4th Report - UK-EU trade: towards a resilient border strategy

While assessments of the effectiveness of the Border Target Operating Model (BTOM) in safeguarding UK biosecurity vary, and regardless of whether full or partial implementation would be sufficient in principle, Defra and the relevant authorities have not fulfilled their responsibilities under the BTOM in practice. As such, the question of adequacy of the system is largely academic; without effective delivery, even a well-designed model cannot achieve its intended outcomes. We are reassured by the overall level of compliance within industry, but a robust, risk-based regime is essential to maintaining standards and safeguarding biosecurity. We have real concerns that the inspection rates set out in the BTOM risk assessment are not being met and that Defra has no effective system of oversight for border controls. We are not convinced that a lack of published data on the inspection rates is due to a desire to protect the integrity of the intelligence system. We have concerns that they are not being published to avoid highlighting Defra’s historic noncompliance with its own targets. (Conclusion, Paragraph 9)

It is essential that Defra thoroughly reviews the implementation of the BTOM. Defra should commit to this review in its response to our Report, and the review must be published no later than January 2026. It should set out why and how much variation in inspection rates is occurring between ports of entry, and how often auto clearance mechanisms are being used and the reasons for this. In its response to this Report, the Government should commit to the publication of quarterly inspection rates for all ports of entry, beginning January 2026, and to publishing historic quarterly inspection rates. (Recommendation, Paragraph 9)

Varying inspection rates at different ports of entry has created a system that can be gamed by those seeking to dodge costs or import illegal goods and may even introduce “temptation” for legitimate importers who witness their consignments auto-clear important processes. (Conclusion, Paragraph 10) 25

In the review proposed above, Defra should work with relevant Government departments and non-departmental delivery partners to assess the scale and nature of intentional non-compliance and outline the steps it will take to address this. These lessons should also be applied to any future UK-EU trading arrangements. (Recommendation, Paragraph 10)

There is a critical need for greater transparency and accuracy in the modelling and implementation of SPS controls. A failure to publish risk assessments and data informing inspection rates, limits scrutiny and undermines trust in the system. Addressing these issues through open publication and review of underlying models will support more effective, evidence-based policy and enforcement at the GB border. As such, we welcome the commitment the Minister for Biosecurity made on 6 May to review the type of data Defra will publish. (Conclusion, Paragraph 11)

Defra should, in response to this Report, provide us with the risk-based assessment models and underlying data used to determine SPS inspection rates. Publicly available models will enhance transparency, allow for independent scrutiny, and help rebuild stakeholder confidence in the integrity of border biosecurity measures. (Recommendation, Paragraph 11)

Defra maintains that a “robust” enforcement system is in operation at the Short Straits entry point. Within the context of flawed IT systems, data gaps, routine auto-clearance of goods and strained local authorities, the Committee does not share that confidence. We are particularly concerned that the absence of robust enforcement mechanisms between the Short Straits and Sevington inland BCP has created vulnerabilities that may be exploited for the illegal entry of products of animal origin into Great Britain. The current system, as it stands, risks undermining the very assurances that the BTOM was intended to deliver. (Conclusion, Paragraph 15)

In an annex included in the response to this Report, Defra should provide us with the August and November 2024 figures relating to the number of lorries that were directed to Sevington Inland BCP for border checks and the number of lorries that present themselves to the BCP for inspection in that same month. This would allow the committee to scrutinise compliance levels without jeopardising the dynamic nature of intelligence-led biosecurity controls. The Government should also outline what specific process it will implement to validate that goods re-exported following inspections at Sevington Inland BCP do in fact leave the UK. This process should include mechanisms for tracking consignments post-inspection and verifying their departure from UK territory, with appropriate documentation and oversight to ensure compliance. Defra should also provide, in its response to this Report, its assessment of the potential merits of creating a legal mechanism to ensure lorries transporting animal and plant products are commercially sealed. (Recommendation, Paragraph 15) 26 Digital Systems

