Informe de evaluación del ecosistema de confianza

Published 29 August 2023

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Having left the European Union, the UK has an opportunity to redefine how we run the border. We can make key decisions about how we implement border controls and radically redesign processes by looking at advances in data collection and sharing and new technologies.

The UK isn’t alone in wanting to improve its border. All governments want to deal with the latest challenges for trade - be they the rise in e-commerce and small packages crossing the border, or new security and biosecurity threats, or the ability to manage the border through crises and supply chain crises caused by geopolitical events. The European Commission has just issued its proposals for an overhaul of customs by 2032, where the main thrust is a move from a declarations-based system to a data-led system. In other words, paperwork and formalities are reduced where data is given transparently and authorities have visibility of whole supply chains. The US has also started the acquisition process for its next generation single window for trade data platform. This will replace their current single trade window, and support the provision of better quality data earlier in the supply chain, more seamlessly and from a wider range of supply chain actors. It will increase supply chain visibility and allow US agencies to make timely, coordinated targeting decisions further in advance, before goods arrive at the border, improving security while speeding entry for legitimate trade.

The UK has big ambitions. Our border transformation projects are not confined to customs but look at all relevant border compliance regimes. But, like every government, the UK government has to balance innovation with a range of responsibilities it must deliver in its implementation of the border: for example, keeping citizens safe, protecting the UK’s environment, enforcing trade policy, honouring international obligations and protecting consumers. To do these effectively, we maintain control over what crosses the border. We need to know what – and who – is crossing the border, while assessing the level of risk these movements constitute so that we can carry out appropriate checks. The UK government also wants to promote economic growth and support businesses to trade easily with countries across the world. Effective border processes are crucial to delivering these objectives, by ensuring that we can enforce controls with minimum burden to businesses.

Current processes at the border are transactional and create administrative burdens for traders. Often traders (and those providing data on behalf of the trader) are required to submit the same or similar information to different entities within the government, creating complexity and cost. Physical checks and other border processes can add further costs and delay the release of goods. These can result in an incomplete or disjointed picture of border flow for government agencies, leading to suboptimal risking and inefficient checks.

One of the goals of our 2025 Border Strategy is to reduce the burden on traders and help UK businesses take advantage of new trading relationships with countries across the world, whilst strengthening our ability to target criminal activity and protect the UK’s people, businesses, health, and environment.

The UK government believes that transforming the border means moving physical processes away from the frontier wherever possible. We believe this can be achieved by taking advantage of cutting-edge technologies and real-time data, which can help us better assure the movement of goods across the border and by triangulating this new data, technology and trusted relationships. This automated assurance and reliability can help to build and ensure trust between actors, creating an “Ecosystem of Trust” (EoT) that could allow a great deal of processes to be moved away from the physical frontier.

In 2021 the UK government committed to testing the idea that an EoT - made up of three pillars; technological capabilities, real time data and trusted relationships - could reduce trade frictions without compromising the UK’s security or biosecurity.

The vision of the EoT is that, by working with industry to harness innovative technology, we can create a frictionless import/export experience for compliant and Trusted Traders and enable enforcement of controls to be more focused on traders deemed to be of higher risk.

We started with the idea that through new Trusted Trader Schemes we might be able to unlock streamlined border experiences for particular traders in exchange for three things:

We set out to explore whether the ambitious goal of using better technology and data to enable frictionless trade was feasible and, if so, what level of benefits could realistically be expected. Possible outcomes range from modest time/cost savings for traders due to data automation and movement of checks away from the border, through to the most ambitious benefits, like the reduction of physical inspections and associated paperwork. The government hoped for greater trade facilitation and a more secure border, capable of detecting and deterring hostile actors.

Government wanted to assess: which supply chain visibility and goods movement integrity capabilities are currently available and deployed by industry; the extent to which these could support an EoT approach in practice; and what the benefits of this might be. This would allow the government to better understand which policy, process and system changes would be required for the EoT model, including what open technology standards would be required to allow efficient scale adoption of the model.

The core features that the EoT pilots set out to test are:

Figure 1: Strawman of an Ecosystem of Trust (as outlined in the 2025 Border Strategy)

Technology offers many opportunities to build trusted relationships between government and users of the border. Our strategy focuses on exploring these approaches with industry and taking forward the solutions that drive the greatest benefits for the UK.

Technology enables greater security assurance, integrity of goods assurance, movement of goods assurance, End- to- end traceability to trader’s premises assurance to government as it allows Government to collect more data upfront from users of the border making the border more secure. Examples include:

Border users experience fewer checks and more predictability because so much is known in advance about them and their goods.

This ultimately creates an ecosystem of trust through greater security assurance, integrity of goods assurance, movement of goods assurance and End- to- end traceability to trader’s premises assurance.

The pilots were based on the principle of collaboration and open innovation between government and Industry, with both working together to co-design trials of technology and processes.

As such the pilots provided an opportunity, in a safe environment, for industry to demonstrate in-practice systems and technologies which have the potential to significantly enhance the way government and industry communicate and share data with each other. The fact that pilots were “dual running” with standard border controls, and so all normal processes were followed while the pilots were testing new processes in parallel, meant that we could be as experimental in our pilots as possible with no detriment to security or biosecurity.

The pilot process began in December 2021 with a call for expressions of interest. These called for self-organised consortia to pilot proposals in conjunction with border departments and agencies. The scope was that consortia would:

Those companies expressing an interest underwent due diligence checks and then were invited to form consortia. The consortia were required to comprise of at least; a port, a trusted importer with an accredited overseas trade partner, a carrier, a logistics firm and a technology company (though some also included research organisations and universities). A full list of consortia members and participants can be found in Annex E.

Industry collaborated in return for an opportunity to shape the future of the border, to test their ideas in a live port setting and to be involved in the development and creation of the standards and requirements needed to deploy technologies at scale.

After a co-design phase where prospective consortia had the opportunity to discuss and shape ideas with the departments who would be piloting them, all consortia proposals were judged by a cross-government panel. The six consortia proposals taken forward to live piloting were announced in July 2022, with pilots then running during the last quarter of 2022 and first quarter of 2023.

The six consortia each came with a variety of products to be tested on their own traders’ commodities across several modes and routes. A summary of the respective six consortia proposals can be found in Table 1. The government and consortia held a series of design clinics to understand their specific user journeys and the significant supply chain events within those user journeys in order to identify when time-critical information would be made available.

Each individual consortium deployed their own system of record (i.e. information storage and retrieval system) and a dashboard to visually present the data, with different “views” for government and industry. One consortium overlaid their dashboard with a data platform to enable enhanced data aggregation.

To assist government colleagues with understanding of the data being provided, each consortia produced a data menu describing the available data fields. A key distinction between consortia was the status of the data they were able to provide:

In addition to dashboards and platforms, several consortia took the opportunity to provide both an historical and operational file export during the pilot duration. Historic file exports contained data held in systems of record prior to pilots starting with the purpose of demonstrating data properties to officials, whereas operational file exports contained data exported directly from consortia to government once pilots had started and were made available at configurable intervals. Co-design discussions took place with departments to establish suitable formats in which to receive the structured data (namely CSV, XML or JSON). One consortium developed a roadmap for how they could achieve file exports in the future.

Consortia also provided extensive augmenting technologies which we explored and trialled to various degrees (see Chapter 3).

Table 1: Summary of the six consortia proposals

Data sits at the heart of the operation of the border. For businesses, data is key to managing complex international supply chains. For the government, data is vital for keeping the UK secure - underpinning our ability to evaluate the risk associated with goods and to make swift and accurate interventions where needed to combat fraud and disease.

Responses to the 2025 UK Border Strategy (PDF, 6.7 MB) consultation consistently emphasised that the government must work with industry to improve the use of data at the border and how it is shared. Specifically, the use of data, technology and relationships between government and users of the border to deliver robust upstream compliance, which would allow processes to be moved away from the frontier.

The pilots have acted as a proof of concept with industry - exploring which data elements could be drawn directly from the supply chain and, broadly, the requirements for the system integration methods to automate ingestion. The pilots, as illustrated in the remainder of this section, have demonstrated that supply chain data can provide additional value to that which is received from discrete declarations.

However, the pilots have also demonstrated that, at present, it is not feasible for supply chain data to replace the traditional declaration process as a result of significant obstacles to provision, adoption, and integration of this data.

