Written evidence submitted by the Horticultural Trades Association (APH0157)

 

 

EFRA Select Committee Inquiry - Biosecurity at the border

Horticultural Trades ASSOCIATION (hTA) submission – 29 January 2025

 

 

Executive Summary

 

About the Horticultural Trades Association (HTA)

  1. The Horticultural Trades Association (HTA) over 1200 members across the entire supply chain of the UK’s environmental horticulture, green spaces and gardening industry. This includes garden centres, tree and plant growers, landscapers, manufacturers and service providers. Many of which import plant products from seeds to plug plants to mature tree loads. As such, we feel we are well placed to provide evidence to the EFRA Committee for this welcome inquiry on biosecurity at the border. The HTA would be pleased to engage further with this inquiry and others subsequently relating to the industry both in written and oral evidence as well as roundtable discussions or arranging committee visits.

 

About the Environmental Horticulture Sector

  1. Environmental horticulture is a sector of over 90% SMEs, many family-owned businesses, supporting 722,000 jobs, contributing £38 billion to GDP and delivering a near £8.4 billion in tax revenues. We are the original green industry and the gardens, green spaces and plants that we grow, nurture and maintain, underpin the UK’s environmental improvement plan targets, net-zero delivery and climate change mitigation.

 

  1. The sector has an ambition to grow, and data published in November 2024, sets out with the right conditions, by 2030, its value could be £51.3 billion and support 763,000 jobs. In addition to action on cross-border trade, the environmental horticulture seeks a holistic government horticulture strategy, inclusive of trade and borders, to be delivered that supports a growth in competitiveness and productivity of the UK sector. The inherent benefits of increasing the capacity of UK production to produce more plants and trees that can be grown in the UK are multiple, including economic benefits, biosecurity benefits and environmental benefits.

 

Biosecurity and risk-based approach

  1. Biosecurity is paramount to the sustainability of species, biodiversity, businesses and the wider sector. Across the sector there is expertise in plant health processes, biosecurity of operations, pests and diseases, with a wealth of knowledge, particularly among growers. Biosecurity applies not just to plants but also to people. It also has a multifaceted aspect where we may see pest and disease threaten ecosystems or crops and sometimes even humans, but also the inadvertent release of invasive non-native species also represent threats too.

 

  1. Ultimately any product that crosses borders poses a potential risk, albeit that European suppliers have an obligation to inspect the products before sending their products to their UK customers. Those items are then inspected again at the border. The industry has additionally seen in increase of pests and non-native species arrive in the UK via other means, for example the IPS beetle is thought to have crossed to the UK naturally, not via trade. Therefore, the trade in plant products, bulbs and seeds is not the sole biosecurity risk, and is indeed, on the whole, very safe, considering the volume of trade. The HTA and its members take the obligation of biosecurity very seriously; it is in our interests to do so. This can go and should go hand in hand with a business model for horticulture businesses to successfully operate whilst importing; and we request that Defra and the wider government supports this endeavour, rather than create further barriers to trade.

 

  1. The UK’s approach to biosecurity needs to be risk-based, expertly informed, pragmatic, and conducted in consultation with industry. While science is extremely and obviously important, business and industry has a leading role to play, with expert businesses properly recognised through earned recognition systems that actively seek to reward good practice. With plant health responsibilities devolved, yet pests and diseases not recognising boundaries, biosecurity should be completely multinational across GB. The 5 year Biosecurity Strategy launched in early 2024 by Defra needs to be better applied and supported across Government using a holistic, multi-agency approach.

 

Cross-border plant trade (commercial)

  1. The UK horticulture sector’s supply-chains are international and dependent on the swift and secure movement of sensitive plants and plant products, therefore how effectively the border operates directly impacts the success of UK environmental horticulture as businesses, the UK green spaces and choice for the UK’s 30 million gardeners. We seek greater recognition of UK environmental horticulture when developing and implementing trade/border related policies, and assessing or reviewing the UK-EU Trade and Co-operation Agreement (TCA) and resetting any UK-EU trade relationship.

 

  1. 79% of UK nurseries/growers rely on plant product imports (99% from the EU, largely via the Netherlands) for their operations. 90% of HTA grower and garden centre members import plant products. In 2023, imported plant material was worth over £770m to the UK horticultural sector, with 99% of that coming from the EU. This import value represents around half of the value of the UK production sector for trees, plants, seeds & bulbs, which totalled £1.54bn pa in 2022.

 

  1. At present underpinning UK production is the original plant material (or, motherstock) that is needed to produce young plants that in turn are grown to maturity. The bulk of motherstock, whether that be for seed, cutting or tissue culture production, is held outside of the UK and imports are critical. This is for mainly climatic reasons, so that motherstock can produce material out of the normal UK growing season, the breadth/variety of motherstock, and also can support biosecurity. It is also not held in the UK for historical economic reasons. Much young plant material the UK imports is produced in high health ‘elite’ and expert growing facilities producing material all year round in bulk, rather than on smaller local facilities, with different focus/specialisms, and in some cases, it may be more challenging to deliver consistent quality/health, lower volumes and greater impacts of climate or other factors.

