairy and chilled pasteurized milk products fall in the low-risk category.
DairyReporter reached out to the Institute of Export & International Trade, a trade association representing exporters and importers, to find out how much friction and red tape the new rules could introduce.
Marco Forgione, director general of the Institute, explained: “Many dairy products are classed as ‘medium risk’, meaning that to be exported from the EU they will need an Export Health Certificate (EHC) and a notification in EU’s TRACES NT system [an online digital certification and management platform for the import of goods, ed.].
“This means that the exporter needs to apply via their local authority for the EHC, and the official veterinarian will need to endorse the certificate. How smoothly this process goes will depend on the individual exporter’s knowledge and confidence, as well as the availability of official veterinarians in the exporting country.
“It will also have a cost implication anywhere from approximately €140 to €260 per shipment, depending on different categories and administration charges.”
Over in the UK, the importer will then need to arrange for a notification in the Import of Products, Animals, Food and Feed system (IPAFFS) with a Common Health Entry Document (a document that records the outcome of the checks),