The implication is that use of supply chain data, as a form of assurance that can replace particular border requirements for traders, will be a gradual process. Better border processes in aggregate will be driven from incremental improvements which are applied and scaled from specific use cases, as opposed to overhauling the current declaration process outright.

Through the pilots, we explored what data it is possible to generate securely from commercial transactions (such as those shown in figure 1) and pass into government to support border agencies to deliver border control regimes, and fulfil other responsibilities e.g. HMRC’s production of trade statistical data.

Below, we include findings from assessments conducted by the Home Office (HO) and Border Force (BF); Department for Environment, Food and Rural Affairs (Defra), Food Standards Agency (FSA) and HM Revenue and Customs (HMRC) respectively.

A core question we tested is whether supply chain data could provide “better quality” data to the government than is currently available through declarations. We used data field analysis to assess whether the minimum risking datasets that departments want for their internal processes could be met by consortia, i.e. testing whether supply chain data could match the scope of the data currently available through declarations. Our findings are broken down by compliance regime using the following criteria to assess the data we tested.

Figure 2: Typical international trade documentation issued

(source: World Trade Organisation)

The key differences between current declarations data and what we call “supply chain data” where it is gathered at source from the supply chain are:

During the pilots we used the following four markers of data quality to assess the data we were seeing from consortia:

Border Force targeting teams are responsible for assessing the potential risks of a consignment, and its related entities, so that timely interventions can be made at the border when necessary. To do this, they use several sources of data which vary by mode, including safety and security (S&S) declarations.

We have assessed the usefulness of data for the Home Office (HO) and Border Force (BF) using two methods:

The findings are given below and highlight that industry has access to valuable supply chain data that is not currently available to BF and HO from S&S declarations and other sources. The findings we would most highlight from extensive analysis are:

The data from the consortia was matched against the data currently used for targeting of each mode. The targeting criteria cannot be shared publicly due to security constraints so we have instead indicated where data was sufficiently matched (noting that multiple consortia data fields could match a single data field used for targeting).

Airfreight, Containers and Unaccompanied RoRo: For the consortia analysed, almost half the available data were strong matches against the BF targeting data set with an additional ~10% of unique matches that were potential matching, bringing the total of strong and potential matches to 59.1%.

Chart 1: Number and % of consortia data fields with strong matches to the data used for targeting by Airfreight, Containers and Unaccompanied RoRo

Chart 2: Number and % of consortia data fields with potential matches (strong matches + maybe matches) to the targeting data used by Airfreight, Containers, and Unaccompanied RoRo

Accompanied RoRo: For the consortia analysed, two-thirds of the available data were strong matches against the BF targeting data set, with an additional ~6% of unique matches that were potential matching, so the total of strong and potential matches to 72.6%.

Chart 3: Number and % of consortia data fields with strong matches to the data used for targeting by Accompanied RoRo

Chart 4: Number and % of potential matches (strong matches + maybe matches) between one consortia’s data and targeting data used by Accompanied RoRo

As well as the comparative data analysis, we performed an operational analysis to determine whether novel consortia data improves confidence[footnote 2] in targeting decisions. Our rationale was that if the new data boosts confidence when making targeting decisions then the rate of false positive checks and other mistakes will reduce for compliant goods, resulting in fewer delays for compliant traders. The evaluation assessed:

Accompanied RoRo: 17 consignments were assessed; ranging from books, kitchen appliances, automotive parts and computer related equipment - all within one consortium (Fujitsu).

Table 2: Accompanied RoRo novel data fields analysis, across 17 consignments

Unaccompanied RoRo: 18 consignments were assessed ranging from: frozen fish; coffee; tea; animal feed; and cut flowers for the same criteria, related to the one consortium dealing with this mode (DBM-ATC).

Table 3: Unaccompanied RoRo novel data fields analysis, across 18 consignments

Data fields assessed with a limited sample size

The new controls as part of the Targeting Operating Model will end the waiver for S&S declarations for EU imports mandating pre-arrival data from EU (as is currently mandated for non-EU traffic) within specified timescales. In RoRo and short sea containers, declarations are required by a minimum of 2 hours before arrival at the UK border; consortia stated that key data fields required for S&S declarations were made available well in advance of the deadlines – 72 hours after goods left port and 96 hours before arrival (this was not tested).

A few movements had Customs Declaration Service (CDS) import declarations, but not all of the movements within the same load. These were found to be useful during the targeting process and would save time accessing other systems. Some critical data elements to BoF risking (e.g. load description, weight and number of packages) were only present in PDF attachments which are not machine readable and therefore incompatible with government-systems specific risking rules.

In one consortia, we had the presence of augmenting technology (smart seals, GPS trackers) as well as the dashboard of supply chain data so we were able to look at the interactions and usefulness for BF.

Dashboard data was corroborated by the presence of the journey tracking data collected via smart seals. The tracking on the dashboard provided the journey start and end point for the vehicle, this could be followed live and demonstrated that the vehicle completed the expected journey. The journey as detailed via the tracker was invariably warehouse to warehouse as the participating transport businesses are goods consolidators rather than manufacturers of goods. When the invoices were examined the true origin of the goods was often found to be from a different city or country to those shown on the tracked journey. The structured data provided often showed the warehouse to warehouse information instead of the true origin of the goods and businesses involved in the transaction this impedes effective risking.

Defra, its agency Animal and Plant Health Agency (APHA) and the FSA have specific objectives, systems and processes: FSA around traceability and food health, Defra in Sanitary and Phytosanitary (SPS) and biosecurity controls, and APHA in controlling plant and animal disease. The results from their assessments of data are below

Availability:

FSA analysed the three consortia involved in the movement of relevant commodities. These consortia were able to meet 66%, 46%, and 66% of FSA risking data requirements respectively. An exact breakdown of where data was and wasn’t available for FSA is below.

Table 4: Consortia data availability analysis against FSA risking data requirements for three consortia

While import documents and information could be provided as part of the pilots, there was no way to replicate identity and physical checks. Defra notes biosecurity assurance capabilities from consortia are limited and do not provide the same level of information/ assurance as regular import processes. While some of the data provided was of interest (like the availability of the Export Health Certificates (EHCs) or phytosanitary certificate early in the consignment journey), the data provided so far could not replace current import processes or means of providing assurance. Assessing it against current import data/ risking information, the biggest gaps were:

For APHA, the plants and plant products team undertook the data analysis in line with the commodities tested. The two consortia that they analysed were able to meet 50% and 30% of the APHA’s risking data requirements respectively. APHA found that consortia data was sporadic and difficult to find in dashboards, therefore the comparative analysis in the table below is not entirely representative of the data that was available during the pilots.

Table 5: Analysis of data availability for two consortia against data used by APHA for risking based on four plant based commodities between 12.01.23 - 21.01.23.

The plant commodities were low frequency checks e.g. melons 1% random selection and green bananas which did not require a physical inspection due to Green Banana exempted Trader Status for this particular trader.

APHA felt that the consortia were not an improvement in existing IT systems where industry has to notify APHA of all regulated and pre-notifiable imports on a purpose built IT system (PEACH) and IPAFFS which uses automated risk engines, inspection recording facilities and links to HMRC’s CDS to enable prompt custom clearance. APHA couldn’t reach conclusions on what assurance the consortia data might provide or how it could improve biosecurity because they didn’t have opportunity to test high-risk goods during the pilots.

Timeliness: It was not possible for the FSA, Defra or APHA to make an assessment on the timeliness of data either because timestamps were not present for the consortia that were analysed; or because it was also not possible to receive scheduled historical and operational file transfers due to the lack of suitable environment.

Accuracy: It was difficult for Defra, FSA and APHA to ascertain the reliability or accuracy of data consortia - for example because, although the FSA has access to IPAFFS and HMRC customs data, they do not own those systems. For Defra, making it clear when documents had been uploaded would serve as a reliable method to confirm that certificates pre-dated departure from the country of origin as per Defra requirements. But if documents are not visible in a user-friendly way this reduces the reliability of this form of data availability.

Accessibility: Most of the data shared through consortia is available to the FSA via IPAFFS and HMRC (Customs Handling of Import and Export Freight (CHIEF/CDS) in a machine-readable format, with the exception of additional documents, seals and temperature data. Generally the sporadic nature of the data available through the consortia means it has little value to FSA’s border processes in its current state.

Availability: Consortia collectively demonstrated industry’s ability to provide data elements necessary to meet over four-fifths of HMRC’s minimum risking requirements and three-fifths of trade statistics requirements.