 

  1. The Netherlands acts as a source and centralised EU hub for plant material, accounting for £635m worth of UK plant imports in 2023 (well over 80%), although material is also sourced direct from other EU Member States such as Germany, Belgium, Denmark, Italy and France. Half of all imported plant material (by value) flows through the East of England seaports of Harwich and Felixstowe, and the bulk of the rest via Hull, Immingham or short straits routes (i.e. Dover), mainly via ‘Roll-on Roll-off’ (RoRo) ferries both as accompanied and unaccompanied freight.

 

  1. Imported plant material is sensitive, perishable and crucial to the industry as much of it is ‘grown on’ by our domestic commercial nurseries to sell in the UK. Finished plants, seeds, bulbs and trees, which are ready for retail sale or planting in the wider landscape, are also imported. It is estimated 70% (by volume) of the imported material is retail-ready. Between 2019 and 2022 exports of plants, trees, seeds and bulbs to the EU fell by nearly 40% from a steady level circa £33 million to £18.2 million due to the restrictions brought in by not having a plant health agreement with the EU.

 

  1. Environmental horticulture businesses have been the most extensively impacted sector in terms of border checks and costs since EU-Exit was implemented. The sector has been subject to full plant health controls since 2021. Prior to leaving the EU, and at the time, without the current BTOM in place, national biosecurity measures existed.

 

  1. Plant and plant products imported from the EU to GB are categorised into high, medium and low risk categories. Plant health controls apply to imports of high and medium risk plants and plant products. All plants for planting, bulbs and some seeds are high-risk and theoretically subject to 100% checks. These goods have been subject to checks at Place of Destination (PoDs) and full documentary requirements since January 2021.

 

  1. The UK has a unique border with the EU when it comes to trading plants and plant products. There is no border anywhere else in the world that sees such a volume of plants and plant products traded between countries that do not have a form of SPS/plant health arrangement, recognition or agreement. Also, it is unique that those products arrive by sea. This makes it difficult when looking for a comparison or a model that works elsewhere in the world that achieves both a smooth and free flowing border and sustains proportionate biosecurity measures. It is clear that there is no ready-made solution to apply. This unique position must be understood when looking at developing and implementing policies and approaches.

 

  1. Biosecurity, borders and trade policy is complex and wide-ranging, and we note that this inquiry is very focused. The border or BTOM and how it operates is not the only issue relating to trade impacting the sector – for example Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) and the Windsor Framework which covers GB-Northern Ireland trade, also have different implications for the cross-border movement of plants and plant products.

 

The adequacy of personal import controls on animals, plants and their products and the enforcement of controls

  1. It is critical that it is understood that anything that moves across a border has an element of risk, and that pests and diseases can arrive through many means – and risk is not just associated or talked about with organised business/economic trade. Individuals – the general population, tourist – have a personal responsibility. Personal imports and individuals travelling abroad from the UK and bringing plant products back with them is a continued risk to plant health. The HTA and others have worked to bring greater awareness to the risks of this practice. However, there is a need to continue to educate travellers and warn them of the rules and the very real dangers to biosecurity, should they bring back plant products containing pests, or invasive non-native species to the UK from abroad. We believe much more can be done on personal imports.

 

  1. Below are some of the statistics that the HTA has gathered from surveys on this topic:

 

2.33% of UK adults said that they brought plants/plant material back to the UK from overseas in the last year. (Source: HTA independent survey with YouGov, December 2024)

 

This is equivalent to 1.3 million UK adults importing foreign plant material into the UK each year (Source: Population estimates, Office for National Statistics, 2024)

 

UK adult awareness of plant pests/diseases (Source: HTA independent survey with YouGov, December 2024): 3% are aware of Xylella Fastidiosa; 11% are aware of Oak Processionary Moths; 29% are aware of Ash dieback; 17% are aware of vine weevils; 4% are aware of Rose Rosette Virus; 3% claimed awareness of a fictional disease.

 

The performance of Defra and its agencies (such as the APHA) in delivering the Border Target Operating Model (BTOM) and communicating and engaging with stakeholders

  1. The BTOM has gone through multiple iterations since it was first drafted as the Border Operating Model in 2023. With the inception on 1 January 2021 of full plant health controls on plants and many plant products, the risk categorisations and inspection rates of all plants and plant products have changed multiple times since then too. While risk should indeed be flexible as pest and disease situations change, the associated plant health legislation is incredibly complex and difficult to keep up to date with from a business point of view. Each pest species has a different ‘Risk Rating’ on the Plant Risk Register, often with multiple host plants, and each source country also has a different level of risk applied. Defra & APHA are the main sources of risk and potential risk information – however information is provided with the focus on the particular pest or disease, rather than the host species – which is of key importance to traders. It is plants that are traded, not pests, and healthy plants are the key to successful trade.

