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Webinar Recording

The Government has decided to delay the remaining import controls on EU goods; these will not be introduced from July 2022. The below guidance is being reviewed. To find out more please click hereA Q&A is also available here.

Border Control Posts and Control Points Webinar

Updated: September 2021

 

Defra Plant Health hosted a stakeholder webinar to talk through Border Control Posts and Control Points and took questions from attendees.

Watch the webinar presentation

Download the webinar presentation slides

(The information in the above links was correct at the time of the webinar. Since 14 September, the Government has set out a pragmatic new timetable for introducing full import controls for goods being imported from the EU to the UK, which affects some of the information shared in the webinar. For the latest on import phasing dates please see here.)

Questions and Answers from the webinar

 

Subject:

 

Border Control Posts

 

Do you think the proposed BCP's for Kent which government are overseeing will be in operation by July 2022?

HM Government is investing an unprecedented £705 million package of investment for border infrastructure, staff and technology in Great Britain (GB), to ensure our border systems operate effectively and maintain efficient border flow.

The government is progressing with construction of new inland facilities in Kent. These include a new BCP in Sevington to accommodate SPS checks for plants, plant products and live animals arriving at Eurotunnel and Port of Dover; as well as products of animal origin (POAO) arriving through Eurotunnel; a BCP in Dover for local POAO; and another site in Kent for live animals. 

The intention is to have BCP facilities operational in time for the introduction of physical inspections of POAO and high priority plants which come into effect on 1 July 2022. We are working at pace with our partners to deliver this.

 

What are the BCP fees?

Other than the BCPs run by the UK Government (e.g. Sevington), BCP usage fees (as distinct from plant health inspection fees) are set by the commercial operators of those facilities. Defra has no control over the level of those fees. We continue to engage with commercial BCP operators and will encourage publication of BCP usage fees in a transparent manner as soon as possible.

 

Who will be responsible for possible damages to the plants?

Experience with non-EU imports, which have been subject to systematic import checks for many years, is that instances of damaged consignments are incredibly rare. Handling and the removal of consignments from lorries is carried out by operators at the BCPs. Plant health inspectors are not responsible for removing goods and are instructed to wait until a consignment has been moved to an inspection area to carry out checks.

In the unlikely event that any plants are damaged, e.g. as a consequence of sampling for the presence of quarantine pest or disease, then resulting losses are not compensated for by the plant health authorities or Defra.  

 

Please can APHA share their high-risk consignment profiles?

For the list of high-priority plant and plant products, please visit the Plant Health Portal.

For further guidance on the frequency of physical checks and the prioritisation of high-priority imports, as well as other importing guidance please visit the Plant Health Portal.

 

When recruiting staff for BCP's what experience are they expected to have in order to carry out the checks? Surely there is not enough time to recruit and train them?

Due to COVID-19, we are running an online training program which allows us to efficiently train new recruits at different locations across the country. As part of that training, PHSIs are required to learn about all aspects of plant health, in addition to safety and handling processes.

Furthermore, plant health inspectors are not permitted to work without supervision from an established inspector until they are trained and assessed as being competent by an appropriately senior inspector. This allows for a consistent and high standard of import inspections across England and Wales, for both EU and non-EU goods. This training, assessment and the ongoing re-evaluation of plant health staff is accredited under the ISO 17020 Standard which includes also external audits from the UK Accreditation Service.

All other members of staff working within a BCP facility are trained to meet standard operating procedures, ensuring inspections are undertaken safely, efficiently, and accurately. Where appropriate, staff will be trained to meet Sanitary and Phytosanitary (SPS) processes and procedures and identify cases of non-compliance.

 

The plants we bring in from France (lettuce and cauliflower for seed production) come in vans through Eurotunnel. Our sites are 1 hour’s drive from the tunnel. Will the vans have to drive to a border control post after exiting the tunnel before bringing the plants to our site? Will there be a BCP at Eurotunnel Folkestone terminal?