Data required specifically for international trade, but not other commercial functions, was most likely to be missing. However, this was not always the case and commodity codes for example, were found in some of the commercial invoices reviewed as part of the pilots.

Consortia also demonstrated the capability to share additional data beyond what HMRC would typically receive when goods are presented for clearance which could be potentially beneficial for risking, two such examples are:

The capability for industry to share additional data with HMRC that they already possess at potentially negligible cost to traders creates potential opportunities. HMRC would be particularly interested in potentially receiving additional data that increases its confidence in the classification, origin, destination and valuation of the goods as well as understanding what happened to them enroute and who are the responsible stakeholders in the supply chain.

The documentation typically requested as part of a typical post-clearance compliance check are airway bill/ Bill of Lading, licences, preference/ certificates of origin, payment/ financial records and instructions to their agent.

Timeliness: Upfront access and analysis of key documents (outlined above) could re-orientate the form and timelines of checks, and could improve their targeting (subject to HMRC systems being able to process this information).

Timeliness of data largely improved across all pilots as data was made available often by the stakeholder who generated the data. This differs from common commercial practices where HMRC typically receives data shortly before the consignment is dispatched and would allow HMRC to receive the data when it is generated, or shortly after.

Accuracy: HMRC was unable to robustly test the accuracy of data as it did not have access to a counterfactual to confirm if the data held was factually correct. HMRC did confirm for a small sample of consignments that the data accuracy was broadly equivalent to what is currently received. While HMRC could not confirm data quality improvements, consortia proposals and capabilities could logically provide it, for example, by reducing the opportunity of keying errors. While not a guarantee of accuracy, most platforms used cryptographic data security techniques, such as digital ledger technology to create an audit trail of when and who placed data on the platform. ​

Accessibility: Data was made available to HMRC in two ways - consortia platforms and in some cases via a bulk download of structured data. While HMRC knows industry can meet its current requirements, the main issue is accessibility. Overall the data was insufficiently accessible: it was made available on dashboards that required HMRC officials to ‘eyeball’ the information and it largely consisted of unstructured commercial documents which was not suitable for bulk processing of data. The structured data received in historical and operational file transfers was unsuitable because some data elements were missing and others that were available weren’t provided, as had been requested, in the correct format required to be analysed by HMRC systems, below is a non-exhaustive list of examples:

These accessibility challenges must be worked through collaboratively between government, industry and international partners and how to overcome them is further explored in Chapter 6.

In summary, the first cut of the data provided by consortia did not meet all of departments’ current requirements but were able to provide a lot of departments’ “ideal” data requirements, including information on good(s) descriptions such as quantities, values, buyer, and seller; and information on logistics such as routes, delivery addresses.

We think this is promising, and that consortia proved that they could improve data provision iteratively once they were made aware of what specific data fields the government wants to receive. Long term, with the right incentives, industry has shown that it can create mechanisms to collect various desirable data fields from supply chain participants. For example, HMRC gave specific requirements to the Chainvine-led consortium who were able to amend their system of record and update their dashboard to include further fields[footnote 3].

There were a small number of data elements, specifically required by the government in order to administer control processes but which didn’t always appear in commercial documents. These data fields are either used uniquely when submitting data into government or are generated during interactions with government border processes (like reference numbers). Examples are shown in the table below.

Table 6: Data elements required which may not typically appear in commercial documentation

We observed a spectrum of coverage for these sorts of data in EoT systems during the pilot: those systems designed to submit customs declarations and SPS pre-notifications generally provided more complete coverage, while the remainder provided support for those data elements relevant to the core functionality of the software. The specialist nature of these data items means there is little scope for full automation, although we noted a number of ‘helper’ facilities like look-up lists, detailed guidance, or Artificial Intelligence (AI) based initial calculations, for human review, aimed at reducing the effort required in this area.

Improving access to commercial documents offer several advantages beyond the better quality covered above, including:

Long-term, once we have established solutions to accessing industry data and overcoming technical barriers (at Chapter 6), we can see a set of likely steps on a pathway to transforming the border.

Table 7: Pathway to transforming the border

The UK government maintains its requirements for structured, declaration data to meet border requirements, but industry systems are organised to allow the generation of that data with a greater level of automation, and therefore lower level of ongoing costs than at present.

This is the least ambitious first step, where EoT systems establish a more efficient mechanism for supplying the existing, entirely unchanged declaration processes and formats. This would require no changes in the government’s approach, and this could be pursued by businesses independently of any improvements the government makes at the border.

A hybrid approach is where key documents are fully digitised (e.g. those relevant to pre-arrival notifications) with some essential data elements being submitted, or pushed into government systems.

Other elements of government data requirements could be accessed from industry systems if and when needed.

The hybrid approach represents a potentially realistic model with scope for realising benefits for industry and government. This approach would involve establishing new data pathways into government that can run alongside the existing declaration processes, while also allowing experimentation on the exploitation of supply chain data to the mutual benefit of trade and government. These facilities will be new, but it is possible to create them with modest amounts of investment and in a progressive manner that will allow us to make progress towards reducing trader burden without creating a lot of disruption or risk.

Most radically, where systems can make the relevant business documents available to the government then it might be possible to eliminate the need for separate declarations, perhaps in the context of a Trusted Trader scheme.

Our assessment is that the most radical vision, where users of EoT systems might be taken entirely out of the existing declarations process, is a long-term vision and extremely difficult to do quickly due to the costs, complexity and disruption involved in establishing the new approach, in addition to resolving all the current blockers described in this report, such as the provision of data fields not exchanged in the commercial process in Table 6. In particular, established, largely automated processes relied on by trade and government to expedite movements across the border (for instance, customs clearance) are based on existing declaration data structures and would need to be redeveloped. Plus alternative solutions would be needed to replace those aspects of the S&S and biosecurity controls that rely on structured pre-arrival data.

During the pilots several consortia used their close ties with international partners to make additional information about goods movements available to the UK government, which was assessed by departments and border agencies. In order to achieve secure frictionless trade, it is critical that data exchange models extend beyond the UK border to include competent authorities and trading partners in other countries. Key benefits to this approach are:

The DBM-ATC consortium deployed “TLIP” infrastructure to capture supply chain documentation and events for a number commodities including coffee, tea and flowers. TLIP in Kenya is integrated with the Kenyan Government’s ‘KenTrade’ single window platform which provides access to international trade documentation by ‘pointing’ to the actual records, such as the original export declaration or e-phyto certificate, avoiding the need for duplicate entry.

The Accompanied RoRo team in BF assessed a subsection of these data elements, including key location events such as arrival and departure from ports that are relevant for targeting and were new to their processes (see table 10). Data elements that were not assessed were either irrelevant for targeting purposes, or were already available to BF targeters through other means.

Table 8: Supply Chain Documents Present in TLIP for Coffee, Tea and Flowers

The table below shows which administrative documents originate from competent authorities in Kenya. These government documents are made available 3-5 minutes after they’re created in government systems and - during pilots - were available 3 weeks in advance of goods arriving at the UK border on the TLIP platform.

Table 9: Documentation shared by Kenyan authorities

In addition to better quality and timely data, additional assurance such as due diligence, and other corroborating data can be collected and shared from international partners.

TLIP provided BF targeters with a ‘consistency check’ for a number of consignments to highlight where there were critical differences in specific data fields across a number of documents in the consignment journey. For BF the data consistency checks provided key indicators for a movement’s legitimacy, specifically where data fields were consistent across all documents, and the type of documents provided offered increased confidence (official documents – Health Certificates etc). Discrepancies across certain data fields may lead to quicker intervention decisions, allowing a much faster assessment. Additionally, consistency checks allow for a much quicker assessment, avoiding the need to access individual documents in order to confirm consignment data, with the ability to check specific documents where appropriate.

TLIP currently collects data from Kenya (tax, customs, SPS, standards agencies) but has planned activities with Tanzania, Rwanda and Uganda (SPS), Port of Rotterdam, Belgium, Dubai and Germany offering further opportunities to scale the evidence-backed value of making available high quality and timely data from a broader range of international jurisdictions.

Given the benefits highlighted in this chapter, it’s clear that we need to work with international partners. Recommendations for how we do that are in Chapter 6.

We have tested various augmenting technology capabilities during the pilots, although not as many as consortia offered us, given the complexity of defining use cases and operationalising the pilots.