 

  1. Biosecurity is a top priority for the sector, and the Place of Destination (PoD) checks that operated between 2021 and 29th April 2024 provided industry with greater biosecurity than they are experiencing today. The PoD checks were due to EU-exit. The HTA does not believe that the current approach at the border can achieve the level of biosecurity provided by the PoD system nor the ambition set out in the BTOM in the near or medium-term without substantive change and investment including in existing infrastructure and new systems, as well as delivery on alternatives to Border Control Points (BCPs) for plants.

 

  1. As a longer-term ambition, we seek an SPS agreement with the EU as the number one priority for our sector. However, we also have long-proposed solutions that meet the sector’s unique needs and can be implemented with good design and application of resource within a few months. Whilst we are aware the PoD system operated 2021-2024 was not intended to be permanent, we sought (and still seek) a dual PoD and BCP system operation. This ensures full biosecurity controls are in place during the pragmatic period, gives businesses choice, places the expertise in biosecurity and handling sensitive plants with the experts and relieves the intense pressure on APHA that is currently being experienced.

 

  1. This type of system, if well designed and done so in collaboration with the sectors, means that even without a plant health agreement, a hybrid BCP/PoD+ system can operate smoothly and effectively with minimal cost, meaning biosecurity is high and WTO obligations met. This solution was rejected by Government, with a determined approach to push through BCPs to the exclusion of all other solutions, even to the detriment of the UK’s biosecurity with the check levels we see today.

 

  1. Inspection rates: During the operation of the PoD system, we estimate inspection rates were running at circa 40% i.e. 40% of inspections that were meant to occur were completed. So while consignments might be selected by the ‘risk engine’ to be inspected, they would not be inspected due to various factors. These “PoD inspections” were conducted thoroughly and properly at the PoD, on plants that were unloaded by the recipient and set out to facilitate inspection. While these rates may not reflect the intended rates published by Defra, those inspections that were done, were done properly and facilitated by experts (e.g. the nurseries).

 

  1. We now estimate inspection rates to be slightly higher at BCPs, but still not achieving the intended rate. Also, we know that many of the inspections done at BCPs are not done to the highest standards due to restrictions of access to plants on trailers, the time pressures of trailers queuing to be inspected, there not being enough BCP capacity and restrictions on APHA resource availability. In fact, all of those factors produce a very unsatisfactory inspection landscape, where the intended rates are likely never to be achieved at BCPs and some of the inspections not fully completed.

 

  1. It is known that APHA have had to recruit significant numbers of extra staff in an ever rapidly changing situation. Issues have subsequently arisen with delivery of inconsistent information to businesses and untrained staff operating where previously long-held positive relationships with businesses have been in existence. Indeed, many businesses see their APHA inspector as a positive extension of their business – advising on pest and disease, best practice and helping them navigate complex situations. These relationships have unfortunately been largely lost due to a combination of inspections moving to the border and new staff coming in. indeed, with third party port operators, HTA businesses have even been involved in directly advising handling operations at BCPs in order to demonstrate best practice in handling and caring for plants. While not the direct responsibility of APHA, this is a direct consequence of unloading & reloading plants for inspections at the border.

 

  1. Having seen inspection rates start off extremely slowly under the ‘pragmatic approach’ when BCPs were first introduced on EU materials in May last year and having done extensive engagement with third party port operators who manage and run the BCPs at those ports, we believe the BCPs have reached capacity now. Without significant investment in port infrastructure and a properly developed dual PoD+/BCP dual scheme, biosecurity is now permanently compromised in GB. Defra have indicated a wish to get to business as usual (BAU), but with the downsizing and reorganisation of Defra borders teams, and the lack of BCP throughput capacity we believe BAU has already been achieved. This is disappointing and concerning for those impacted by the border.

 

  1. Biosecurity Risks. The design of Sevington border facility contains a major risk to the UK’s biosecurity. For example, not only do curtain sided lorries cross Kent potentially releasing their unwanted pests into the local environment, but there is also a real possibility that lorries can simply ‘drive by’ the facility, unloading at their destination without any checks. Even if that product is subsequently recalled for its proper check, the goods have already entered into the environment without a check. Reloading them and taking them back to Kent just exacerbates the issues if there was a pest on board.

 

  1. BCPs are also capable of introducing cross-contamination, because all BCPs are built to virtually the same design and designated to the same standard, there is no provision made within the ‘turn out’ area when multiple loads are unloaded for inspection at one time, thereby facilitating a mobile pest to cross from one load to another. In addition, there is only a single ‘drive in bay’, meaning curtain-sided lorries, which make up 25% of the plant trade haulage from the EU, and 1 in 4 lorries selected for inspection, either have to wait for very long periods or are just removed from inspection lists due to lack of capacity to inspect.