Consignments containing regulated plants and plant products will need to be checked at an approved inspection facility (Border Control Post, Inspection Centre or Control Point) from 1 July 2022. Consignments will be selected for inspection based on risk as described infrequency of physical checks and the prioritisation of high-priority imports. 

While there is not a BCP site designated at Folkestone, there are other BCPs in close proximity. For BCP and CP locations please visit gov.uk. Further information on BCPs, CPs, and an interactive map can be found on the Plant Health Portal.

 

Will there be any changes to the list of high-priority plants and plant products as the new rules comes into effect? Is there already a list of 'high risk' countries of origin?

No. No changes are intended to be made to the list of high-priority plants and plant products. A full and final list of high-priority plants and plant products can be found on gov.uk and the Plant Health Portal.

Interception and non-compliance data of imports from EU and non-EU countries are collected by Defra and published on the Plant Health Portal. New reports are uploaded routinely, and in turn the ‘Alert List’ is updated accordingly.

 

Is a member of staff from the company required to attend a BCP during an inspection?

A member of staff does not need to wait with the consignment before the inspector arrives. However, a staff member must be available when the inspector arrives to facilitate inspection and to accompany the inspector to the inspection point.

The composition of the consignment must be maintained until an inspector confirms whether the whole consignment needs to be made available for inspection, or if they only need access to certain parts of the consignment.

 

Is there a contingency keeping the PODs in operation?

The PoD scheme was developed and introduced as part of post-transition period planning, to ensure trade was not disrupted at the GB border once the transition period ended. It was introduced in conjunction with the EU-GB phased plant import regime, which introduces the official controls on EU regulated goods in stages since 1 January 2021 to help business adapt to the changes.

Additionally, the government issued a revised timetable for the introduction of import controls in March 2021. This revised timetable was introduced in order to minimise the impacts and disruption caused by COVID-19 and allow businesses further time to prepare for any upcoming changes.

 

163 locations at BCPs? is this the total number of inspections that can take place at one time ?

No, each BCP has multiple bays available for inspections of multiple vehicles to take place, meaning BCP sites can handle multiple consignments at any one time.

 

Will facilities be BRC accredited? This could cause integrity issues in terms of handling.

BRC accreditation is a commercial decision and not part of the Official Control Regulation (OCR) designation requirements. Port operators and other port staff are trained to handle foodstuffs to avoid damage and cross-contamination.

 

If you hold plants on suspicion there is a problem then it is determined nothing is wrong who stands the cost of shipping the items that are on hold?

Not all plants are selected for diagnostic testing or taken off the lorry for a physical inspection, only those that are identified for a visual examination or diagnostic testing will be taken off the lorry. Even if a specific species or genus is flagged for an inspection, only a representative sample of those plants or products will be removed.

In the unlikely event that any plants are damaged, e.g. as a consequence of sampling for the presence of quarantine pest or disease, then resulting losses are not compensated for by the plant health authorities or Defra. 

 

Consignments arrive with recent check and hence Phyto Cert issued - is it necessary for these checks?

Following the introduction of plant health controls on high-priority plants and plant products imported from the EU to GB on 1 January 2021, PHSI in England and Wales have recorded numerous cases of interceptions of harmful organisms and non-compliance. These cases have all been identified as a result of physical and identity checks at PoDs,  demonstrating the biosecurity value of the new controls.

For further details on the interception and non-compliance data for both EU and non-EU countries, please visit the Plant Health Portal.

 

What assurances can you give regarding deterioration of small plants and or bare rooted plants due to prevailing weather, ie frost wind sun etc, some of our plants dry out in less than an hour on a sunny day

Designated plant specific BCP facilities must provide temperature-controlled zones, dedicated inspection and biosecure detention areas; and extensive cleaning protocols to avoid the spread of harmful pests and diseases. If a plant needs to be in a temperature-controlled room, it will be immediately moved to one so that it is in the appropriate environment until it can be reloaded on the lorry.