In summary, while all devices aren’t by themselves a panacea and tests showed that they could be circumvented by determined criminals with various degrees of effort, the devices are still useful because:

We think augmenting assurance can combine with other capabilities to form an ecosystem of trust which collectively gives the government more confidence in accrediting reliable actors. That model is explored in Chapter 4.

We have assessed a number of technologies with information about the identity and integrity of the goods being moved, testing them in conjunction with new data capabilities. We considered how these technologies might help answer some of the questions considered as part of the controls operating at the border:

Issues around goods’ integrity:

Issues around goods identity:

We have also assessed the threats, hazards and risks present at the border as well as the mitigations and controls adopted by the responsible departments. The status of the testing done on augmenting technology is shown below in Table 10.

Table 10: Testing status of augmenting technology

Many of the EoT deployments use internet-enabled devices (also known as Internet of Things or IoT devices) to help secure and track the movement of goods. These IoT devices can be broadly classified into two categories:

Two types of “passive” devices (i.e. devices that do not require a power source) are used:

Figure 3: Container with smart seals, electronic labels and sensors

Top left: Smart sensors - placed inside the container (i.e. the roof) GPS enabled, premitting the same type of location features as smart seals, and are also equipped with environmental sensors (light levels, humidity, temperature etc.).

Bottom left: Electronic Seal placed onto doors. Radio frequency device transmits information when scanned by a portable reader device can alert the scanner that the seal was broken.

Top right: Chainvine - Electronic labels placed in the contents (i.e. boxes, pallets and individual products). Generally contain a QR code, URL or radio frequency devices that, when scanned, will redirect the user to a website and provide information about the goods or provide approved service users to submit or review other data related to the item such as data about the production, distribution, status and location of goods.

Bottom right: Smart seal placed on doors - provides geo-location, lock tamper evidence, remote control features: remote unlocking: updates to status reporting frequency. Can typically record opening or tamper events and detect when equipment enters specific locations.

Vulnerabilities at the border can arise where goods are routed through international locations outside of our control or because of criminal activity in the supply chain. Goods moving from Europe, particularly via the Short Straits, can often be ordered, loaded and dispatched on the same day. Therefore timely pre-arrival data about the goods, route, transport equipment and supply chain participants is of critical importance.

Government prioritises risks according to the National Control Strategy, which sets out priority high risk categories (for example, drugs, cigarettes, and weapons). In many of these cases, augmenting technologies could be useful. For example, in tackling smuggling where an organised crime gang might operate part of a supply chain using unaware logistics companies (known as piggybacking or rip on/rip offs); or in tackling an insider threat where staff working in an official capacity, or with responsibility for organising aspects of the supply chain, are compromised and assist with the movement of illicit goods.

Devices may be able to support risking for specific threats. Instances where a ship has been targeted, and where intelligence to say it has been attacked is available, combined with a triggered seal, could help BF narrow down the search for the offending container.

Smart seals devices can also help mitigate against the risk of substitution of goods as this generally requires the doors to be opened. However this does not apply to rip on/offs and piggybacking where they do not disturb the doors for access into the container or do not require container access.

Historical data from devices may help with forensic analysis after a successful intervention to identify possible patterns of behaviour that inform future targeting.

While devices could help, there is limited potential for mitigating these risks due to the ways that determined criminals can circumvent the technology:

Some consignments of goods are kept under customs controls after the goods leave the port of entry. For example, goods moving under customs transit, to a customs warehouse, or selected to attend an inspection at an inland location.

Technology could help the government reduce the risk of these goods being unloaded or substituted before officials have an opportunity to examine them, by providing information on tampering, unscheduled stops, and diversions to customs authorities. This information could help inform if an intervention is necessary and the nature of an inspection when required. The information gathered could also inform subsequent investigations and profiles of non-compliant trade set out in trade analytics below. The financial benefits that could be made available, in principle, when technology can secure the integrity of a load is further explored in Table 16.

Customs processes can generally be conducted away from the border, but it is sometimes necessary to select movements for compliance activity. A number of factors are involved in deciding when to apply controls, including whether there is correct information about the origin and destination, and the potential for interference with the goods en route.

Smart seals are already used in some industries to ensure the integrity of goods while they are being transported. These devices typically incorporate GPS trackers - allowing the movements and speed of the vehicle carrying the goods to be recorded - and tamper alerting features that can report if the seals have been cut or damaged. Electronic seals, which can cost a few pounds and are less expensive than smart seals which can cost hundreds of pounds, provide a software record of tamper events and a rudimentary form of tracking based on the locations where they are scanned. But there are challenges. As explained above, these devices do not present a serious obstacle to organised criminal groups intent on unloading or substituting goods prior to an inspection.

A European Commission sponsored investigation into the use of smart and electronic seals as part of Common Transit Convention (CTC) is underway. This exercise is considering if this type of technology can augment or replace parts of the current process which relies on vehicles following a pre-agreed route and travelling between customs offices within predicted timescales. Work to-date has focused on a review to ensure there were no legal obstacles to the use of electronic controls, and an audit has been initiated to determine how electronic seals are being used today by participating nations. After the audit is complete, work will move on to assess the implication for other EU technology initiatives like the EU Single Trade Window and a review of what data and device standards would be useful in assuring successful adoption of the technology. HMRC are representing the UK in the working group along with several other nations and have been feeding back the findings from this pilot exercise.

Furthermore, there is also a separate piece of work on going about standardisation of smart and secure seals as part of the World Customs Oragnisation’s SAFE Framework of Standard (FoS). In the existing review of the SAFE FoS, the UK also proposed some amendments in the interest of supply chain security and the integrated customs control chain, in particular to ensure a fully secure movement from stuffing of the container to release from customs control at destination. The UK proposed that customs should apply a seal integrity programme based on the use of smart security devices or high-security mechanical seals as prescribed in ISO 17712 at the point of stuffing, including procedures for recording the affixing, changing and verification of seal integrity at key points, such as modal change.

The integrity assurances offered by devices are relevant to aspects of the controls related to the import of germinal products, animal products, and plants and plant products, covered by SPS controls.

SPS controls specify the allowed temperature range for transporting chilled and frozen goods. Should officials conclude that the correct temperature has not been maintained during transportation, goods may be destroyed or rejected. Maintenance of temperature conditions during a journey is often referred to as cold chain management.

Temperature measurement devices are standard on refrigerated units and - when accessible via the reefer control panel - data logs are accessed by some port officials conducting SPS checks at the port as a way to identify possible issues during the journey. This provides additional information to the testing done at the port which can only assess the temperature at the point the inspection is done at the Border Control Posts (BCP).

The devices used in the pilots, however, are internet-enabled and this allows for the possibility for remote monitoring and reporting. We tested a number of these devices and associated monitoring software during the pilot and they were shown to measure temperature conditions within a unit, periodically broadcasting the status to central monitoring software where the data could be viewed in dashboards or via software interfaces and data extracts. Some of the systems were capable of sending automated alerts, for instance when temperature went outside of specified thresholds for a set period of time.

The technology is mature: for instance, smart containers - where cold chain management is built-in or retrofitted to refrigerated containers - have been in use by large carriers to enable remote monitoring of the status of the refrigerated units on vessels and alert crew members about any equipment problems for over a decade.

We heard from a number of industry experts that, while cold chain failures do happen (either because of equipment failures or human error) it is not a regular occurrence. Defra has analysed data made available by some of the ports on the causes of Products of Animal Origin (POAO) consignment rejections and found that between 2% and 10% of the goods rejected are because of cold chain failures. The method of transportation is assumed to have an impact on this rate, with airports reporting higher rates of rejections due to temperature not being maintained. This analysis only considers consignments from countries outside of the EU and as such there is also potential for more frequent occurrences in goods travelling from the EU which may not be insulated to the same extent as products on longer journeys.

Consideration also needs to be given to the value of the above challenges being resolved. Veterinary advisors working at BCPs explained that cold-chain integrity is only one aspect of the work undertaken by officials when assessing whether goods entering the country comply with SPS controls. Other aspects of these controls are not assured by this type of technology, for instance, checking that packing is intact and the goods match the health certificate.

While cold-chain management devices demonstrated maintenance of cold-chain during transport, they did not demonstrate that the goods were safe from either a food safety or biosecurity hazard standpoint at the point of loading. Therefore, this technology might reduce the frequency of checks for trade adopting them, but on its own it does not eliminate the need for physical checks.

