4th Report - UK-EU trade: towards a resilient border strategy
Select Committee
Environment, Food and Rural Affairs Committee
HC 1279
15 September 2025
Recommendations
18 results
2
Accepted in Part
Require Defra to publish a thorough review of BTOM implementation and quarterly port inspection rates by January 2026.
Recommendation
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 …
Read more
Government Response Summary
The government partially accepts, committing to improve understanding of inspection rates and variations across BCPs and to continue collecting inspection data, but does not commit to a new comprehensive public review by January 2026 or a specific approach/timescale for publishing quarterly inspection rates.
4
Rejected
Require Defra to assess intentional non-compliance within the BTOM and outline corrective steps.
Recommendation
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 …
Read more
Government Response Summary
The government rejects conducting the proposed review to assess intentional non-compliance, but agrees with the principle of investigating and addressing such issues, citing existing departmental actions and capabilities.
6
Acknowledged
Require Defra to provide risk assessment models and underlying data for SPS inspection rates.
Recommendation
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 …
Read more
Government Response Summary
The government agrees that transparency is beneficial and outlines its risk-based regime for SPS controls, describing the factors used in risk categorisation, but does not commit to providing the specific assessment models and underlying data as requested.
8
Accepted in Part
Require Defra to provide Sevington BCP lorry data, validate re-exported goods, and assess commercial sealing.
Recommendation
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 …
Read more
Government Response Summary
The government partially accepts the recommendation, committing to provide further data on non-attendance at Sevington BCP by January 2026, and outlining the process for validating re-exported goods. It assesses commercial seals but rejects a legal mechanism due to potential for abuse and logistical challenges.
10
Accepted in Part
Require confirmation of disease commodity code database and a 24/7 IPAFFS update team.
Recommendation
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 …
Read more
Government Response Summary
The government partially accepts, confirming that a dedicated digital team is in place to update IPAFFS 24/7. However, it declines to publicly share the list of commodity codes for notifiable diseases, citing exploitation risks, but confirms their identification is complete.
13
Deferred
Set out strategic objectives for shared EU-UK digital border biosecurity systems, clarifying IPAFFS adoption.
Recommendation
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 …
Read more
Government Response Summary
The government defers action on setting out strategic objectives, clarifying system adoption, outlining contingency plans, or publishing comparative analysis, as formal EU negotiations have not yet commenced.
14
Accepted in Part
IPAFFS must ensure full interoperability with EU and local systems for border biosecurity.
Recommendation
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 …
Read more
Government Response Summary
The government partially accepts, committing to maintain and update IPAFFS and evaluate its feasibility for integration with EU systems, but rejects providing wider access to local authorities due to data concerns and defers specific integration commitments until EU negotiations.
15
Accepted in Part
Confirm real-time IPAFFS access for local authorities and publish digital interoperability roadmap.
Recommendation
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 …
Read more
Government Response Summary
The government partially accepts, committing to maintain and update IPAFFS and evaluate its integration with EU systems, but rejects giving wider access to local authorities due to data implications and cannot commit to pilot projects before EU negotiations commence.
17
Deferred
Provide analysis of Single Trade Window delays and outline renewed implementation timeline and costs.
Recommendation
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 …
Read more
Government Response Summary
The government states that the Single Trade Window Programme is not led by Defra, and therefore, this response is not the appropriate place to provide an analysis of delays or a future roadmap.
18
Acknowledged
Develop future border cost recovery mechanisms collaboratively with industry to rebuild trust.
Recommendation
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 …
Read more
Government Response Summary
The government acknowledges industry concerns regarding the Common User Charge, explaining its cost recovery model and transparent publication of operating costs, and notes that an annual review of the charge is ongoing.
19
Accepted in Part
Co-design BCP cost recovery mechanisms with industry and publish Sevington Inland BCP operational costs.
Recommendation
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 …
Read more
Government Response Summary
The government states the Common User Charge (CUC) was designed to minimise business impact and publishes estimated operating costs for Sevington BCP, committing to publish actual costs after the annual review, but doesn't explicitly commit to co-design future mechanisms with industry.
21
Accepted in Part
Adopt hybrid BCP/PoD plant inspection model and share biosecurity protocols for inland BCPs.
Recommendation
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 …
Read more
Government Response Summary
The government rejects adopting a hybrid inspection model that includes PoDs, citing biosecurity and legislative reasons. However, it did provide the requested guidance on biosecurity protocols for inspecting multiple consignments at BCPs in an attached annex.
