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

Key findings

• Risk-based inspection rates set by the BTOM are not being met across ports, with capacity challenges causing lower inspection rates than intended, and auto-clearance mechanisms ('TODCOF') routinely used despite being intended only as contingency measures.
• The IPAFFS digital system is fundamentally flawed—it took six days to update commodity codes after the January 2025 FMD ban on German products, allowing prohibited goods to auto-clear for a six-day period, exposing critical gaps in IT responsiveness and data reliability.
• Sevington inland border control post, located 22 miles from Dover, creates enforcement vulnerabilities allowing lorries to offload contraband en-route or fail to present for inspection, with weak mechanisms to track goods post-inspection.
• Inland local authorities, essential to the BTOM's enforcement, received no additional funding despite expanded responsibilities, have limited access to IPAFFS, and face inadequate data-sharing from national agencies, hampering illegal import detection.
• Industry stakeholders report unequal inspection rates across ports enable gaming of the system, small and medium enterprises face disproportionate costs (e.g., £14,500 CUC fees for 3% inspections), and the planned Single Trade Window has been indefinitely paused due to cost overruns.

Recommendations

• Defra must conduct a thorough review of BTOM implementation by January 2026, clarifying port-by-port inspection rate variations, auto-clearance usage frequency, and publish quarterly inspection rates for all ports starting January 2026 including historic data.
• Defra should assess intentional non-compliance (mis-declarations, fraudulent documents) and outline steps to address it, including exploring mandatory commercial sealing of vehicles at origin and tracking mechanisms for goods post-inspection at Sevington.
• Defra must provide risk-based assessment models and underlying data used to determine SPS inspection rates to the Committee and make them publicly available to enhance transparency and rebuild stakeholder confidence.
• Government should confirm establishment of a 24/7, 365 digital team to update IPAFFS and provide a pre-identified commodity code database for the top five notifiable diseases; clarify whether IPAFFS will be retired for TRACES NT integration or replaced wholesale.
• Defra should ensure local authorities have real-time access to IPAFFS, conduct a comprehensive interoperability assessment across national and local authorities within three months, launch pilot projects for cross-border digital integration, and publish a publicly available roadmap with clear milestones.
• Any future Border Control Post cost recovery mechanism must be co-designed with industry, avoid disproportionate impact on SMEs, and Defra should publish operational costs of Sevington Inland BCP in the interest of transparency.
• Department should provide analysis of Single Trade Window delays and outline renewed implementation timeline and associated development costs; future border systems must prioritise ease of use and interoperability.
• Defra should provide August and November 2024 figures on lorries directed to Sevington versus those presenting for inspection, and assess merits of a legal mechanism requiring commercial sealing of animal and plant product vehicles.

Key actors

Alistair Carmichael, Baroness Hayman, Helen Buckingham, National Farmers' Union, Fresh Produce Consortium, Dover Port Health Authority, Food Standards Agency, Department for Environment, Food and Rural Affairs