In some jurisdictions, electronic labels can be used as an alternative method for supplying information required by marketing standards. For example, pending changes to the labelling requirements for wine produced or sold in the EU after December 2023 will require the inclusion of ingredients and nutritional information on the label. EU legislation allows for this data to be provided via an electronic label (a QR code that takes the user to a website that lists these details, for instance). Legislation in other jurisdictions allows for e-labels to be used to link to safety and usage data about goods like medical devices.

Legislation allowing e-labels for marketing standards often prohibits the use of the linked websites for advertising purposes, and we saw demonstrations of how consortia systems, operating independently of the producers, importers and exporters, can provide ‘clean’ platforms that help traders comply with these requirements. We also saw how related services can be built that allow multiple supply chain participants to view or submit data relevant to the goods, for instance commercial documentation or data related to the current status and location. These services can be permissioned so that users of the systems only see certain data points, and can participate in workflow based on events occurring inside the system. A proof-of-concept implementation run during the pilot showed how a government official might access the system and submit an enquiry to instruct supply chain participants to take action so that the query can be resolved.

Some of the devices included in the pilot were able to measure environmental conditions beyond the temperature inside a container or trailer, such as measurements of CO2 and humidity. These sensors are primarily useful for quality purposes and do not form part of the Official Controls related to SPS controls.

Electronic labels create a link between physical packaging and data related to the sale, routing and provenance of goods being moved. This information is relevant when assessing the impact of biosecurity or health incidents since it can help identify goods subject to a common issue but despatched to multiple locations, and can help authorities trace back to the area where problems originate. Although we saw demonstrations of the technology being used, there is insufficient evidence on the basis of the pilot to confirm its potential value to the government or to understand how this might turn into benefits to trade, as this information is already currently recorded on EHCs.

The provisioning of electronic labels and potential for due diligence capture as they are scanned across the supply chain present interesting possibilities in terms of an understanding of what is moving and its condition at multiple points in a goods movement. One aspect of this is a low cost and low friction way to incrementally accumulate information about goods rapidly via mobile devices.

Origin of goods is important for customs, SPS and biosecurity purposes. Electronic labels could be used to support evidence of where a product was produced. The technology is already used on products such as wine and spirits, to inform consumers about the regions, ingredients, conditions and alcohol content of the wine.

Electronic labels could enable the government to access data and communicate with the supply chain. The smart labels can be scanned by authorities and link with producers’ systems to view records such as certificates, invoices and transportation documentation. Each department would be able to view documents and information most relevant to their needs. During the pilots, we were able to scan a code with devices which linked into the consortia system.

An additional functionality of enabling the government to place queries, questions and updates on the traders systems was being developed to open channels of communication between producer and UK government.

Goods moved through the UK but destined for a third country are currently subject to controls at the point of entry and exit. In principle, it might be possible to reduce elements of these controls if technology could be used to provide assurance that goods were not unloaded during the journey through the country. Transit movements were not in scope for the pilot and so this hypothesis was not further tested.

In theory, government agencies could use telematics from smart devices to build profiles identifying trading patterns of non-compliant trade. This could inform Trusted Trader scheme enrolment decisions or help identify emerging hazards, and provide part of an overall picture of assurance alongside environmental sensors and smart seals. Government and industry experts agreed that while this was out of scope for the pilots, it was an interesting development, of which, we would need to seek out examples of real-life application to consider whether sufficient benefit could be drawn out to make investing resources worthwhile. There would also need to be further consideration into the handling, storage and access of the data involved.

Seals - whether smart, electronic or mechanical - provide evidence that no persons have had access to goods after loading. On their own, these do not provide a reliable means of assuring the identity of the goods loaded match the accompanying paperwork. Instead, assurance is required to confirm the status and identity of the goods before sealing. This could be from a trusted or accredited person/company who guarantees the goods are what was declared and witnesses the goods being loaded.

Development of technical features can help mitigate the risk that devices might be misused, either because of human error or deliberate attempts to circumvent them. For example, permissioned devices can only be opened/closed by approved staff and allow control over who can apply the devices and provide an audit trail identifying who, when and where the devices are locked or unlocked. Other features deal with cybersecurity threats aimed at internet-enabled devices.

These developments go some way to mitigate the risks associated with incorrect device usage, however it is expected that other assurances will be needed to provide confidence the devices are being used correctly. For example,assurances gained during enrolment into a Trusted Trader scheme where an assessment could be made of the organisation’s quality control procedures and approach to staff vetting and training.

For agrifood, third country agreements allow veterinary officials associated with a nominated competent authority to sign-off on export health and phytosanitary certificates to confirm the goods comply with import regulations. This offers assurances that the goods are correct when they are dispatched, but does not guarantee goods will not be altered in transit. The existing health certificate process does not rely on smart technology, although it could be improved by digital signatures for instance which allow officials to electronically “sign” a document. Digital signatures are a mature technology and widely adopted, however, they are not permitted in the current Official Controls legislation which still requires wet signatures and stamps to be used. Defra is aiming to adopt digital signatures as part of the Target Operating Model.

There are challenges to using devices as part of government control processes:

Given that it is unlikely that process controls can entirely eliminate the possibility of false alarms due to malfunction or incorrect usage of devices, efforts would be required to ‘calibrate’ the reliability of the devices so that the costs of responding to false alarms could be balanced against potential improvements to government interventions on non compliant trade.

Telemetry data from augmenting technology could be used to corroborate other information sources and build a clear picture on the status of moving goods.

There was no scope for integrating telematics (the data generated by augmenting technologies like smart seals) with government systems during the pilot, with data instead made available primarily via dashboards and data extracts. The information captured is based on expert opinion from government border agencies as there was no data integration during testing.

In a scaled model, regulatory authorities and other participants would need to access existing and new categories of supply chain information in a number of ways, including via online dashboards alongside APIs (system-to-system technical interfaces), and potentially other operational and historic data transfer methods.

Departmental teams expressed different preferences for how new categories of information could be used in an operational context where volumes can be large. However there was general consensus from UK government experts in risking and compliance that it would be preferable for information to be available via both traditional means (e.g. batch, dashboard and API) and via notifications that specific activities or events have occurred. Some teams would not want to receive new information unless a problem is encountered by one of the consortia systems i.e. by exception.

Departments also have an interest in accessing telematics data generated by augmenting technologies in internal systems. We heard that the data has potential to play a role in a number of government activities, including refining risking and targeting decisions, supporting Trusted Trader arrangements, credibility checkers, and audit and investigation. Further data analysis would be needed to understand and calibrate the data against these use-cases and this would require investment in new government data capabilities and access to the larger data sets that were available in the pilot.

This chapter sets out how the capabilities tested in our pilots can be organised into a new “Ecosystem of Trust” border model, as well as how industry and government would need to collaborate to bring about this model.

This chapter also highlights a particular learning from the pilots which is encouraging: we have found new methods by which it’s possible for government to access and use commercial data for compliance purposes without putting burdens on the supply chain, and those new methods can co-exist alongside existing patterns where the government leverages industry data through APIs and third party software.

Taking advantage of cutting-edge technologies and real-time data helps the government better assure the movement of goods across the border. Automated assurance and reliability can help to build and ensure trust between actors, creating an “Ecosystem of Trust” (EoT) that could allow processes to be moved away from the physical frontier and alleviate burdens on traders without compromising the UK’s security or biosecurity.

The EoT model is an organised collection of capabilities and participants operating at and around the border. Each part of the model aims to remove border frictions while improving biosecurity and security outcomes. While the pilots assessed particular elements in isolation and with limited integration into government systems, they demonstrated the potential in organising capabilities, people and information in a mature, scaled EoT model.

The strategic vision of the EoT is that, by working with industry to harness innovative technology, we can create a frictionless import/export experience for compliant and trusted traders and enable enforcement of controls to be more focused on traders deemed to be of higher risk.

Figure 4 represents an illustrative EoT which involves industry supply chain actors and one or more regulatory authorities.

Ecosystem of trust deployment which focusses on the following:

It has the potential for frontline regulatory port systems to receive precise timely data relevant to specific location and control regime and for the Single Trade Window to collect data in a standardised format and effectively makes accessible to regulatory authority systems.

The steps are explained in detail in the table below.

Our findings suggest the most effective way to scale an EoT across industry and government will be to progressively build out the model starting small with supply chain data feeding into a single compliance regime. The impact of the additional data on that compliance regime can then be evaluated which may lead to improvements over time, such as by adjusting what data is provided, and when it’s provided, through positive feedback loops. The model could then be scaled further by expanding the use of this data into multiple compliance systems and integrating further sources of assurance.

