The government’s much-vaunted Border Target Operating Model (BTOM) is flawed and is failing to provide a ‘robust, risk-based regime of inspections’ of potentially infected food imports coming into thd country, MPs have concluded.
Hot on the heels of its damning report into the wider failings of the UK’s biosecurity border controls, the Environment, Food and Rural Affairs (EFRA) Committee has today published a new report into UK-EU trade and the government’s border strategy.
It is equally critical, finding that the BTOM is ‘flawed’ and ‘inadequate’ as banned products pass through the border unchecked. It concludes that Defra has no effective system of oversight for [biosecurity] border controls and that the previous government’s vision for the UK’s Biosecurity, Borders and Trade Programme has not been realised.
This is ‘not simply an operational concern but continues to present real threats to the health of UK animals and plants and therefore the viability of our agricultural and horticultural sectors’, the report warns.
The report says that ‘it is essential that present arrangements are reviewed and bolstered’. MPs heard that the system is failing to provide a robust, risk-based regime of inspections, is imposing excessive burdens both on responsible, law-abiding businesses and on local authorities, and may be creating incentives and opportunities for criminals.
It found that varying inspection rates at different ports of entry has created a system that can be gamed by people seeking to dodge costs or import illegal goods, thus jeopardising biosecurity and damaging trust in the system amongst law-abiding compliant businesses.
The MPs also expresses doubt over the explanations given for Defra’s reluctance to publish inspection rates, saying that it is ‘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,” the report said.
The Committee is calling on Defra to clarify the inspection rates, explain the variations between ports and demonstrate how risk-based inspection rates are being met.
Sevington
The report highlights numerous problems with the effective operations of commercial border controls, particularly at the Short Straits. Echoing concerns repeatedly raised by the Dover Port Health Authority and others, it noted ‘specific and repeated concerns that the unique location of Sevington inland BCP [Border Control Post], 22 miles away from the Port of Dover, provides opportunities for exploitation by criminals’.
The report also lists flawed IT systems and data gaps as being amongst the causes of weak enforcement. The Committee heard, for example, that after the government introduced a ban on meat imports from Germany in early 2025 in response to an outbreak of foot and mouth disease, prohibited products were able to continue entering UK for a further six days because of the use of a default digital mechanism known as ‘TODCOF auto-clearing’.
UK-EU deal
The MPs looked at the implications of the Common Understanding to work towards establishing a commonsanitary and phytosanitary (SPS) area agreed between the UK and EU in May. It noted that the UK will continue to rely on the present system of biosecurity controls until an agreement is reached and in circumstances in which an agreement is not reached or is withdrawn from.
MPs found that the UK-EU negotiations offer the opportunity for government to reset its relations with UK stakeholders as well as with the EU, stressing that ‘delivering a border system that is truly effective, efficient, and equitable will require sustained investment, meaningful engagement, and a commitment to learning from the lessons of the past’.
The Committee reports that there is a high level of compliance amongst industry but that companies are dissatisfied with the current enforcement regime because of their concerns over value for money, inspection standards and biosecurity. The report says that better transparency, consistent enforcement and clear communications are necessary to rebuild trust with importers and businesses.
The MPs also heard that a further problem exists at the stage of inland local authorities, which have responsibility for control of imports that have passed border posts, as local authorities have not received the necessary funding, staffing or system access to enable them to carry out these responsibilities.
Failing enforcement
EFRA chair Alistair Carmichael said while compliance by law-abiding companies with the import control rules is high, despite the high costs the system imposes on them, enforcement by the relevant authorities is failing, despite the best efforts of the operating teams and management. This is leaving the UK’s biosecurity ‘at serious risk and allowing opportunities for criminal enterprise’.
He said: “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.”
Defra response
A government spokesperson said: “Rebuilding the UK’s biosecurity remains a key government priority, and we are investing £1 billion in a new National Biosecurity Centre to boost our world leading facilities and protect our farmers, food supply and economy.
“The Border Target Operating Model is designed to protect our livestock, crops and food chain from dangerous diseases while minimising disruption to trade, and must be followed while we finalise our veterinary agreement with the EU that will make trade with our biggest market cheaper and easier.”