Q.43 A question in respect of earlier slot from DEFRA. Is there any update on levels of SPS checks on different
A. The level of physical and identity checks from January 2022 will be proportionate and based on assessments of biosecurity and public health risks. POAO, germinal products and ABP imported from the EU will be subject to a minimum level of checks. Some commodities, such as shellfish and certain ABPs, will be subject to higher minimum check levels. PHAs have been informed of the minimum % levels to be checked.
Q.42 We understand that the 1 Jan 2022 date is set. There will be issues with NPPOs not open to provide the
necessary phytos for pre-notification. This was an issue previously over holiday period, will the UK provide an easement for UK importers of plants/plant products? Appreciate that this is a policy question.
A. There are currently no plans in place to implement an easement for phytosanitary certificates following 1 January 2022. However, the UK government remains focused on delivering electronic certification (‘ePhyto’) as a solution for both the import and export of plants and plant products in the long term. This is DEFRA's priority for the next stage of development following the implementation of the new IT services in 2021 and will eliminate the need for paper certificates. Our intention is to have this delivered for imports by the end of 2021.
Q.41 Will the operational testing consider looking at more difficult issues, such as mixed up multiple consignments not
palletised (adding delays in examination times) and will it also consider the process when something is found to be
wrong, what happens for goods not released?
A. The BPDG Ops Testing team are currently developing this level of detail into our test scenarios and aim to incorporate as many complexities, such as groupage and mixed loads, as possible into the testing programme this year.
Q.40 Are the original end to end testing locations / commodities that were planned to take place on the
original timetable of implementation going to remain the same?
A. The programme has expanded following the delay of import checks until Jan 2022. We will test as much as we reasonably can in the time available.
Q.39 Will there be an API option to complete IPAFFS dec?
A. The IMP notifications in October will not have any API-functionality, Defra have accelerated the development of a trader API and cloning in advance of January to ease the burden on traders.
Q.38 Can understand wanting all the right systems and policies in place to test but the later it is, the less time industry has
to adapt its staffing and processes to implement.
A. We recognise this challenge and continually work to review the constraints and dependencies for operational test dates. The BPDG Operational Testing team are tracking these dependencies to ensure we deliver tests and provide feedback to give as much time as is feasibly possible for industry to adapt.
Q.37 Will your pre-testing include working with Spanish authorities on plants/plant products?
A. Yes, the BPDG Op Testing team have good engagement with Spanish officials. We intend to work closely with the Spanish authorities and ports in terms of planning and execution of tests via Spanish routes.
Q.36 Based on the current information available - is the operational testing scalable to the volumes predicted?
A. Due to the nature of live operational tests - moving actual goods on consignments through UK ports to test the infrastructure, IT, customs and regulatory import processes - it is not possible to scale the tests for volume. BPDG do record the duration of each process step in the tests we run so we can feed real data into government data models for analysis/scaling.
Q.35 Will the IPAFFS tests in October also test groupage consignment use of certification e.g. multiple pick-up points and that that will definitely work for Oct 1st?
A. The intention is to continue running dedicated exercises to validate key elements of the EU to GB groupage and mixed load models under consideration and develop complementary guidance, alongside a series of planned trader readiness sessions ahead of introduction of imports controls.
Q.34 How many live tests have been undertaken - such as the example given from Holland?
A. 10 live operational tests in total were completed last year. Operational testing for import controls is taking a rolling programme approach this time and started in mid-July. A desktop test of the IPAFFS pre-notification has completed so far.