22
Acknowledged
Future border policy development requires structured, transparent stakeholder consultation from the outset.
Recommendation
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)
Government Response Summary
The government accepts the recommendation, agreeing on the vitality of communicating timelines for decision-making and delivery during the BTOM to UK-EU SPS Agreement transition, and will communicate with industry after negotiations begin, but does not detail a process for structured, transparent, and iterative consultation.
23
Accepted
Commit to clear timelines, a delivery plan, and prompt communication during BTOM transition.
Recommendation
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)
Government Response Summary
The government accepts the recommendation, committing to communicate clear timelines for decision-making and delivery throughout the transition from BTOM to the UK-EU SPS Agreement to help businesses plan.
24
Accepted in Part
Potential Sevington BCP sale raises commitment concerns and creates local authority uncertainty.
Recommendation
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 …
Read more
Government Response Summary
The government partially accepts the recommendation, committing to maintain and improve the Sevington BCP in the interim and comply with the New Burdens Doctrine for local authorities, but defers clarity on the site's long-term future pending EU negotiations.
25
Accepted in Part
Clarify Sevington BCP future, commit to maintenance, and support affected local authorities financially.
Recommendation
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 …
Read more
Government Response Summary
The government partially accepts the recommendation, committing to maintain and improve the Sevington BCP in the interim and comply with the New Burdens Doctrine for local authorities, but defers clarity on the site's long-term future pending EU negotiations.
26
Accepted
People's welfare and working conditions are central to successful border system design.
Recommendation
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 …
Read more
Government Response Summary
The government accepts the recommendation, detailing ongoing improvements to welfare facilities and measures to reduce wait times at the Defra-run Sevington BCP, while noting employer responsibility for health and safety at other BCPs.
27
Accepted
Outline plans to reduce haulier wait times and ensure adequate 24-hour driver welfare facilities.
Recommendation
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 …
Read more
Government Response Summary
The government accepts this recommendation, outlining ongoing improvements to welfare facilities at Sevington BCP and actions to reduce wait times by coordinating inspections and ensuring proper documentation.
Conclusions (9) Observations and findings — click to expand
1
Conclusion
Acknowledged
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 …
Government Response Summary
The government agrees that a robust, risk-based regime is essential for safeguarding biosecurity through the BTOM and shares context on how the implemented regime supports this. They balance transparency with commercial sensitivity and operational confidentiality and cannot commit to a specific approach to publication. They highlight that Sevington is the only government-run BCP in Great Britain.
3
Conclusion
Acknowledged
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
Government Response Summary
The government acknowledges the principle of investigating and addressing non-compliance, referencing existing enforcement actions and a commitment to improve data and develop strategies to tackle non-compliance trends, but it does not propose a specific review to address varying inspection rates.
5
Conclusion
Acknowledged
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 …
Government Response Summary
The government agrees that transparency in risk-based assessment models is beneficial and outlines its existing SPS control regime, but it does not commit to new specific actions regarding the open publication or review of underlying models and data.
7
Conclusion
Accepted
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 …
Government Response Summary
The government describes its ongoing efforts to review data on non-attendance at Sevington BCP, follow up on missing vehicles, and improve data collection, stating these actions address the committee's concerns about enforcement robustness.
9
Conclusion
Acknowledged
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 …
Government Response Summary
The government acknowledges concerns about the functionality, integration, and reliability of IT systems underpinning the UK's border biosecurity regime. They welcome efforts to review data recording and analysis within port health authority and Defra IT systems.
11
Conclusion
Accepted in Part
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 …
Government Response Summary
The government acknowledges the importance of understanding inspection rates and will work to improve its use of existing data and consider how it can be articulated publicly, while also emphasizing that border checks are not the primary mechanism for managing biosecurity risks; Defra commits to continue collecting inspection data at each port.
12
Conclusion
Deferred
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)
Government Response Summary
The government states that formal negotiations with the EU for the SPS Agreement have not yet commenced, making it impossible to provide confirmation or a cost-benefit analysis at this stage. They expect negotiations to start later in the autumn and will carefully consider options during negotiations.
16
Conclusion
Acknowledged
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 …
Government Response Summary
The government reiterates its commitment to the Single Trade Window, which aligns with the committee's observation of its importance, but does not directly address the specific point about learning from past cost overruns and delays in system development.
20
Conclusion
Rejected
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 …
Government Response Summary
The government rejects reintroducing Place of Destination (PoD) inspections, stating the scheme was temporary, concluded in April 2024, and did not meet necessary biosecurity standards or legislative requirements for permanent facilities.