A more mature EoT model will be able to aggregate and corroborate information or assurance from multiple different parties. Examples of what the model could include are: data from augmenting technology such as sensors and smart seals, results from due diligence checks (like those tested in the pilots e.g. Retail Asset Solutions as part of the Fujitsu & DBM-ATC consortia) or supply chain actor compliance organised by financial institutions (such as Know Your Customer).

While the EoT model is building up, there will need to be a lot of collaboration between government and industry to explore the necessary assurance and interoperability requirements required to deliver benefits to all parties. Mechanisms like the Ecosystem of Trust Interoperability Working Group, which was established during the pilots and brings together government and industry to discuss and “solutionise” these issues, will need to continue.

Further detail of the components of an ambitious model and a visualisation of how the model operates in a collaborative and progressive environment between government and industry is shown in Annex D.

During the pilot we started to experiment with new ways of exchanging data between supply chain participants and the government, one of which we called “signals”.

Signals are simple messages that can be exchanged between organisations to indicate that an action has been taken or that something has been decided. It is not necessary in every use case to move a large footprint of ‘raw’ data. In the context of international trade, a vast number of events are generated and it is not necessary to broadcast every one of these and all associated data. To illustrate:

The signals approach has advantages:

The pilots’ Interoperability Working Group made progress establishing a draft data format for signals and sketching out a simple protocol that sets the ground rules for signal message exchange. If taken to completion this work would explore how government could take advantage of novel supply chain information and insight which is very likely to be useful in addition to more usual forms of information.

EoT development has the potential to improve the UK government’s ability to monitor and manage imported food and feed safety risk, with significant benefits if exchange of intelligence and communication could be made more seamless and timely. To deliver this aim, government should progress essential data governance work and co-develop the required shared information exchange infrastructure. There are numerous opportunities where government departments, PHAs, local authorities, labs and industry could develop and improve how information is exchanged for mutual benefit.

Example operational use cases include:

Feedback loops for food and feed sampling results: If any EoT stakeholder receives unsatisfactory sampling results, they could be shared quickly to all other relevant parties through signals. Those stakeholders could then target their resource to conduct further testing on the products identified in the original signal, sharing their results back to all parties through additional signals. The FSA could then use all the additional data generated to help ascertain whether there is a systemic issue that requires further control, or if initial results found were just an isolated anomaly. This collaborative working would make the best use of resource to protect consumers, maintain confidence in the market and help ensure import controls remain targeted and proportionate.

Lab results: Labs used for port samplings use the Laboratory Information Management System (LIMS), PHA have Port Health Information Management Systems (PHIMS). Currently PHIMS engages with ULIMS through an intermediary system. The feedback loop for the LIMS outputs to other PHAs dealing with similar imports will be valuable particularly around signals for failed samples rather than sharing raw data. There’s also opportunity for FSA/UK government systems to retrieve relevant data (e.g. for intelligence gathering). Sharing the raw data would create more complexity in controls and require a larger number of agreements to be in place. The pass/fail results could be shared within an ecosystem to help better targeting of risk, facilitate feedback loops and address issues like port shopping.

PHA interventions on non-compliance: PHAs will undertake a number of checks at the border (e.g. identity and physical checks). The ability to share non-compliance insight rather than raw data with other PHAs, BCP, LAs, FSA, and Defra in a timely manner, particularly for RoRo loads which move quickly will enable faster interventions. The signals outlining the business details and the nature of the non-compliance generated in this process will enable the updating of the risk models and targeted risk interventions. Sharing details of business non-compliance efficiently to all relevant border agencies across the country would help mitigate negative impacts of potential port shopping (traders avoiding targeted controls due to local intelligence not picking up historic non-compliance occuring at other ports) or traders using triangular trade routes to avoid controls (where goods real origin, which dictates whether controls are applicable or not, is obscured). There might be some quicker wins with this use case by linking with existing systems or systems in development.

$CTAThe pilots established the potential economic ‘size of the prize’ that could be released from an EoT model, or specific capabilities. The purpose of this analysis is to be used as a benchmark against which to compare costs, in order to inform the scope and scale of a future model.

In summary, there are a wide range of benefits from an integrated data source that is immutable, secure, shared with correct access controls in place and trusted across the supply chain.

There are benefits for industry: reduction in data duplication and the need to manually enter data yields a corresponding reduction in administrative overhead and submission errors, simultaneously improving data visibility, traceability and tracking. There are also benefits from increased facilitation to businesses that demonstrate that they fulfil the UK government’s data and assurance requirements.

The EoT could apply to many different types of declarations but we have used customs declarations as an initial test case at this stage. Based on the most recent published estimates the costs of individual import customs declarations are between £20 and £56 (note these 2018 estimates may not reflect the current costs experienced by traders). Our analyses suggest that the EoT could result in between £15m - £225m of benefits by reducing the costs of customs declarations for traders.

Based upon data from one BCP importing goods from non-EU countries, we have established that up to 13% of rejections could potentially be prevented utilising aspects of the EoT model, with the potential for an additional 49% to be added to this category pending further testing.[footnote 4] Given that a quarter of imports of SPS goods currently experience delays at the UK border[footnote 5] - with knock-on consequences for product spoil - this benefit is significant.

On a macroeconomic level, the costs to industry of paperwork associated with border crossings could be reduced by 75% from digitising border document processes.

Earlier chapters set out what the benefits to the government might be, as better data improves risking systems and provides opportunities for border efficiencies. For industry, there is a spectrum of benefits, from time and cost savings of data automation, reduced rejections and disruption through to other benefits summarised in the figure below. In order to release these benefits, stringent assurance criteria will need to first be met. These “hypotheses” and their associated value are discussed further in the remainder of this section of the report.

Figure 5: Theoretical framework for EoT benefits

Indirectly submit information to HMG through an integrated supply chain data platform which replaces the standard declaration process. The administrative burden associated with submitting declarations is reduced.

Encounter fewer or faster checks as trusted traders. HMG risks more effectively pre-arrival. Reduction in time and demurrage costs.

Experience fewer rejections and product spoil with faster clearance and HMG advanced view of richer pre-arrival data.

Experience higher supply chain resilience and certainty reducing disruption to business activity.

Receive advance view of richer pre-arrival data resulting in better ability to target the highest risk consignments and more efficient resourcing for both HMG and Ports.

Act on more timely, more rich pre-arrival data. Time taken to validate documents at the border reduced.

Improved policy making from improved transmission of data across government/agencies.

Access verifiable data showing the provenance of goods. Meaning a better ability to establish authenticity, enforce compliance, and raise ethical or ecological practices in production.

Produce better security, fiscal and biosecurity outcomes as a result of improved targeting at the border.

Experience a smoother flow resulting in less GHG emissions. Experience a better border experience resulting in macroeconomic benefits.

More ambitiously, data and technical capabilities providing new assurance to the government in lower friction ways allows government to reduce the burdensome mechanisms through which risks are controlled. Industry providing more assurance allows government to make changes to provide further facilitation, alleviating trader pain points. This is important as part of making an EoT model attractive to trade. We worked with departments and agencies to define what data they would need to receive before they could release facilitations and set out some examples below to illustrate the sequencing involved in solving tech challenges before we can implement ambitious policy facilitations. These “hypotheses” and their associated value are discussed further in the remainder of this section of the report.

Our analysis has aimed to establish the potential economic ‘size of the prize’ that could be released from this ecosystem of trust model. The purpose of this analysis is to be used as a benchmark against which to compare costs, in order to inform the scope and scale of a future model. There would be significant costs involved with scaling up and operating an EoT model, as demonstrated in the figure below.

Figure 6: Theoretical framework for EoT costs

A fee charged for traders utilising Supply Chain Data systems, which would likely be a combination of fixed and variable fees. It’s also important to consider integration costs.

Some traders may choose to pay to integrate Consortia functionalities into their existing supply chain systems.

Creating and running IT systems required to enable the EoT and associated schemes, including any automation of current processes. Staff would be required to manage and review data, although this cost may be offset from some border processes being automated.

We have been provided the following evidence from consortia on the indicative hardware and licensing costs associated with their technologies.