 

  1. Consolidation also risks biosecurity. In order to mitigate the ever-increasing BTOM related costs hitting hauliers, exporters and importers, businesses both in the UK and EU are now using consolidators. This means previous trades, which likely were business to business, nursery to nursery, now visit a consolidator in the EU where they are amalgamated with batches of plants from other EU areas, obtain their phytosanitary certificate on what is pretty much a production line. They then cross the border and land at a distribution centre in the UK, often handled by a 3rd party importer, mixed with other plant materials,

 

  1. Biosecurity is also being compromised currently where loads are being ‘waved through’ to avoid excessive waiting times at BCPs or queues of lorries or where systems are down and manual processes in play. We are seeing loads that should be inspected are not and see no plan to remedy this from Government. Biosecurity is cited as the main reason for moving from the PoD system to the BCP system, so any 'pressure release valve ' is counterproductive to the laudable ambition of enhancing biosecurity.

 

  1. The disruption of needing to stop goods and go via BCP also represents a lack of control for grower businesses where control over their supply chain is of paramount importance – to control costs, expedite order and first and foremost, maintain the biosecure chain of custody. There is a part of the plants journey now where the receiving business has no control over what happens to it, where it is put and what it is mixed with. And will never know this.

 

  1. Communication of issues and resolving solutions at the border, particularly for the plants sector, have been slow to improve. A recent example of the lack of communication are the incidents at Sevington BCP concerning the findings of Pochazia shantungensis, a brown winged cicada that, while not a quarantine pest of the UK, was nevertheless intercepted on loads of mature stock sourced from the Italian region of Pistoia in September 2024. The loads were held and identification of the pest made by sending away samples to the laboratories at FERA in York. While there are still legitimate questions around whether this pest can survive in the UK climate, and also its official status in the UK (as the Plant Risk Register was not showing that it was regulated at the time of interception) this pest has the potential to infest fruit trees. Major issues arose when loads were held with little to no direct communication to importers and their agents about what was happening, why had the loads been held, how long was the estimated time frame for the hold and who to contact in the event of questions. Communication was virtually non-existent.

 

  1. There should be a known and effective means of communicating when loads are put on hold pending investigation. There are also issues when loads are held pending investigation and the plants are not cared for, meaning that even if subsequently released plant quality suffers, even resulting in non-viability of the products.

 

  1. The issue at Sevington took days, sometimes weeks, to resolve. Many hundreds of thousands of pounds worth of plants and trees were destroyed even those that passed testing were compromised, and the overall faith of the sector in the ability of the Government to deliver an effective and clear border was severely affected. The issue and activity around was very poorly communicated to the trade, and to importers & hauliers involved. While we hear lessons have been learnt, we still have no communication as to what to expect if such an interception is made again. Ideally a real time border alert system should be in place to help a) inform importers and hauliers about their own consignment and b) inform the wider sector that there is a potential issue so that businesses can take prompt action. Deliveries can quickly be halted and the right pre-emptive action can be taken by the originating exporters. In the above case, loads were still coming in from the exporting country, with no instruction or information about what to expect nor advice from APHA on how best to deal with the suspected threat.

 

  1. Seeds imports: The HTA has had a number of seed industry businesses raise issues concerning the cross-border trade in seeds. These businesses are primarily trading packet seeds for the hobby or direct to consumer market, but there is a diversity in the businesses. Some examples of the differences are that some import filled packets, importing bulk, importing from the EU but original source from outside the EU. The UK has a substantive number of SME and specialist seed businesses, who are particularly impacted by friction in cross-border trade arrangements, testing and complexity.

 

  1. The impact of the challenges faced is causing reduced trade, huge cost and resource burdens, increased consumer prices and reduced choice, decreased UK resilience with lack of seed, reduced investment in business growth and a disproportionate impact on SMEs.

 

  1. While testing of seeds is necessary to establish the presence of pathogens and viruses, the volume of seed taken for testing, and the length of time it takes, often makes smaller batches unviable for sale. Couple that with the fact that the same tests undertaken in the originating country are not recognised by the UK as valid, means batches are often tested twice, held for unreasonable amounts of time and reduced significantly in volume.

 

  1. Key asks on trading in seeds: a proportionate and appropriate sample size, respecting total volume and risk, when seeds are taken for testing. Expedited testing with a service level agreement in place on timeframes that meets commercial and seasonal timing needs; confirmation and application of actual inspection rates; clarity and consistency of advice for businesses importing seed(s) including on definition of source of origin, and easier to access and navigate communication and guidance; improve communication and engagement with the sector when destruction notices are issued.