Throughout our inquiry, we heard repeated and serious concerns about the functionality, integration, and reliability of the IT systems underpinning the UK’s border biosecurity regime. As enforcement relies on data, these concerns raise fundamental questions about the Government’s ability to deliver on its commitments under the BTOM. We welcome the Department’s efforts to review how data are recorded and analysed within port health authority and Defra IT systems and how these can be combined to create a reliable and complete data picture. We note that the Department is now working to pre-identify commodity codes for the top five notifiable diseases to enable faster updates in future. We are also encouraged by the improved response to subsequent FMD outbreaks in Slovakia and Hungary, where IPAFFS was updated immediately in line with policy changes, preventing goods from auto-clearing controls. This demonstrates that lessons are being learned but also underscores the need for a more resilient and responsive system from the outset. (Conclusion, Paragraph 19)

In response to this Report, the Government should confirm that it has produced a list of pre-identified commodity codes for the top five notifiable diseases and provide a copy of this database containing the commodity codes in question to the committee. The Government should also confirm that it has established a digital team that can update IPAFFS ‘24-7, 365’, in line with the statement from the Chief Veterinary Officer. (Recommendation, Paragraph 19)

It is disappointing that it required persistent questioning from the Committee over a period of three months before the Department provided answers to all our questions regarding the initial response to foot and mouth disease (FMD) outbreaks in Europe. This reflected cultural and bureaucratic issues within Defra that impeded effective scrutiny and timely adherence to parliamentary processes, ultimately creating barriers to public transparency. We are encouraged by the Minister’s commitment to improve transparency and the handling of correspondence with the Committee. (Conclusion, Paragraph 20)

The Common Understanding with the EU presents a positive and welcome opportunity to bolster UK biosecurity and we praise the Government for its work in this regard. It remains unclear, however, how the Government sees the new arrangements working in practice. (Conclusion, Paragraph 21)

In response to this Report, the Government should set out its strategic objectives for shared EU–UK digital systems in the context of border biosecurity. Specifically, it should clarify whether IPAFFS will be retired in favour of adopting TRACES NT, or whether a model of integration is preferred. The Government should also outline contingency plans for 27 digital system continuity in the event of a breakdown in any future SPS agreement. Defra should publish a comparative analysis of the costs and benefits of both integrating IPAFFS with TRACES NT, or adopting TRACES NT wholesale, ahead of the establishment of a Common SPS Area. Any new IT systems introduced as part of this transition must undergo rigorous testing prior to deployment and be fully interoperable with existing platforms across both UK and EU jurisdictions, including those used by local authorities. (Recommendation, Paragraph 21)

Until a Common SPS Area is formally established, IPAFFS will remain the UK’s primary digital system for managing border biosecurity. It must therefore be capable of meeting the operational needs of all users and enforcement bodies, including importers, port health authorities, and inland local authorities. The system’s interoperability with EU platforms and local authority systems is essential to ensure effective enforcement and traceability. (Conclusion, Paragraph 24)

In response to this Report, Defra should confirm it is taking steps to provide local authorities with real-time access to IPAFFS to support enforcement and traceability of consignments. Until the UK gains full access to EU systems, IPAFFS should be maintained, updated as needed, and evaluated for potential integration with EU databases to ensure continuity and efficiency during any transitional period. To achieve this, a comprehensive interoperability assessment of existing systems should be conducted across relevant national and local authorities, followed by the establishment of technical standards and data-sharing protocols aligned with EU and local systems. If deemed feasible by the assessments, within the next three months, pilot projects should be launched to test cross-border digital integration with selected local authorities and EU counterparts, helping to identify functionality gaps and inform future improvements. A publicly available roadmap should then be published, setting out clear milestones, timelines, and accountability mechanisms to guide progress toward full digital interoperability. (Recommendation, Paragraph 24) Cost, delays and administrative burden

There is a need to learn from the cost overruns and delays associated with developing new digital systems such as the Single Trade Window. While an SPS deal with the EU may ease administrative burdens, the UK’s global trade requires a fully functioning Single Trade Window to deliver the necessary efficiencies. (Conclusion, Paragraph 27) 28

