The long-awaited Border Control Posts could lead to significant costs for nurseries and the landscaping trade, many of which are proving impossible to forecast

It has been delayed five times, but at the end of the month, the next and most significant stage of the Border Target Operating Model will come into force. 

As of 30 April, all plants being brought into the UK will need to do so via a Border Control Post (BCP), which the horticulture industry says is likely to spark price hikes, delays and potentially a lack of availability – though it is difficult to forecast exactly how bad these could be. 

“The tweaks that have happened since Brexit have been inconveniences to a degree and a bit more paperwork; but this is a fundamental change to the process,” says Richard McKenna, managing director of Provender Nurseries. 

The BCPs will be replacing the Place of Destination (PoD) system – a ‘temporary’ solution whilst the BCP model was being implemented, one which has been in place for the last three years, despite initially being touted as a six-month fix. Nurseries and landscaping sites could apply to become a PoD, meaning that plants could be sent directly to them and inspected on site, rather than at the border. But as of the end of this month, the PoD system will cease to exist and plants requiring inspection will be stopped at the border.  

“If they have been selected for inspection, the plants will not be able to leave the boundaries of the port, and the lorry must report to the Border Control Post,” explains Sally Cullimore, technical policy manager at the Horticultural Trades Association (HTA). “The only time they would be allowed to exit the port, if they were selected for inspection, is if they were going to a Control Point.” 

These Control Points are inland inspection facilities where Sanitary and Phytosanitary (SPS) checks can also be carried out, and a nursery can apply to become one, though this is not quite as straightforward as it sounds. 

Why are we switching to Border Control Posts? 

In one word, Brexit. When Britain left the European Union at the start of 2020, and in the absence of a plant health agreement or similar with the EU, it had to start abiding by World Trade Organization rules and began working towards introducing Border Control Posts, with an initial date set for the summer in 2021. The PoD system was temporarily put in place, though a series of delays have meant it has been in place far longer than intended.

Whilst UK nurseries and the landscaping trade have adjusted to using this system, there are downsides to it. “With the Place of Destination scheme, we’re currently on about a 40% inspection rate on plants that should be inspected all the time, so it’s not ideal,” says Cullimore. And whether you receive your inspection on site or not, you’ll still be charged a flat inspection rate of £32.15.  

Was the UK not biosecure before Brexit? 

Despite ‘Brexit’ and ‘biosecurity’ becoming somewhat synonymous to some, the UK had biosecurity measures already in place before we exited the European Union. Before December 2019, and ahead of full plant passporting coming in, there was a “simple process” with a fairly quick turnaround between placing an order and receiving it on site, says Cullimore. At the end of 2019, but prior to Brexit, everything had to have a plant passport for traceability purposes and for assurance that the supplier had carried out a plant health check. 

There were “national measures” too. For example, if part of the EU had a pest that wasn’t present in the UK, then national measures could be put in place requiring anybody importing at-risk plants to pre-notify and the plants would be inspected once they arrived at the nursery, or the UK could prohibit the at-risk plants from being imported. In other words, robust measures were available when necessary under EU plant health rules. This, if it were coupled with a robust voluntary scheme such as Plant Healthy and plant passporting, would “cover all bases,” says Cullimore.  

Once Brexit came into effect, the process became more complicated with a series of additional costs and extra resources around pre-notification. When the Border Control Post system starts on 30 April this year, there will be a “very complex process at the border that may or may not involve some significant costs,” with no checks taking place after the border. 

How likely is it that plants will be stopped for inspection? 

The Border Target Operating Model sets out three risk groups – low, medium and high – with plants for planting being considered high risk and therefore the majority at a 100% inspection rate. Both medium and high-risk plants require phytosanitary, or health, certificates before they are allowed to enter the UK from the EU.

If it’s non-woody and packed and ready for the final user – which can also apply to landscaping as well as retail – then there is a lower inspection rate of 30% as they are deemed to be less risky, explains Cullimore.

To avoid being overly optimistic, expect plants to be inspected, though the government says it will be taking a ‘pragmatic approach’ to begin with. This could mean that if there were a long queue of lorries waiting to be inspected, then the waiting lorries would be released to cope.

What does this change mean for nurseries? 