 

  1. HTA key BTOM issues: We have set out here issues relating or impacting directly or indirectly on biosecurity, however we would also like to set out a number of other issues affecting businesses relating to the operation of the BTOM that we have recently submitted to Government. Without going into detail, and in no particular order, these issues include-

 

    1. Issues with groupage, particularly for SMEs, involving delays for non-selected consignments travelling on groupage and the unwillingness of hauliers to take consignments moved across borders on groupage
    2. Extra charges related to border operations, including the Common User Charge
    3. Dwell times on port affecting hauliers and affecting plant quality and delivery times
    4. The difficulty of businesses to safely forecast costs for the coming season, thereby impacting income and subsequently the confidence and ability to invest. Also the impact of all costs on the consumer and inflation
    5. The negative effect on relations with long held and trusted EU based suppliers and their willingness to trade with the UK, and the subsequent potential impact on the economy
    6. The mothballing of the Single Trade Window and its potential to smooth processes
    7. The significant impact of Brexit on Northern Ireland trade
    8. The impact of CITEs regulations and requirements on trade
    9. The lack of the promised Authorised Operator Status scheme, still in pilot form with no decision on whether it will be a full scheme or not
    10. The lack of support for businesses to become Control Points (thereby circumventing BCPs) and the absence of a ‘one stop shop’ for applicants
    11. The slow progress of IPAFFS and other related IT systems, their frequent issues, down time and negative effect on the businesses.
    12. The lack of any recognition of liability for damages incurred on plants at the border by Government agencies and some BCP operators
    13. The impact of the BTOM on SMEs
    14. The haulier shortages now becoming apparent due to delays at the border, hauliers subsequent significant costs and the resulting shortage of drivers due to drivers leaving the plant haulage sector.

 

 

Actions to address challenges

  1. The HTA is calling on the both the UK and EU to negotiate an SPS agreement which has the potential to allow plant imports and exports to move across the UK-EU border quickly and effectively without undue delay and cost. An SPS agreement, if crafted correctly, will maintain biosecurity, and has the possibility to enhance it, which is of great importance to the sector. Any agreement with the EU must be based on mutual recognition of each other’s plant health areas; this is of paramount importance. We see this as the long-term solution to address border issues and friction, and be able to include biosecurity measures that reflects the UK’s needs. We are developing detailed positioning on this and would be pleased to eventually provide this to the committee.

 

  1. The HTA has produced an ‘Issues & Solutions List’ specific to Borders (EU-GB trade only). Given this is our evidence, we have not included our commentary on the position of UK government on these areas. We note that this is very specific and complex and are able to provide greater explanation of the multiple systems and processes.

 

  1. ‘Issues & Solutions List’

 

Detail/ Action

Issue

Solution/ HTA Asks

Progress

Every agency or entity that has input into border processes, or requires trader input, operates in its own separate silo and therefore, traders are often left without access to the right contact and the right relevant information in order to discuss an issue.

Multi-agency Approach

A single overarching agency that has access to all the relevant information and is therefore able to pass on information to importers, agents, and hauliers.

None

BCPs were not designed & built for plant imports, particularly if they are held for over 24 hours.

BCPs are not equipped to unload ‘exceptional loads’.

The designation process does not include proper quarantine facilities, resulting in plants being held for extended periods and BCPs unable to isolate infected stock.

BCPs do not have defined destruction processes & costs published (or even in existence), which means there is no commercial choice for importers.

Cross contamination potential of more than one trailer unloaded into shared ‘turnout’ area.

Border Control Points (BCPs)

A new system such as moving inland to facilitate inspections for EU goods at properly equipped registered and audited locations is required (e.g. POD+ system)– not utilising the full CP designation process & not requiring customs approvals. For example – unloading of tree for one importer resulted in significant damage to the stems, and eventually the trees died. They were high value specimens brought in for a specific job.

Retrofitting BCPs to be able to properly handle all types of plants, trees etc and also mechanisms to guarantee biosecurity & temperature control of plants.

Having a consistent destruction process published and costs.

Save legislation allowing ‘exceptional large loads’ to be handled outside by currently designated and suitably authorised BCPs/CPs with the right infrastructure (due 30 January 2025).

No further progress on anything else.

Damages to plants & trees are frequent as products are being offloaded and reloaded by third parties at BCPs.

Stock being held for long periods of time is deteriorating to the point it is unsaleable, unusable and sometimes dies.

Government and its agencies do not accept responsibility for these damages or losses because they are don’t be third party operators, despite the instruction for inspection originating from Govt regulatory requirements.

Govt position for damages & deterioration is that importing is done at the importers risk and no liability is taken for any damages incurred. BCP port operators differ in approach between ports, e.g. one accepts no liability for anything at all and a waiver has to be signed for goods to exit the port, while others have a complaints process.

Government Liability

Government should take some responsibility for business-damaging activities that occur accidentally when goods are inspected or held overly long due to inadequate govt systems or errors.

None

Currently the UK NPPO is experiencing a 2-week delay in issuing interception date to trade.

Lack of publicly available data on the operations of BCPs, how many inspections have been requested, how many have been conducted, what commodities the inspections were on - by BCP i.e. the progress of the ‘pragmatic approach’ and how to establish when we have reached business as usual.

Trade cannot confidently react to biosecurity issues when they happen and cannot forecast best routes for products due to lack of data, transparency and real time information.

UK NPPO data

 

*National Plant Protection Organisation

UK NPPO needs to update trade as soon as an issue is identified in real time using a prescribed alert system.