Indicative evidence from the pilots suggests that telemetry devices (in this example, smart seals) are typically either bought outright and then integrated with consortia platforms for a fee or leased from consortia for a monthly fee. Devices bought outright can range from £8-£328 in cost, depending on the configuration required. The cost of other telemetry devices may fall outside the upper end of this range. On top of this, there would be a fee charged to traders for the data from their smart seal to be made available in consortia platforms, which could be up to £13p/m. Alternatively, traders are given the option of paying a fee of £13-£41p/m to use devices provided by the consortia.

Device lifetime varies with device type and capability, with evidence suggesting this could range from 300 hours up to 3 years. Additional costs for consideration in relation to telemetry devices include the charging and recovery of the devices, which would be incurred between uses. At lower price points where the devices are not reusable there is also a need to consider disposal from an environmental standpoint.

Initial, anecdotal stakeholder research suggests that small to medium sized enterprise (SMEs) are currently less likely to use technology such as smart seals and smart containers. Some consortia who provide dashboard services already said that they do have SMEs in their customer database, but no numbers have been gathered nor is it clear what products these customers import. Although the pilots were aimed at benefiting these SMEs, research and consideration towards these businesses would need to be given to understand if the scheme would be beneficial and viable for these traders if they would need to provide upfront funding for technology required.

For the use of supply chain data platforms, traders are typically charged a platform fee and an additional fee based on the frequency of their usage of the platform. This usage fee varies greatly depending on the size of the trader, and the scope of the platform under consideration. Some consortia also have variable fees dependent on the type of platform access traders would like.

The UK’s SPS[footnote 6] regime process includes pre-notification, documentary checks, and examination - identity, physical checks and sampling.

Pre-notification is required and mandated for live animals, Products of Animal Origin (POAO), High Risk Food products Not of Animal Origin (HRFNAO), and for Plant & Plant Products (P&PP) that are regulated and notifiable. Live animals were not under the scope for the pilots, and so are not considered further. In theory (by legal default), P&PP pre-notification must be made at least four working hours before consignment arrival at a UK port for air and RoRo freight and at least 24 hours before consignment arrival at a UK port for all other forms of freight. For animal products, by legal default pre-notification must be made one working day in advance of arrival, or four hours if there are logistical constraints.

The documentary and identification cross referencing check is the first key stage in the assessment of compliance with import conditions. Under the Target Operating Model, a risk-based approach will be applied to SPS imports, and controls (including documentary checks, ID and physical examination) will be appropriately weighted against the risks posed by both the commodity and country of origin.

All consignments require some form of border process as part of the SPS regime. Examinations have three elements; documentary checks, identity check (this can involve a seal check which is mandatory for some Animal By-Products (ABP) and physical checks which can include sampling.

While the majority of checks are compliant, those which are non-compliant require more time to process and bring to a resolution as there are legal processes to follow.

Data suggests that approximately 12% of pre-notifications for HRFNAO and POAO goods are made after the consignment arrives at a UK Port, for checks by the Port Health Authority (PHA) or APHA.[footnote 7]

Late pre-notification can cause delays at the border - for example, based on anecdotal evidence (applicable to LoLo consignments) from APHA:

A significant amount of PHA and APHA effort associated with the documentary checks is to bring the consignment into compliance by raising queries, seeking amendments, or additional documents. Suffolk Coastal PHA estimates that 9% and 26% of all HRFNAO and POAO documentary checks require PHA intervention to bring them into compliance respectively.

For examinations (i.e. identity checks, physical checks, and sampling) within a deep-sea container port,the logistics associated with the movement of containers is provided by the port operator. The presentation - the time from when a container is requested to when it is moved into the BCP for inspection by the PHA or APHA - can range between 2.4 and 5.2 days.[footnote 8] These times are applicable for LoLo transport, and are likely to differ for RoRo.

Temperature sampling for analysis, laboratory testing, or diagnosis may also be required. Where samples are taken, they are submitted to an approved/accredited laboratory for analysis, or - under certain circumstances - can be analysed on site. The time taken for the laboratory report will vary depending on the product and the analysis required. Suffolk Coastal PHA has provided us with figures that suggest sampling time can range between 2 and 15 days. Analysis of FSA data suggests that on average, around 13% of HRFNAO consignments are currently selected for laboratory testing. For POAO and P&PP consignments, it is generally assumed that around 10% of consignments that go through physical testing will be selected for further sampling checks.

After all of these processes, there is a possibility that consignments will be rejected for being non-compliant. This could be for a range of reasons - including microbiological contamination, composition, or labelling. Analysis suggests that on average across ports, 2% of POAO goods are rejected, while data provided by the FSA suggests that the average rejection rate across ports for HRFNAO goods is 1.3%. This equates to over 85,000 import consignments being rejected per year (assuming 1.3% rejection rate also applies to P&PP). In almost all cases, this is due to a consignment failing a physical examination or a laboratory test.

Departments involved have given thought to what assurance points they would need in order to issue any new facilitations to trade, and we have been able to match these against the assurance points which consortia are capable of providing. This gives us a picture of how feasible these assurance requirements are for industry to fulfil, before we try to quantify the sort of benefits this would release.

Table 11: Defra and FSA requirements for assurance, and how the consortia meet them

1. Country of origin and commodity code, along with other crucial data fields (specific commodities require additional information, such as dairy products and composite goods), if made available early in the movement of goods, would inform better planning and targeting of resources for operational staff working at the point of entry or to help make adjustments that reflect the latest thinking on dynamic risk rules so that the goods are controlled appropriately.

Summary: All consortia are capable of meeting the requirements of this assurance criteria. Some consortia (Fujitsu, IBM-Maersk, DBM -ATC) are capable of providing this information in a structured format as well as from source documentation, allowing for improved deployment of dynamic risking rules. All consortia are able to provide this information before goods arrive at UK points of entry. This could permit improved planning and targeting of resources for operational staff.

2. Departments receive a notification detailing a single assurance opinion (or attestation) which has potentially been corroborated by other departments or supply chain actors.

Summary: Most consortia platforms are capable of making signals available based on a single assurance point, such as a check that is performed during the import process. Two consortia (Connected Borders, DBM -ATC) are capable of allowing multiple actors, such as departments and agencies, to corroborate and manage actions related to these signals on their platforms, meeting the assurance criteria in full.

3. Greater level of food and feed commodity/product information including details such as batch number, brand, ingredients lists (if applicable) which include origin of animals and other ingredients.

Summary: Most of the consortia did not provide this additional information through their pilots, with the exception of Chainvine and Azarc who manage and deal with regulation associated with highly specific commodity groups. Several consortia described a risk with asking for this additional information increasing unnecessary administrative burdens on the trader unless a clear agreement is made on its collection and usage with the UK government.

4. Cold chain monitoring and smart container technology confirms that appropriate temperatures for chilled or frozen goods are maintained at correct levels. Provide signals to PHA/FSA/Defra identifying where cold-chains are broken.

Summary: All consortia are in theory capable of collecting data points generated by smart devices for cold chain monitoring. Chainvine & IBM collected this data during the pilots. All consortia are capable of setting parameters, or configuring when exceptions should be triggered when an acceptable range has been exceeded. Each consortia can generate this assurance as a signal that is triggered in the event of a deviation and made available to the relevant department or agency.

5. Electronic seals and smart Container technology can provide assurance that consignments have not been tampered with between leaving establishment of origin and UK arrival. This technology can provide signals to PHA/FSA/Defra where unexpected deviations occur on-route.

Summary: All the consortia are capable of capturing data elements related to tampering generated by smart devices on their platforms and systems. Azarc, DBM -ATC and Fujitsu each deployed smart devices during the EoT pilots that were able to determine if a consignment had been tampered with outside of an authorised event. All the consortia, whether they had smart sensors deployed during the pilots or not, are capable of generating a signal based on this type of event occurring. Some consortia recommend that this type of event be captured by exception to prevent large amounts of costly unimportant data being captured.

6. Imported food and feed have electronic labels so if an issue is identified within the supply chain (including inland at commercial premises, labs or consumers) traceability data can be obtained and shared straight away, allowing for incident management to be more efficient and effective.

Summary: All consortia are capable of capturing this data, which is generated through existing industry solutions. As part of a workflow, consortia systems can capture which device scanned the code (ensuring only authorised people use the device), as well as who. This can then be linked back immediately to the relative traceability data and shared to government border agencies.

The potential benefits that could be released as a result are:

Fewer or faster checks could be given to those traders if the assurance were deemed by Defra and the FSA to be substantial enough to ensure overall risk mitigation was sufficient.