 

Is there a possibility to get a preferred position (lower control %) when a company can prove good practice / no problems found. How would I apply for it?

GB's plant health regime is risk-based, and the history of compliance of specific trades (where the trade is the combination of a specific commodity from a specific origin), is a significant factor in determining biosecurity risk. Consequently, trades with a proven track record of compliance and meeting prescribed eligibility criteria may be subject to a reduced frequency or intensity of checks.

The same rationale does not currently apply to traders.

For a list of those goods please visit the Plant Health Portal.

 

I'm worried that in a consignment of bare root plants we may only have say 50 Quercus - how are you ever going to find them?

Without it being possible to cover every scenario, any individual consignment can be made up of as many commodities as the importer chooses. If a consignment of plants for planting has a wide range of genera, an import inspector would only choose 10 genera to inspect. Import inspectors will take a pragmatic approach to this selection, alongside assessing the risks for each genus.

 

What safeguards are there to ensure BCPs are operating properly? Can Government step in if issues are found?

Once a site has been approved to operate as a BCP/ CP, requirements must continue to be adhered to in order to maintain their BCP/CP status. 

The Competent Authority will withdraw or suspend the BCP/CP designation when:

  • the BCP/CP no longer complies with the minimum requirements
  • its activities pose a risk to public, animal and plant health

Yearly BCP/CP audits are conducted to confirm compliance. Where APHA detect non-compliances, audits will be conducted more frequently.

BCPs may also be subject to Border Force audits to confirm compliance to customs conditions.

 

 

SLAs and delays

 

Do the BCP's operate 24/7? eg. do the 4 hour windows apply during all hours of the day?

Each BCP will have their own operating hours and SLAs that are based on trade levels and demand. These will vary by site and region across England and Wales and will be published shortly.

APHA will inspect consignments at registered places of destination 7 days a week, 7am to 7pm. For more information on contact details and operational hours, please visit gov.uk.

APHA and the Forestry Commission will inspect your consignments during working hours. If goods arrive outside of the working hours, then APHA and the Forestry Commission may hold goods overnight until they can be physically inspected.

 

My concern is not around APHA's SLAs and inspections causing delays but around delays caused by volumes of traffic transiting through the port. Will the ports be given guidance around the time they take to get plants to be inspected to the APHA inspectors and what is deemed acceptable?

APHA works closely with BCP operators to facilitate the inspection process and BCP operators are aware of inspection requirements. They also have to implement detailed procedures to demonstrate their ability to present goods for inspection as part of their operation.

 

What Service Level (expectation) will be in place (used control time, between truck arrival and departure)?

APHA are reviewing service level agreements (SLAs) for completion of inspections at BCPs. APHA service levels apply once the goods are available for inspection and this may vary by site and region across England and Wales.

 

How much time will be planned for each inspection?

Inspection times vary depending on commodity. APHA inspects a sample of each consignment and will complete inspections in line with their service standards. APHA will inform the applicant if they expect any significant delays.

 

There is a shortage of hauliers, if they find that there are delays at the border they are unlikely to want to haul plants. What do you anticipate will be the time scale for delays at BCP?

APHA have extensive experience of import inspections and work closely with BCP operators to ensure inspections are completed efficiently. This includes procedures to manage inspection volumes effectively during peak times to avoid delays. Inspection times may vary depending on the commodity, however if there are no biosecurity concerns following the inspection, the consignment is released immediately for onward transportation.

 

Unloading and reloading

 

Are plants always taken off the lorry at BCPs and CPs?

No, not all plants are unloaded, only those that are flagged for an inspection will be removed from the vehicle. In the case a specific species or genus is selected for an inspection, only a representative sample of those plants or products will be removed for checks.

If a consignment is not selected for an inspection and has cleared customs, the driver is free to move to the final destination and no plants would have been removed.

 

How will you be able to inspect plants in the middle of my 6ft high pallet of bare root hedge plants without drying them out?