A public set of data should be published regularly to show progress.

Publishing interception data within 24 hours has been committed to, but as of 27/1 this has not be implemented. All other requests for clarity of inspection data have been refused.

 

 

These systems have been developed piecemeal, and the system that connects into them (ALVS/GVMW/Destin 8 etc) are overly complex, and not available to all supply chain actors.

The systems are owned by various departments of commercial entities.

They do not currently work together, this means that there are double entries, unclear information on whether a plant has or has not been inspected. In turn, this means extra costs and change buying patterns which bolster biosecurity.

IT Systems – IPAFFs/CDS

A synchronised system that is up-to-date and with all the relevant information is needed, which is visible to all supply chain actors and is overseen by one Government office.

Single Trade Window now mothballed

IPAFFS still not perfected, but some patch fixes have been implemented.

CDS & IPAFFS systems still not fully synchronised.

There are multiple elements within the IPAFFS and CDS systems generate a ‘hold’ on a consignment. It can be extremely time consuming and of no benefit to biosecurity to ID what the error is, how to release the hold. Different departments give you different reasons for holds, often giving opposite advice. Delays are too long trying to get releases secured, while plant sit at ports & BCPs getting paperwork amended.

Noncompliance notices are issued immediately to legitimate traders trying their best.

Consignments are held for significant periods of time for unknown reasons. Importers, agents, and hauliers have to chase multiple agencies to find out where they are.

 

Consignments on Hold

There is no ‘one stop shop’ where a singular agency is able to provide information to importers, agents, and hauliers are able to gain information, as to why their consignments are being held.

Communication needs to improve between importers, traders, and IPAFFs/CDS to ensure there are no unnecessary delays to consignments being held. 

A pragmatic approach needs to be taken when biosecurity is not compromised, and the cessation of issuing non-compliance orders ‘blacklisting’ traders who are willing to fix issues and wanting to comply should be implemented immediately.

Publication of data on border movements, inspection rates for products, real-time alerts on at-border holds.

Little progress, holds are still difficult to view.

No commitment to a real time alert system.

Data still not visible.

Communications with all parties in border process very difficult and time consuming.

Issues around GB Plant Passports not being affixed to retail-ready plants in the EU on behalf of GB Plant Passport holders.

Significant impact of having to move affixing operations into GB if a trader does not have a GB based distribution hub and delvers direct to site or store.

Plant Passports

Requesting an extension to the easement (Easement expires at the end of June 2025)

Design and develop a workable electronic plant passport system that is launched before easement ends

ePP Task & Finish Group set up, but little progress made.

Easement not extended.

AOS is not accessible for smaller businesses due to the requirement of an CP status, furthermore, there continues to be little certainty on whether or not it will become an official easement.

Authorised Operator Scheme (AOS)

HTA seeks engagement from government to expediate AOS and identify easements for SMEs to which CP and AOS is not viable.

Potential for a ‘collaborative’ scheme should be investigated where several businesses join together (as a co-op maybe) to run a CP that has AOS status – would need Govt support and direction.

Still no guarantee AOS system will launch.

Pilot still being evaluated.

No solution for SMEs.

APHA do not have any policies regarding fumigation / spraying for pests on held consignments (biosecurity risk – curtain sided vehicles held pre-destruction).

Biosecurity issues at BCPs as facilities are not as biosecure as they could be, and each BCP has a different approach to quarantine, destruction and presenting goods for inspection.

APHA

APHA need to create policies to mitigate against this as a matter of biosecurity.

No commitment made

The current CITES import system in the UK is outdated and heavily paper-based, conflicting with the UK’s Border Target Operating Model. This system has caused significant trade losses and seizures of legal products.

CITES

An urgent need to review and modernise CITES and fully digitalise and remove unnecessary procedures from the system.

A consultation from the industry is also needed.

Consultation still awaited.

No commitment to fully digitised service

 

  1. 10 multi sector asks. In a letter dated 17 October, with a follow up letter dated 21 November, the Fresh Produce Consortium and HTA set out 10 joint asks of the Government. This represents multi-organisational agreement on the issues being faced at the border and relevant solutions proposed by multiple industries, many of the issues contributing to compromising biosecurity and none of them reducing costs and friction in border processes.

 

10 specific border related actions

  1. Urgent border policy summit with cross-government ministerial engagement, to hear directly from businesses and establish as swift and solutions focused action programme.

 

 

  1. Urgently ensure there is ownership and oversight within government of the full suite of border and trade related policies impacting UK horticulture and fresh produce businesses and consumers. We must see growth and economic considerations fully understood when making policy decisions. The reduction in resourcing of the borders team in Defra should be reversed.

 

  1. Deliver the reset of the UK’s relationship with the EU. The HTA seeks an SPS/plant health agreement to be achieved based around the principle of mutual recognition, whilst maintaining essential elements of the revised UK Governments border approach.

