The introduction of new border inspections looks set to have major implications for tree nursery businesses and forestry’s continuing battle against pests and disease.
THE UK government exploded its BTOM (Border Target Operating Model) on 30 April. Before Brexit, UK companies importing trees and other plants could phone up the European supplier and receive the goods within just two days, simple as that – but not anymore. That’s because the UK has finally fired the starting gun on its new border policy, which mirrors controls the EU has had in place for UK companies trying to export plants to mainland Europe since the UK formally left the Single Market over three years ago.
As of 31 January 2024, imported plants from the EU (and Switzerland and Liechtenstein) categorised as ‘medium risk’ joined those considered ‘high risk’ in requiring checks by plant health inspectors before they could be transported. This clearly impacted UK companies large and small, including Provender Nurseries, which occupies an eight-hectare site at Swanley in North Kent. This is one of the biggest wholesale nurseries in England, with 5,000 different lines of plants sold to 11,000 customers across the UK.
Managing director Richard McKenna told the press how these post-Brexit requirements meant Provender Plants now has to secure phytosanitary certificates – plant health checks – before the plants can be shipped to it, and how the costs would run into hundreds of thousands of pounds and frequently add a full week to delivery times. He added that the company was braced for spiralling costs and significant delays to what are perishable goods.
And that was the good news, because from 30 April these products, already requiring a phytosanitary certificate, will have additionally been subject to planned physical health checks at a series of new border posts in the UK. The government claims the new system will reduce the risk of importing plant pests and diseases while not hurting trade or piling even more costs onto the consumer, but bosses in the plant industry are not so sure. They are fearful of widespread confusion, with new border posts unable to cope with the volume and nature of trade and new inspections.
This is partly because physical health checks are not confined to plants for planting but extend right across the animal and plant product spectrum to take in cut flowers, live animals, meat, dairy and all other food products of both animal and plant origin. In the run-up to 30 April, there was a blitzkrieg of stories in the national press and, to their credit, plants for planting received their fair share of publicity.
Costs are sure to rise due to the ‘Common User Charge’ which, for goods travelling through the Port of Dover and the Channel Tunnel and inspected at the government-run Sevington inland border control post in Kent, will incur a charge set at £29 per type of product, with a £145 cap for mixed consignments. In this context it is still unclear whether a lorry-load of container-grown trees comprising a dozen different species will be levied a charge of £29 or £145.
However, when you add on other costs such as health certificates, port-health costs and admin charges it will clearly cost a lot more. The government has said the whole exercise would cost traders and importers a total of £330 million a year, but an Allianz Trade report puts the cost at £2 billion per year.
What’s more, there could be problems with availability in the future as companies, not wanting to bear the extra aggravation and costs, withdraw from importing products from Europe – something which apparently happened in the opposite direction when the EU imposed its border checks on UK goods back in 2021.
Whether or not the new border control posts will be able to cope with anticipated volumes is still up in the air, but for sure there is real doubt as to whether this new inspection regime will reduce the entry of harmful plant pests and diseases. Some scenarios suggest it could even make all sorts of things a whole lot worse. That’s because we are not talking about dried dog biscuits, but living plants which will deteriorate or even die during the anticipated delays.
Most of these plants will be container grown or have soil attached to the roots and there is no way soil can be checked rapidly, if practically at all, for the myriad of pests and diseases it can carry. It has become increasingly obvious that some of the alien pests and diseases hitting our trees over the last 20 years have entered as contaminants of soil rather than as active infestations or infections of the trees growing in the soil or with soil particles attached to the bare roots.
And there’s the rub, because as of 31 January, EU low-risk goods have been exempt from systematic controls at the border, so not requiring a phytosanitary certificate or pre-notification. Instead, they are subject to enhanced inland monitoring via surveillance at the most appropriate locations and times, and evidence-led visits to premises by plant health inspectors. Plus, from 30 April low-risk imports from non-EU countries have been removed from requiring phytosanitary certificates. Now it might be easy enough to classify a living plant as low risk on the basis of the species, but the soil in which it grows could be carrying a whole range of pests and pathogens totally unrelated to the plant roots it surrounds.
Funnelling volumes of living plant material through one relatively small and highly condensed border post runs the risk of cross contamination, pest transfer and disease transmission unless health and hygiene procedures are meticulous, down to the last dirty fingernail. Living plants under extra stress from moisture deficit, elevated temperature, illumination deficit and heavy handling during physical inspection will be increasingly susceptible to infection by microbial pathogens and pest attack by insects.
At the time of writing, questions still persisted about the extent of inspection, including the proportion of consignments of high- and medium-risk plants to be inspected.
The wider public could be forgiven for wondering why it has taken so long for the government to introduce these controls, when the EU has had its checks in place for the past three years.
The UK government initially intended a swift introduction, but just as swiftly backtracked, postponing five times since 2021 and leaving EU exporters of animal and plant products free to send them to the UK without checks. The first three delays were essentially because the border control posts were not complete and, in some cases, not even started. The fourth was over fears it would add extra costs to household bills and the fifth down to concerns over business readiness and inflation. In a more recent twist, a DEFRA presentation seen by the Financial Times during April 2024 indicated a sixth postponement on the cards, with government fearing that if the new border measures were implemented as planned, big delays could follow.
To mitigate this, the rate of checks would be initially ‘set to zero for all commodity groups’ – essentially switching off large parts of the risk management system, in what it called a ‘phased implementation approach’.
In typical bullish style, the UK government says it is setting out a world-leading model (BTOM) for the import of sanitary and phytosanitary goods, including plants and plant products, underpinned by an intelligent approach to risk management. Whether or not it turns out to be a ‘world-leading’ model remains to be seen, but one thing for sure is that the UK is a world-leading ‘dumping ground’ for alien insect pests and pathogens.
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