It’s another hit to the already shallow pockets of UK nurseries. Costs for simply running a nursery have increased dramatically in recent years, many occurring since Brexit, such as raw material costs (like plastic), energy prices, wage bills, transitioning to peat free and the initial costs of Brexit. All compounded by the lingering impacts of covid-19 and the surge in demand caused by the pandemic – all of which have already impacted plant prices over the last four years or so. Unfortunately for nurseries, it’s difficult to predict how much switching to BCPs will impact them, but it’s bound to take its toll.

All lorries passing through the government’s new £147m Border Control Post at Sevington near Dover – and all government run BCPs, should more be built in the future – will need to pay a Common User Charge (CUC). This covers the cost of unloading and reloading the lorries, as the Animal Plant Health Agency is not legally allowed on the back of the trucks, and all consignments will need to pay the charge regardless of whether they are inspected or not.  

The CUC was recently revealed to be £29 per commodity line for all medium and high-risk goods, though there will be a maximum charge of £145, so nurseries will be paying for up to five commodity lines per lorry. That’s in addition to the plant health inspection fees. 

“Our sector typically has multiple commodity lines per consignment, meaning, in reality, businesses in our sector will be paying the £145 maximum charge. This will be a huge new cost burden for many, hitting SMEs hard, particularly those using groupage,” says HTA chairman James Barnes. 

This is a known cost at least. “What you can’t possibly forecast is how long the driver will be waiting for that inspection at Sevington,” says Cullimore. “So, everything arriving at Sevington will be on a lorry, and it will be driven by a driver who will have to wait for that inspection to take place, and we have no way of knowing how long they’ll be waiting. So, there will be charges for that driver’s time which are utterly unforecastable. We can forecast the CUC, we can forecast the plant health inspection fee, but we can’t forecast the waiting times.”  

Delays could also reduce truck capacity, pushing up haulage prices, and might even spark hauliers to no longer bother with the UK market, warns Stuart Tickner, Provender Nurseries’ head of biosecurity and production.  

To limit the impact, Provender Nurseries has successfully applied to become a Control Point, converting a building for this purpose. “We should be able to bring in plants quicker and more easily, hopefully with less damage, and in a timeline that we can control within reason,” says McKenna. 

“There will still be some minor increases in cost, though. We have to cover the paperwork and offloading, for instance, and we still have to have the plants inspected here,” adds Tickner. And that’s on top of the time, money and infrastructure required to build a CP, plus the ongoing costs to run such a facility. 

“The Control Points have to be the same as Border Control Posts, and most nurseries are not commercialising them; it’s just so that they can retain control of their own plants,” says Cullimore. Whilst some Control Points are run by freight forwarding companies or customs agents whose sole purpose is importing products, a nursery’s purpose is to grow and sell plants. “That’s where the differentiation lies, but we haven’t seen that differentiation in the designation process, or an acknowledgement that nurseries are perhaps different and need help to overcome barriers to having a Control Point, such as cost and planning restrictions.”

Plants Limited applied to become a Control Point but was turned down at the first stage. “After doing further research on the size of the building involved to comply, we wouldn’t even start to get planning permission at our site in Chobham,” says director Rachel Blakey.

The pre-notification system for importing plants is also switching over, from PEACH to IPAFFS. And IPAFFS hasn’t been without its teething problems, leading many to revert back to using PEACH – something that won’t be an option once PEACH is turned off this month.

What could the knock-on effect be for landscapers and garden designers? 

Put simply, if nurseries don’t know how the price of plants could be impacted, then landscapers and garden designers don’t know either and it could impact how they quote for future work – and could even impact existing jobs. 

“There are landscapers who have quoted work months ago on a fixed price supply, but some of the nurseries supplying them might not know that the PoD system is no longer going to exist and that they are going to go to a BCP, that there are going to be offloading and inspection costs. It could have a significant effect on some pricing models,” says McKenna. 

With the PoD system coming to an end, if landscapers are importing directly from the continent, they will be unable to have plants inspected on site on arrival if they have registered as a PoD; inspections will now need to take place at the border before reaching the site. If trucks are delayed and stock is sitting in the back of a lorry at a BCP in 30-degree heat, becoming dry and damaged, then there could be more wastage too. 

