TDUK explores the new UK Border Target Operating Model

UK Border Target Operating Model

TDUK offers its members insight into the new UK Border Target Operating Model, and what this means for the timber sector.

There has been a flurry of Government communications over the last month ahead of the 31 January implementation date of the new UK Border Target Operating Model (BTOM). This document, published last summer, is being promoted as a world-leading system to improve safety, security, and sanitary controls at the UK border after Brexit.

Unfortunately, these communications have caused some confusion in the sector because they appear to suggest the upcoming changes to the phytosanitary requirements for Plant imports may also be applicable to the imports of wood products.

To be clear, the plant health border control systems for the import of wood products will remain fundamentally unchanged after 31 January. Responsibility will remain with the Forestry Commission and the process required is laid out online here.

One important change coming into place on 31 January is in relation to the waiver codes that are regularly used by importers of wood within their customs declarations. TDUK published a Trade Note on this specific topic earlier in January, which members can read online here.

The Forestry Commission also provided information to all registered professional operators on the critical border changes in its most recent plant health newsletter, which is online here.

It is also important to be aware that, from 31 January, full customs procedures will be implemented on exports coming to Great Britain from Ireland – any members involved in such exports should discuss the implications with their nominated customs agent.

The new BTOM has brought some welcome changes in terms of online information, with the UK integrated online Trade Tariff now showing specific plant health requirements against the individual commodity codes. This will allow traders to not only see that their chosen commodity code has plant health requirements, but also see the countries to which these requirements apply, and the waiver code that could be used against customs declarations for products originating outside this group of regulated countries.

The sector has further implementation stages of the BTOM to look forward to. The next of these is 30 April 2024, at which date high-risk plant products (including regulated wood imports) must come through a Border Control Post (BCP) or Control Point (CP) where identity and physical checks will be carried out. Checks will no longer take place at designated inland Places of Destination (PoDs).

The Forestry Commission’s advice for GB importers of wood, wood products and bark is:

  • if you currently use a POD, find an appropriate BCP and start planning your route for the changes to checking high-risk goods coming into force from 30 April 2024, or
  • consider becoming CP designated and have your checks done on-site. More information about becoming a CP can be found here.

The third stage takes effect from 31 October, 2024, when safety and security (S&S) declarations for imports from the EU will become mandatory. This is scheduled to take place alongside the rollout of a single trade window or portal for streamlined pre-arrival datasets. The government should publish more details on this in due course, and this issue has already sparked a number of questions to the TDUK inbox from our membership.

Below, we have provided a couple of contrasting examples that illustrate the positive changes in the UK integrated online Trade Tariff and highlight why the new waiver codes are so important.

  • If we first look at commodity code 4407961000, which is used for Planed, end-jointed products made of Birch wood. Under the Imports Controls section there is a clear requirement for a Quarantine Release Certificate, which applies to those countries within Phytosanitary Group 9. This is currently a group of 11 countries including those from the EU where ALB is known to be present. The “Conditions” link highlights that wood declared under this code, which originates in a country not on the Phytosanitary Group 9 list, should use the waiver code 992Y to show it is excluded from the requirement to provide a Quarantine Release Certificate, by virtue of the country in which it originates.
  • If we now look at the commodity code for Birch Plywood 4412331090; under the Import Controls section we see the requirement for a Quarantine Release Certificate is absent. This is because Birch Plywood products are not considered a plant health risk in relation to ALB. This means the “Conditions” link is also absent and therefore there is no requirement to include a waiver code on your customs declarations for Birch Plywood originating in EU Member states.