 

 

  1. Remove barriers to the current Control Point (CP) system, through provision of inspectors to CPs after 5pm, meet the 4-hour service level agreement at BCPs, expedite roll-out of Authorised Operator Status (AOS or ‘trusted trader’), and, given BCPs are not fit-for-purpose in-terms of capability or capacity for handling high-risk plant trade, ensure access to AOS and establishing a POD+ system for those businesses.

 

 

  1. Review UK commodity risk categorisation further including for current high-risk plant products, cut-flowers, and seeds.

 

 

  1. Urgent action on communications and trading systems access including broader access to IPAFFS, publication of data on border movements, inspection rates for products, real-time alerts on at-border holds, improved system for UK plant health related alerts,

 

 

  1. Improve pest and disease testing capability and biosecurity measures at the border, by providing and properly equipped on site laboratories at key BCP and CP locations, improving testing times and proportionality of tests applied, such as seed sample sizes used. Or confirmation of prohibitive pest presence. 

 

  1. Confirm now an easement-extension beyond the 30 June 2025 deadline to allow GB Plant Passports to be affixed to retail-ready plants in the EU on behalf of GB Plant Passport holders.

 

  1. Pause the Common User Charge for 12 months and fully review the economic impacts of UK borders policy.

 

  1. Direct and active international engagement to reassure those involved in global horticulture and fresh produce supply-chains that the UK government is open for trade, business and seeking to improve border operations bot now and give future certainty.

 

 

Plant Health Management Standard and the Plant Health Certificate Scheme

  1. Since 2018 the environmental horticulture and landscaping industry, through its various trade associations and businesses, has been an active participant in supporting the development of the Plant Health Management Standard (the Standard), and the Plant Healthy Certification Scheme (PHCS).  The Standard requires (among other things) organisations to risk assess UK and overseas suppliers in the context of pest and disease risks, and to accept responsibility for the plants they source and assure their traceability, and for putting in place procedures for checking that goods in which have the potential to be infested or to harbour pests (whether from the UK or overseas) are checked on receipt; the benefits in terms of reducing the risk posed by cross-border trade from adoption of the Standard are clear. The industry has also supported, and continues to support, Plant Healthy Ltd, the independent charity (the Charity) which owns and controls the Standard and the PHCS. 
     
  2. The science-based, independent and apolitical development of a Standard which incorporates both policy, trade, and scientific perspectives is a hugely positive innovation.  The PHCS currently provides a means through which around 80 organisations can formally certify their compliance with the Standard. The HTA has been a key player in achieving this figure, for instance through undertaking and supporting significant trade-focused communications and promotions in partnership with Defra and the charity to drive adoption both of the Standard, and the PHCS. 
     
  3. The future development of the Standard, and approaches to certification in the supply chain, are of critical importance to the continuing success of this innovative partnership.  Firstly, industry awareness and adoption of the Standard needs to be driven throughout organisations in the supply chain.  The industry has an affinity with plants, and has a huge vested commercial interest in good standards of biosecurity in its operations.  The HTA is committed to playing an active role in promoting good biosecurity practice to its members as a critical part of Environmental Horticulture and Landscaping.
     
  4. Certification to the Standard (as opposed to adoption/implementation) has now, in our view, reached a critical juncture.  Many businesses currently certified via the PHCS rely on this certification as a means of accessing government grants, for instance related to tree planting. 
     
  5. Our view is that emerging bio-secure public procurement policies are likely to increase commercial importance of certification for these businesses.  At present, the PHCS is the only pragmatic route available for businesses to certify that they meet the Standard that is recognised by Defra and the Charity. This presents a systemic ‘risk’, insofar as the Charity and the PHCS are single points of failure for businesses relying on the ability to be able to certify to the Standard; should there be operational issues affecting the business continuity of the Certification, this presents an increasing risk to businesses.
     
  6. With this in mind, we have formally expressed interest in the OHAS (Ornamental Horticulture Assurance Scheme) certification scheme becoming an equivalent route to certifying to the Standard; OHAS already has provisions in place which are highly consistent with the Standard.  This would substantially and rapidly increase the proportion of the supply chain which is certified, and establish the precedent for other certification schemes and scheme providers to be able to offer routes to certification to the Standard.
     
  7. OHAS and other schemes operate internationally, and so have the potential to play a role in raising awareness and eventual adoption of the Standard outside of the UK’s jurisdiction, further assuring cross-border trade. We anticipate that this approach of enabling certification to the Standard to be achieved through a range of certification schemes will provide accelerated certification ‘capacity’ and resilience in terms of ensuring the PHCS and/or the Charity’s capacity to administer it at increased scale does not slow adoption. We welcome the Charity’s acceptance of the principles of this approach, and would welcome formal Defra endorsement of this strategy for the Charity.
     
  8. A key factor in the adoption of the PHCS to date has been the ‘incentive’ of being able to access various public sector grants relating to tree planting.  The HTA’s view, based on our experience of running certification schemes and observing the operation of schemes in other sectors, is that further incentives need to be found to drive certification.
     
