19 April 2024


Traders and logistics service providers are preparing for the next phase of the UK's new Border Target Operating Model (BTOM), with physical checks on certain goods subject to veterinary and phytosanitary control (SPS goods) commencing from April 30. These checks will be conducted at specialized Border Control Points (BCPs). The UK Government is implementing a Common User Charge (CUC) to cover the costs of these controls. The exact amounts of the CUCs were published less than four weeks before their implementation, and there remains some uncertainty still regarding additional charges at ports and BCPs, which will be payable on top of the Common User Charge to private operators.

Freight forwarders, carriers, logistics service providers, and customs agents typically do not absorb these charges, even when they arrange payments as agents; instead, they pass them on to their clients, either the importer or the exporter. It is expected that these additional costs will lead to higher consumer prices due to the increasing cost of importing SPS goods into the UK. Small traders, both in the UK and the EU, specializing in niche products, will be particularly affected.

For European logistics service providers most uncertainty lies still in the lack of a legal framework for handling new IPAFFS reports by intermediaries, especially those not established in the UK. While the roles and responsibilities of forwarders, carriers, and customs agents are well-defined in national and international legislation, an 'IPAFFS agent' has yet to be legally defined by the UK government. The responsibilities and status of EU-based operators transiting through the UK also remain unclear. The mechanism for paying or collecting CUC is also opaque, as it requires registration to the UK’s IPAFFS system, but the status and legal responsibilities of agents and non-UK registered entities remain undefined.

As several IT border customs projects are unfolding this year on both sides of the Channel, the logistics and customs sectors are stretched thin, both in resources and patience. While tackling significant EU IT customs system launches at home, the European freight industry is bracing for further changes in UK border processes in October, when EU carriers will be required to file pre-arrival declarations for all goods destined for the UK. It remains uncertain whether EU carriers can manage these declarations themselves, whether UK customs agents will have the capacity to assist them, and whether importers are prepared to absorb yet another additional cost to their transactions.