Future border systems must prioritise ease of use, interoperability, and support for trade growth. In its response to this Report, the Department should provide an analysis of the reasons for the Single Trade Window’s delay. It should also outline the renewed timeline for the implementation of the Window and the costs associated with its development and pausing. (Recommendation, Paragraph 27)

Border control posts recover costs whilst operating as the least-cost, high-efficiency solution for border checks. Industry trust in the Common User Charge has been undermined by a perceived lack of transparency in cost recovery processes and concerns over the widespread use of auto-clearance. Many stakeholders feel they are not receiving value for money. It is vital that future cost recovery mechanisms are developed collaboratively with industry. (Recommendation, Paragraph 29)

If the Government continues to operate a BCP within the common SPS area, any cost recovery mechanism must be co-designed with industry and should not disproportionately affect small and medium-sized enterprises. In the interest of transparency, the Government should publish the operational costs of running Sevington Inland BCP. (Recommendation, Paragraph 29)

Industry has expressed dissatisfaction with the current system of SPS checks on plants and plant products conducted at inland Border Control Posts (BCPs), citing concerns around value for money, inspection standards, and biosecurity. While a future SPS agreement with the EU may significantly reduce or remove the need for such checks, improvements to the current system are necessary to rebuild industry trust and ensure continued compliance and biosecurity in the interim. The competing demands for APHA plant inspectors across BCPs and Control Points, restricts the availability of inspections at CPs, industry’s preferred location, at the time consignments arrive. Reintroducing Place of Destination (PoD) inspections for a limited number of consignments could ease pressure on the system and improve inspector availability at CPs without requiring a significant expansion of the workforce. (Conclusion, Paragraph 35)

The Government should adopt the Horticultural Trades Association’s proposal for a hybrid inspection model, combining BCP and PoD approaches. Following a short consultation with industry, the Government should designate specific consignments eligible for PoD inspections. Additionally, APHA should share with us its guidance on the biosecurity protocols in place for inspecting multiple consignments at inland BCPs, including measures to prevent cross-contamination. (Recommendation, Paragraph 35) 29 Planning and delivery of future commercial biosecurity arrangements

Future border policy development must include structured, transparent, and iterative consultation with stakeholders from the outset to ensure policies are workable and informed by the sector. (Conclusion, Paragraph 40)

During the transition away from the BTOM, the Department should commit to clear timelines for decision-making, a delivery plan, and communicate changes promptly to allow businesses to plan with confidence. (Recommendation, Paragraph 40)

Reports that the Government may be seeking to sell and repurpose the inland border control post at Sevington raises concerns about its ongoing commitment to maintaining and improving the facility while it remains operational. This demonstrates an assumption that an SPS agreement will soon remove the need for inland checks. However, given the uncertainty around the timing of any such agreement, and the significant risks associated with an animal or plant disease outbreak, continued investment in infrastructure and operational efficiency is essential to ensure effective border management in the interim. The announcement of the Common Understanding has also created uncertainty for local authorities who were anticipating recouping the costs of their investment into border facilities through charges for their use. (Conclusion, Paragraph 42)

The Government should publicly clarify its intentions regarding the future of Sevington BCP, including whether it plans to sell or repurpose the site. Regardless of any future SPS agreement, Defra should commit to maintaining the facility and improving the efficiency of current border checks to ensure continued resilience and value for money. In its response to this Report, Defra should set out its position on supporting local authorities who stand to lose out financially due to the proposed agreement with the EU. (Recommendation, Paragraph 42) User experience

Implementing the BTOM goes beyond logistics and finance; people are central to a successful, biosecure border. The welfare, dignity, and working conditions of those delivering and using a border system must be integral to its design and operation. (Conclusion, Paragraph 44) 30

In its response to this Report, Defra should outline plans to reduce current wait times for hauliers at the border and outline how it intends to ensure that all drivers have 24-hour adequate welfare facilities. Any future border infrastructure and operational planning must explicitly include provisions for adequate driver facilities and realistic scheduling, to mitigate the human impact of delays and disruption. (Recommendation, Paragraph 44) 31