If an inspection cannot take place at the BCP due to special circumstances, the plant health authorities may choose to move the goods to an alternative facility under statutory controls. This will enable reliable plant health checks to be performed in a way which permits safe handling of the plants/trees. 

 

Your reference for palletising products this does not take into account the lorries that are loose loaded. Who will be responsible for the costs of reloading and any damages that might occur?

Experience with non-EU imports, which have been subject to systematic import checks for many years, is that instances of damaged consignments are incredibly rare. Handling and the removal of consignments from lorries is carried out by operators at the BCPs. Plant health inspectors are not responsible for removing goods and are instructed to wait until a consignment has been moved to an inspection area to carry out checks. In the unlikely event that any plants are damaged, e.g. as a consequence of sampling for the presence of quarantine pest or disease, then resulting losses are not compensated for by the plant health authorities or Defra. 

 

Large trees do not come on pallets or cages what experience will both inspectors and stevedores have in handling and inspecting without damage and if a £3,000 tree is damaged beyond sale will Defra compensate for this?

If an inspection cannot take place at the BCP due to special circumstances, the plant health authorities may choose to move the goods to an alternative facility under statutory controls. This will enable reliable plant health checks to be performed in a way which permits safe handling of the plants/trees. 

In the unlikely event that any plants are damaged, e.g. as a consequence of unloading a lorry for checks, then resulting losses are not compensated for by the plant health authorities or Defra. 

 

How will hauliers know how to pack the lorries efficiently for inspections they load in order of efficient collection? Are you expecting them to repack before crossing the channel?

For guidance on best practices for packing a lorry more efficiently, please visit this page on the Plant Health Portal. This guidance is not mandatory, we understand that not everyone can follow these suggestions.

 

Where a trailer contains loose loaded trees/plants for several different destinations, how will you ensure that everything is loaded back in the same order and separated properly

If an inspection cannot take place at the BCP due to special circumstances, the plant health authorities may choose to move the goods to an alternative facility under statutory controls. This will enable reliable plant health checks to be performed in a way which permits safe handling of the plants/trees. 

 

A tightly packed lorry of Italian hardy plants loaded by specialists in Italy, if unloaded, will unlikely fit back on the same lorry - how will this be accounted for?

Where it is at all practicable, consignments selected for physical inspection will be unloaded and inspected at the BCP. However, under exceptional circumstances, loads which present significant handling difficulties can, at the discretion of the Import inspector, be moved inland under statutory controls for the inspection to be completed. Importers should be aware that consignments moved inland, that are subsequently found to be infested with a quarantine pest or disease, will potentially be subject to destruction as re-export will not be an option since APHA would be unable to certify pest freedom to facilitate export to another country.

 

Our consignments from Italy take 4 of our experienced staff 5 hours to unload - are you aware of the time involved in unloading and packing?

Yes, PHSIs and APHA colleagues are aware of the time it takes to unload and reload lorries. BCP operators are responsible for unloading and reloading consignments on lorries. APHA will not inspect goods until they are moved to an inspection area. However, BCP operators have extensive experience with non-EU imports, which have been subject to systematic import checks for many years and required unloading and reloading.

 

What happens if the exporting nursery does not get all the items on the truck as planned and the lorry arriving in GB does not have all the goods on it as planned on paperwork and Phyto as they are done in advance to loading at times?

A phytosanitary certificate should show the maximum number of items being exported. It is permissible for the volume that is stated on the PC to be greater than that which ultimately arrives. However, an accurate packing list should also be submitted with the application. Please note that if the PC and packing list vary it could prompt investigation by the plant health authorities.

 

Control Points

 

What are the requirements it takes to become a Control Point? Is there a document outlining what is needed to become a Control Point?

There are certain minimum requirements in place that must be met for a premise to be designated as a CP. These requirements are more stringent than for a Place of Destination (PoD), which are a temporary arrangement whilst permanent infrastructure (BCPs) are put in place. Because CPs perform the same function as a BCP, enabling checks before goods enter into free circulation, they must be customs authorised as a temporary storage facility and comply with the conditions for this type of customs authorisation. Consignments that are transported to a CP must enter via a port with a BCP designated to handle plants.