Availability might also be impacted because of the CUC being charged by commodity line. Some nurseries might try to keep below the maximum £145 charge by ordering more of the same rather than small amounts of multiple lines, and landscapers might find it costly to put in small orders for numerous products from the continent. And the solution is not to ‘buy British’, says Tickner. “Many popular plant lines are produced in Europe and sent over, so they still need to be imported somewhere along the line.” 

To ensure traceability, McKenna urges landscapers to start keeping records of where plants are being planted, if they have not done so already. Rather than the previous system where the plant passport used to be on the paperwork, it has since changed to be on the plant, so landscapers should consider writing the client’s details at the top of the invoice or using another method to keep track. 

“They should know which garden they have gone into in case there was ever a recall on those plants or if APHA wanted to inspect them. If they turn up at your door and ask where the plants are and you don’t know, APHA can take further action.” 

Wood packaging material should be checked by landscapers too, says Tickner. It should be stamped as having met ISPM15 international standards to show it has been treated. “It holds just as much risk as living plants do. The outbreak of Asian longhorn beetle was brought in on wooden pallets for an Indian sandstone supplier in Kent. It cost something like £30m and took eight years to eradicate; they had to fell 2,200 trees in public spaces and privately owned gardens.” 

Can anything help the transition? 

Once the ‘pragmatic approach’ has come to an end and the creases are ironed out, inspection rates are likely to go up as a result of the Border Control Posts and IPAFFS, which should improve the UK’s biosecurity, says Tickner. But the unknown costs are an ongoing concern. “We’re very good at adapting; we can adapt overnight – if we know what we’re adapting to.” 

Associations such as the HTA are therefore calling for a transition period to BCPs, one where the PoD system remains in place for a period of adjustment – and that’s not just a chance for nurseries and the landscaping trade to adjust, but also for those working at BCPs to become better equipped at handling plants.

“Loading, offloading, and handling all different plant types and trees is a very skilled process,” says Adam Whitehouse, head of operations at Robin Tacchi Plant. “It can take years to train a nursery operator to achieve the skill and experience required to safely and efficiently handle the full range of plants coming through the BCPs.” 

There can be up to 500 different species and genus on a lorry, which have to be found, inspected, repackaged, and reloaded in the right order as quickly and efficiently as possible, says Cullimore. “The BCPs were not designed to cope with that sort of product. We are importing plants in all different types of packaging and the way these lorries are loaded is like an art form. BCPs are not set up to cope with that type of unloading and reloading.” 

As a result, there are various risks, from cross contamination to there being no temperature control in the turnout area, which is often too small in the first place.  

Cullimore suggests running a restricted version of the PoD system – so, not necessarily allowing all 7,000 PODs to continue, as the APHA would struggle to cope, but to limit this number based on certain criteria – alongside the BCPs for at least a year. This would allow for a whole season’s worth of data on IPAFFS and a chance for the BCPs to perhaps be retrofitted to better handle plants. It would also mean that, should the government’s ‘pragmatic approach’ lead to lorries carrying medium or high-risk plants being released without inspection, they could be on their way to a PoD and perhaps face inspection there instead.  

Is there a silver lining? 

The upcoming changes and resulting media coverage highlight the need for biosecurity in people’s minds, says Cullimore. “If I could give a message out to people it would be to be very aware of your supply chain and know where you’re getting your plants from. The plant health inspections are not quality control; they are just checking representative samples to make sure they are what they say they are and that they don’t have what the phytosanitary certificate says they don’t have. We say 100% inspection rate, but they don’t inspect all the plants; they just take one and have a look. So, know who is supplying your plants and what their biosecurity processes are. Be plant health aware.” 

Cullimore adds that a nursery with a Plant Healthy certificate or an Ornamental Horticulture Assurance Scheme certificate has been audited to a certain standard and has therefore done their due diligence. “I can’t stress enough how much a voluntary accreditation scheme is as best a guarantee of biosecurity that you can get.” 

The government’s ‘pragmatic approach’ might hide the impact of the BCP system for the first few months. But as soon as the inspection rate ramps up to 100%, there is bound to be a hit on plant prices and availability – and it won’t just be nurseries taking it on the chin. Landscapers and garden designers need to prepare too. As Tickner says, “it really will affect the horticultural industry as a whole.”