"Border Target Operating Model is potentially a missed opportunity for UK horticulture"

The UK government announced the final publication of the Border Target Operating Model (BTOM) yesterday. Despite the aim of the model to protect the UK against security and biosecurity threats and ensure a smooth flow of goods, several horticulture industry members express disappointment as delays and costs will increase throughout the chain. It even has been said that the BTOM is potentially a missed opportunity for UK horticulture. In this article, some reactions from the industry.

Positive first steps, but the HTA urges further progress on Border Trade Plans for horticulture
The Horticultural Trades Association (HTA) represents over 1,500 members across the UK environmental horticulture sector, and Fran Barnes, Chief Executive, said, "Our unwavering focus has consistently centered on ensuring the seamless, swift, and secure movement of plants and plant products while protecting the UK against biosecurity threats. While we acknowledge the positive strides made with the formal release of the Border Target Operating Model, the model doesn't go far enough in adequately addressing the legitimate needs of the horticultural sector."

"One major concern lies in the readiness of Border Control Posts (BCPs) to handle the diverse range of imports received by the horticultural sector from the EU. We welcome the proposed delay to the introduction of checks at BCPs until 30 April 2024. However, we are disappointed that this date is inconveniently placed in the middle of the high season for the plant trade and that the delay is not long enough to complete the proposed pilot of the Authorised Operator Status model.

"Since January 2021, the industry has followed import and export requirements outlined in the Trade & Co-operation Agreement (TCA) due to the absence of a Sanitary Phytosanitary (SPS) or plant health agreement with the EU. However, it is clear there needs to be better dialogue between the EU and the UK regarding plant imports. Given that the value of imported plant material surpassed £753 million in 2022, constituting half of the cumulative value of the UK's trees, plants, seeds, and bulbs production sector, it is imperative that we impress upon the government the need for ongoing refinement of the BTOM.

"Furthermore, this issue will impact garden center customers: the expected costs of full border controls to the supply chain are estimated to top £42m per annum (at existing pre-notified consignment numbers). Therefore, beyond 2024, this would equate to a 4.5% cost increase for no material gain. And there is also potential that plant ranges will be restricted or delayed, meaning a reduced choice for garden enthusiasts."

Delays and increase in costs
Also, Neil Alcock of Seiont Nurseries, a plug and liner producer in Caernarfon, Gwynedd, and Andy Burton of Double H Nurseries, a wholesale plant nursery in New Milton, are concerned about the increased costs and delays.

Alcock: "I believe that the already 5 times delayed border control model will increase costs and create more friction for our imports from the EU. Although not ideal, the current system of inspecting incoming stock in our nurseries is working okay for us. There is still some uncertainty about the exact cost, which will apply to every consignment, but it's somewhere between £25 and £43. With over 150 trucks on a large Ferry, it could take hours to check even a small percentage, so who will pay for the standing time of trucks? Us! Seiont Nurseries, as exporters, have already seen this with our product going to the EU, who implemented their Border control checks immediately after Brexit. We now pay a lot more for transport costs due to trucks standing longer. We have to work a lot harder now to maintain our EU sales. It's just another Brexit non-benefit!"

Burton: "Our products are categorized as high risk, so they are already subject to Dutch and UK plant health checks on import. The main change that will impact us next year is that checks won't be carried out at the Place of Destination (POD), so we will need to use a Border Control Post (BCP) or set our site up as a Control Point (CP). This will add further cost and risk of delay to the import process. As always, we will try to mitigate these costs as far as possible, but they will inevitably create further inflation of prices, which is obviously not what consumers want!"

Concerns to be addressed:
In HTA's announcement that was sent out yesterday, they say that they emphasize the importance of meticulous planning, thorough testing, and effective communication to ensure a smooth transition to any new trade system, recognizing the significance of the horticulture industry. They highlighted three concerns that need to be addressed.

Working collaboratively with the government
The association also mentioned that they are committed to working collaboratively with the government to ensure that the plant trade remains a top priority. Sally Cullimore, Technical Policy Manager at the Horticultural Trades Association, added: "We want to work with the government to deliver a border model that is efficient, cost-effective, accessible to all businesses, and recognizes the EU's unique role in supplying the UK gardening and landscape market. The horticultural sector faces an unprecedented regulatory burden, and we need the government to understand our industry's importance and impact. While we welcome some changes in this final publication, we are disappointed that the final model has not fully addressed our red line asks. We urge the government to keep the door open on the BTOM to enable us to continue to collaboratively engage with Defra and other stakeholders in our shared pursuit of enhancements that will notably benefit UK horticulture."

Links and sessions to learn more about the BTOM
HTA also shared the following links to learn more about the BTOM, what it means for plants, and seminars about what this means for the horticultural sector (7 September), as well as a session on what this means for exports from Ireland (21 September).

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