CPs must ensure Plant Health and Seed Inspectors (PHSI) can perform the necessary official controls in a safe and bio-secure manner and that the goods remain under customs supervision until plant health checks have been completed.

To be designated as a CP, the facility must meet the same minimum requirements as a BCP. These minimum requirements include:

  • a sufficient number of suitably qualified staff to oversee operations
  • premises and facilities appropriate to the nature of volume of consignments
  • equipment to enable the performance of checks, including access to WIFI and import IT systems.
  • arrangements in place to prevent risks of cross contamination and compliance with biosecurity standards

The full requirements are set out in Article 64(3) of Regulation (EU) 2017/625 on official controls (OCR) legislation.

To ensure appropriate biosecurity standards are met, CPs must also provide for:

  • area for unloading with appropriate cover
  • inspection rooms/areas
  • storage rooms/areas
  • washing facilities e.g. toilets/sinks

These requirements are set out in Commission Implementing Regulation (EU)2019/1014.

For more information, please visit gov.uk.

 

Is it just plants that can be inspected at CPs?

Plants or plant products, including high-priority plants and high-risk food and feed of non-animal origin (HRFNAO) may be inspected at CPs designated for these commodities.

 

Is there a limit to the amount of CPs that will be approved?

In the OCR legislation, there is no limit to the maximum volumes a CP can handle. However, CPs must have the appropriate facilities to manage the volumes of goods they are forecasting.

It is also necessary that there is sufficient service demand at a prospective CP to make them operationally viable. This will be assessed based on factors including the likely number of checks which are to be performed at the prospective facility and of which commodities. It is not possible to set precise thresholds given the range of different factors which will be taken into consideration.

 

What timeframe is set for the assessment for a new CP from begin to end?

Defra coordinates directly with HMRC, Border Force and other relevant agencies in order to assess applications. The application review depends on several factors and the total time for designations varies depending on the nature of the application.

Operators also need to allow for time to adapt their facilities to meet the CP infrastructure requirements such as inspection and chilled storage areas.

For businesses intending to be designated as a CP before 1 July 2022, Defra recommends you complete and email an EOI as soon as possible. For more information on the designation process and CPs requirements, please visit the plant health portal.

 

Can the control point be at the place of business?

Yes, as long so long as the minimum requirements are met.

 

Can an individual nursery be appointed as a control Point for their own goods alone?

Yes, an individual nursey can apply to be a CP for their own goods alone.

Any business can apply to become a CP, but there are eligibility criteria which must be met. CPs must meet the same minimum requirements as BCPs to ensure that they afford the same biosecurity safeguards and enable effective Sanitary and Phytosanitary (SPS) checks to be performed. Consequently, they must be customs authorised as a temporary storage facility and meet the same minimum requirements as a BCP in terms of facilities and resource to facilitate inspections.

Prospective applicants are advised to familiarise themselves with the process and conditions for customs authorisation.

If your business obtains CP status and another business requests to have goods delivered to your CP for inspection, it is at your business’s discretion to grant approval to anyone wishing to use your facility. Defra will not be involved in this process, including overseeing contracts -- it is a commercial arrangement. Businesses must first consider and ensure their CP is able to cope with the additional volume if they authorise the use of their facilities to other businesses.

 

For plant products that will not require stringent temperature control, such as seeds, is there an exemption to the temperature control requirement element at a CP?

Article 3(1)(c) of R. 2019/1014 states that facilities must have:  “…storage areas or storage rooms, including rooms for cold storage where this is appropriate to the category of goods for which the border control post has been designated”.

Therefore, cold storage is only needed if it’s appropriate for the categories of goods CPs have been designated to handle.

 

What hours will CPs work to? If consignments arrive at early hours in the morning and inspectors aren't available, will consignments be held overnight?