  9. There is currently very positive work underway funded by Defra investigating the potential for access to financial support (whether publicly or privately funded) for businesses which are critically impacted by a biosecurity incident; we appreciated the consultative approach that Defra took into this research, and the opportunity we were given to input into research design and promoting the research to our members.  Were access to such financial support conditional on being certified to the Standard (through whatever route/scheme) this would provide a major incentive /benefit for businesses to certify to the standard relative to the costs (which are typically in the low-to-mid £ thousands per year).
     
  10. Recognition of the status of businesses which are certified to the standard in terms of the regulatory approach applied to their international trade in plants also has the potential to drive adoption of certification to the Standard by providing a clear business incentive; we would be keen to engage in a dialogue with Defra into potential ways of progressing this. Equally there are ‘soft’ ways of creating such incentives for adoption, for instance inclusion of certification as judging/eligibility criteria for prestigious industry awards (for instance HTA has made Plant Healthy Certification a consideration in judging for its Grower of the Year awards).  We would like to engage in a more detailed dialogue with Defra and the Charity around how industry-focused activities could be leveraged to drive adoption of the Standard, and certification where commercially feasible and affordable for businesses.
     
  11. We note that a bio-secure supply chain for the UK’s plants and trees ends with the ‘consumer’ of the UK’s plants. Since 2019 we have tracked via a nationally representative sample survey from YouGov, the proportion of the general public who report bringing back plant material from trips overseas. The latest figures for 2024 show that an alarming 1.3 million brought plants or plant material back with them from overseas trips.  The potential for this consumer behaviour to damage the UK’s natural landscape, and the UK’s horticulture and landscaping industry, is a major concern for our industry; we have shared this data with Defra, and our understanding is that the data correlates closely with its own estimates. We would like to see greater urgency and focus from Defra on addressing this consumer behaviour, and would be willing to play a positive role in this.
     
  12. We receive limited updates or information from Defra around its plans for a ‘National Conversation’ with the general public around plant health and biosecurity, and would welcome the opportunity to play a greater part in shaping and contributing to it, particularly with regard to this critical risk to UK plant health. 
     
  13. However, we have flagged our increasing alarm at what we understand are Defra’s plans to engage in a consumer-focused initiative which, from spring 2026, would ‘implement behavioural interventions which encourage plant buying consumers to preferentially choose to buy plants from Plant Healthy certified retailers’. 
     
  14. There are many potential risks and adverse unforeseen consequences (for industry and to Defra’s aspirations to increasing certification) which could result from a premature launch of such a consumer-facing initiative. First among these is the fact that there is insufficient time for a significant number of retailers to become certified by spring 2026, nor sufficient capacity to audit and certify so many businesses. Should such an initiative launch without businesses having had time to become certified, it would likely lead to a hostile reaction from businesses, with the perception potentially being that the initiative unreasonably discourages their customers from purchasing plants from them, or indeed from purchasing plants at all given low likely levels of certification among retailers by spring 2026.
     
  15. A second key risk is that the PlantHealthy branding and name was designed for a trade audience. Variations of the words ‘Plant Healthy’ are widely used in trade communications and marketing activity aimed at the public, notably around assurances of product quality.  Adequate time and consultation with the industry needs to occur to ensure that messages, logos, etc around plant health are fully tested, and do not inadvertently imply (for instance) that plants sold in businesses which aren't certified are of inferior quality (or vice versa). 
     
  16. There are many other such potential risks in the direction being taken, and we would like the opportunity to engage with Defra and the Charity constructively and urgently around consumer-focused work in this area. Such engagement will be vital in helping to ensure that consumer messaging dovetails with initiatives in the industry, and so that the current high levels of good-will towards the PlantHealthy initiative and the benefits it is already bringing to cross-border trade are not jeopardised by a premature public awareness campaign which could generate unforeseen consumer responses.

 

Sources and further references

Mission Green Growth: A Strategic Plan from the Environmental Horticulture Group Autumn 2024: https://hta.org.uk/policy/research-documents-and-policy-papers

HTA independent survey with YouGov, December 2024)

https://hta.org.uk/policy/cross-border-trade

Four Years On: Environmental Horticulture Brexit Costs and Border Impacts

https://hta.org.uk/news/four-years-on-environmental-horticulture-brexit-costs-and-border-impacts

 

Original Joint Letter from HTA & FPC to DEFRA

https://hta.org.uk/news/hta-and-fpc-escalate-asks-for-urgent-action-as-border-crisis-worsens

 

Written evidence submitted by The Horticultural Trades Association (HTA)

https://committees.parliament.uk/writtenevidence/130441/pdf/ 

 

https://hta.org.uk/news-events-current-issues/industry-data/market-sizing

 

Overseas trade statistics, HMRC, commodity codes: 0601 and 0602

 

Horticulture statistics, Defra

 

Overseas trade statistics, HMRC, commodity codes: 0601 and 0602

 

APHA Statistics, January 2023

 

 

January 2025