Border Target Operating Model is flawed and inadequate, states report

New Environment, Food and Rural Affairs (EFRA) Committee report into UK-EU trade and the government’s border strategy report expresses severe criticism of the Border Target Operating Model.

Tray of succulents in pots

The ‘UK-EU Trade: Towards a Resilient Border Strategy‘ report identifies the Border Target Operating Model (BTOM) as being “flawed” and “inadequate,” highlighting its failure to effectively prevent the unauthorised passage of prohibited products through the border.

The report revealed that inconsistent inspection rates at the different ports engendered a system susceptible to exploitation to evade costs or import illegal goods. Consequently, posing a real threat to biosecurity and damaging trust in the system amongst law-abiding, compliant businesses. The committee calls on Defra to clarify the inspection rates and to explain the variations between ports and demonstrate how risk-based inspection rates are being met.

The report concluded that the Department for Environment, Food & Rural Affairs (Defra) lacks an effective oversight system for border controls, and that the government’s vision for UK’s Biosecurity, Borders and Trade Programme has not been realised. The EFRA Committee warned “This failure has presented, and continues to present, real threats to the biosecurity of British animals and plants and the viability of our agricultural and horticultural sectors.”

Committee Chair, Alistair Carmichael MP said: “In our scrutiny of the control and inspection of commercially imported animal and plant products through UK borders, we found high compliance by law-abiding companies, despite the high costs the system imposes on them and even though they have been subject to uncertainty, short-notice changes and unexpected additional costs. While these companies show high compliance, they do not have confidence that the system is operating fairly.

“The other side of the coin is enforcement by the relevant authorities and here we found that, despite the best efforts of the operating teams and management, the operations are failing, leaving the UK’s biosecurity at serious risk and allowing opportunities for criminal enterprise.

“Our report describes the numerous problems and inadequacies which are making it impossible for the designated authorities to do their job. These problems arise from a failure by successive governments to appreciate the gravity of the threat, listen to stakeholders, address problems in real time and to understand that, even in a time of scarcity these operations must be adequately funded.”

The Horticultural Trades Association (HTA) welcomed the publication of the EFRA Committee report. The HTA strongly supports this call, warning that without proper funding for enforcement teams, illegal and mis-declared goods will continue to enter the UK unchecked, putting plant health and supply chains at risk.

Earlier this year, the HTA submitted evidence to the Committee, reflecting several key recommendations, including: adopting a hybrid inspection model that combines Border Control Post (BCP) and Place of Destination (PoD) inspections to reduce plant damage, delays, and improve biosecurity; acknowledging the increased costs, administrative burdens, and supply chain disruption facing horticultural SMEs; and calling for better transparency and consultation, including Defra publishing quarterly inspection data and working more closely with industry.

Sally Cullimore, HTA Technical and Trade Policy Manager, said: “This report is a wake-up call. Despite soaring costs and ongoing supply chain disruption, our members have gone above and beyond to comply with the rules – yet they are paying the price for a system that isn’t working. We fully support Alistair Carmichael MP’s call for fair and consistent enforcement, backed by properly resourced teams protecting the UK’s borders. Without this, illegal and mis-declared goods will continue to slip through, putting plant health at risk.”

Cullimore added: “The Committee’s recognition of our evidence, particularly our recommendation to adopt a hybrid inspection model, is welcome, but we now need prompt action to ease the current situation before the SPS/Plant Health agreement with the EU is in place. The Point of Destination system needs to be swiftly reintroduced as an easement, as the current burden is too great for our members. Any delay risks further damage to an industry that is key to achieving the UK’s environmental targets. UK environmental horticulture relies on more than £780 million worth of plant imports annually, with 79% of nurseries sourcing from the EU. Getting this right is essential to safeguard plant health, secure supply chains, and protect the future competitiveness of our industry, while maintaining the variety that UK consumers have come to expect.

“We will continue to work with Defra, APHA and Parliament to help them deliver a border system that is effective, fair, and resilient. Our members deserve nothing less.”