APHA service hours for CPs are currently under review to ensure inspections can be completed efficiently.

APHA usually complete inspections on the day the consignment arrives. Delays mainly occur because of incorrect arrival times given on applications or interruptions to transport schedules. Consignments will be held overnight if they are considered high-risk and the inspection could not be completed on the day of arrival. 

 

IT Systems

 

When will IPAFFS actually be fully functional?

IPAFFS is currently being used by a small number of ‘Early Adopters’ who are testing and feeding back on the service. There will be a phased transition period to the new service, IPAFFS, starting from summer 2021 to allow time for business to familiarise themselves with the new services. We are encouraging traders to register with the current services, PEACH for imports and eDomero for exports, until directed to transition to the new services. Further guidance and support will be offered to traders before, during, and after the transition.

 

Does the 4 hour window for PEACH uploads before arrival in the port still apply from 1 January? And if so, is there a guarantee that all applications will be cleared / assigned for inspection before the end of that 4 hour window?

Yes. Pre-notification via PEACH/IPAFFS is and will continue to be required 4 working hours prior to arrival in GB for RoRo and air freight, or 1 working day for all other methods of transport.

 

Are the applications in IPAFFS per truck or per consignment? And will all the consignments in the truck be inspected if they come from different suppliers? (groupage loads)

Applications are per consignment in IPAFFS. Consignments will be inspected on a risk basis so not all consignments on one load will necessarily be subject to checks.

It is the responsibility of the plant health service in the exporting country to determine the scope of the phytosanitary certificate (PC), but it is common practice for a PC to cover more than one product. A pre-notification is needed for each phytosanitary certificate issued. If the truck contains multiple consignments each with their own PC, then in turn each consignment requires its own pre-notification.

Not all consignments on a truck may be flagged for inspection, only those that are flagged for an inspection will be removed from the vehicle. In the case a specific species or genus is flagged for an inspection, only a few plants or products will be removed.

If a consignment is not flagged for an inspection and has cleared customs, the driver is free to move to the final destination and no plants would have been removed.

 

Will the bulk upload functionality of IPAFFS be available in good enough time to allow importing businesses to become fully accustomed to it prior to BCP introduction?

In conjunction with stakeholders, we are continuing to develop the ‘bulk upload’ solution. Once a solution is in place, we will invite all traders to transition from PEACH to IPAFFS over a period of weeks.

The Early Adopters are testing IPAFFS in its current form, including the ‘multi-line commodity’ functionality. This increases the number of commodity lines from a maximum of four lines - currently available in PEACH- to up to 50 lines. 

We are planning engagement sessions with businesses involved with importing plants and/or plant products from the EU. We will be providing videos and user guidance along with guidance for users on registering for the new service. We will provide videos and user guides and guidance on the process of raising a notification for import agents and those responsible for the load, as well as decision process for BCPs and Inspectors. We will be holding webinars for new users to give additional demo of the new service and allowing Q&A sessions with Subject Matter Experts. 

EU importers of live animals and germinal products are already expected to notify on IPAFFS and have had the opportunity to attend training webinar sessions previously. We will be offering another opportunity to attend these for refresher sessions before the end of the year.

 

The 4 hour window is unrealistic for PEACH because I dont have the CMR details sometimes until it arrives in our yard. We are registered as a POD.

Based on feedback from stakeholders we reviewed our pre-notification time for Roll on Roll off (RoRo) freight.

Importers must provide at least four working hours’ pre-notification for consignments arriving via air or RoRo freight, and at least one working day’s notification for consignments arriving by all other modes of transport.

Further information can be found on gov.uk.

However, this issue may be a technical error. For technical assistance using PEACH or HMI issues please visit the PEACH homepage or contact the Peach Help Desk on 0345 6073224.

 

Why is the seeds module on IPAFFS  not on private beta yet?

The system is live in an “early adopter” phase with a limited number of traders currently solely focussing on plants for planting. We will be opening the system up to the wider industry in the coming weeks.