Traders could experience fewer rejections and product spoil if government had an advanced view of richer pre-arrival data (albeit this would be dependent upon the consignment and the quality of the pre-arrival data and so is currently speculative). Access and fast response to data provided by assurance technologies on the conditions of a consignment - such as temperature, humidity, carbon dioxide and oxygen levels - could result in reduced product spoil. This is applicable not only to foods which have completely spoiled, but where border processes have resulted in delays and therefore a reduction in shelf life. clearBorder (based on a survey of 300 businesses with experience using the border covering the period January to November 2022) found that in 2022, of respondents trading perishable goods, 24% reported delays at the border. 47% of traders who experienced delays linked this to difficulties moving goods across the UK border.[footnote 9]

From reviewing rejected consignment data for imported POAO goods from non-EU countries received at one BCP, initial analysis suggests that up to 13% of issues seen could be potentially prevented, identified or reduced in number utilising aspects of the EoT model[footnote 10],[footnote 11]. For a further 49% of rejection it is unclear, and would require further testing to conclude, whether an EoT could reduce rejections. This assumes that if business documentation can be made available to government, targeting teams can triangulate information between these documents, certification and pre-notification information. This may allow for corrective action before goods depart the Country of Origin, however this would need to be tested to determine whether this is feasible within logistical restraints. Further testing would be required to comprehensively understand whether a proportion of the uncertain rejections could be preventable and what investment and/or resource would be required to realise that figure. More detail can be found in Annex A.

Improved biosecurity outcomes. With the additional advance data utilised alongside the risking matrix being developed, further steps could be taken to identify biosecurity risks and other reasons for rejection. This could then allow BCPs to apply intelligence-led targeted checks with greater accuracy which could allow for more effective resourcing for both government and ports and could increase the likelihood of biosecurity risks being identified at an earlier stage.

The UK faces significant public health, plant health and animal health risks associated with the importation of goods. An effective import regime is therefore essential to protect domestic food safety and animal and plant health and welfare. It serves to monitor and enforce UK import controls that prevent biosecurity and food safety hazards entering the UK, which can and have had considerable consequences to the UK economy and agricultural sector (see below). With the additional advanced data used alongside the risking matrix being developed, further steps could be taken to identify biosecurity risks and other reasons for rejection. This could then allow BCPs to apply intelligence-led targeted checks with greater accuracy which could allow for more effective resourcing for both government and ports and could increase the likelihood of biosecurity risks being identified at an earlier stage.

Table 12: Socioeconomic impacts of biosecurity outbreaks[footnote 12]

The Foot and Mouth Disease outbreak in 2001 cost the UK an estimated £8 billion and caused widespread damage to the agricultural sector and international trade.

The agri-food sector contributed £116.2 billion or 6% to UK national gross value added in 2020.

In 2021, the UK exported £20 billion of food and drink (6.2% of total good exports).

Ongoing EoT work could help ensure STW enables the required data collection, or data access via government and industry systems interoperating, and enables the FSA and PHAs to utilise the data according to their needs. The EoT pilots have demonstrated that industry is willing to provide data and work with UK government on developing mechanisms for data exchange.

Food and feed safety incident management: Timely supply chain data will allow the FSA and PHAs to quickly track imported products that have been identified to cause harm to consumers (illness or potentially death), as well as identify the businesses involved in the supply chain, which would speed up the process of preventing those goods entering the UK market and/or enable timely product recalls.

Imported food and feed surveillance: Detailed supply chain data would also significantly improve the FSA and PHAs ability to target imported food and feed for surveillance purposes. More granular level of supply chain data will enable relevant parties to target specific foods and feed with the aim of gathering evidence to inform continual risk categorisation. The outputs of improved surveillance capabilities will allow SPS import controls to be more targeted and proportionate, providing the required data and evidence to ensure only the riskiest products are subject to additional border requirements/checks.

Reduction in disruption at the border. Disruption at the border may be caused by time taken to prepare paperwork, to receive confirmation of declarations or licence applications, to secure agents and transport or to deal with unprepared customers and suppliers. In 2022, clearBorder(based on a survey of 300 businesses with experience using the border covering the period January to November 2022) found that 58% of respondents experienced delays with imports, with 47% of respondents blaming these delays on difficulty moving goods across the border and over half of them increasing their expected delivery time by up to 3 days.[footnote 15] The monetised impact of disruption at the border is discussed further in the remainder of this section.

Customs declarations are required for all goods exported from and imported to the UK. Goverment uses this data to calculate VAT and duties owed on imported goods and to compile trade statistics.

S&S declarations are another example of regulatory documentation, currently collected for all goods exported from the UK, while for imports, they are required for non-EU imports and will be introduced for EU imports by October 2024. They provide data for security risking, to protect our society from harm, by detecting and intercepting illegal and harmful goods from entering our shores.

If industry can provide upstream supply chain visibility in a machine readable way, government could potentially conduct more accurate selection/non-selection of consignments for compliance interventions. Systems such as those trialled in the EoT pilots can also help to reduce the administrative burden associated with providing data to government, as existing trade documents can be made available in a machine-readable way (assuming that government can ingest data in this form), resulting in fewer data fields needing to be manually populated.

The ‘size of the prize’ is significant. The below table highlights the volumes of customs import declarations made in 2021.

Table 13: Import declarations by declarant representation and trade partner, 2022[footnote 16]

The potential benefits that government departments and agencies managing customs and security at the border could offer if rigorous assurance criteria are met by industry are listed in the table below.

Table 14: Examples of potential value release from the EoT - customs and security regime

Example 1: Checks could be reduced, and predictability of passage increased, for participating compliant businesses who can provide supply chain visibility to departments and agencies involved in managing the UK customs and security regimes.

Supply chain visibility achieved through timelier, richer, and more assured data, which is machine readable and interoperates with government systems, could enable more accurate selection / non-selection of consignments for compliance interventions.

In principle this would reduce the number of ‘false positives’ and therefore the relative number of checks on participating compliant businesses.

Summary: Industry would need to demonstrate the ability to provide additional high quality structured data to improve upstream and downstream supply chain visibility including:

Full supply chain visibility would be the preferable outcome for government but is unlikely to be possible in all cases. However, incremental improvements in supply chain visibility could potentially enable equivalent improvements in the accuracy of selection / non-selection of consignments. This was not conclusively tested during the pilots and requires future collaborative assessments between government and industry.

Example 2: Checks could be reduced, predictability of passage increased, and friction associated with providing commercial documents could be decreased for participating compliant businesses who can provide digital, machine-readable commercial documents to departments and agencies involved in managing the UK customs and security regimes.

Government could, in principle, automate some document checks of digital, machine readable commercial documents which are interoperable with upgraded government systems.

Summary: Industry would need to be able to consistently share relevant digital, machine readable, interoperable commercial documents. This was not a capability demonstrated during the pilots and would require trade digitisation. Government would also need to build capabilities to automate document checks.

Dashboards used within the pilots did create the opportunity for virtual manual inspections of commercial documents which could provide some limited benefits to businesses who can provide government access to relevant commercial documents through similar platforms before the goods reach the border.

This potential opportunity would have lower technological barriers but would be a resource intensive process for government and provide less benefits to traders than an automated solution.

Further work is necessary to assess the feasibility, scalability and desirability of both potential approaches.

Example 3: Route 2, physical goods checks, could potentially be moved away from the border and conducted at the haulier or consignee’s premises if participating compliant businesses could deploy augmenting technology (e.g. smart seals) which can ensure government of the integrity of the load.

If a load of goods is selected for a physical check, and government is content that the augmenting technology can provide a sufficient level of assurance that the goods will not be replaced or removed, in principle government could allow the load to continue to a secondary location, away from the border, where officials could conduct necessary checks.

This could potentially reduce disruption for hauliers and/or traders.

Summary: UK government needs to be content with the level of security and assurance that the technology provides is sufficient for its needs which would require further testing of devices available on the market and standards used by industry. The information from augmenting technology would need to interoperate with government systems and these systems would have to be capable of communicating effectively with hauliers, consignees and compliance teams.

Example 4: A consortium could self-assess their duty payments. A consortium with Entry in the Declarant’s Records (EIDR) authorisation, and providing a supplementary declaration could complete a declaration in their own records and notify relevant departments before completing a monthly aggregated supplementary declaration (satisfying HMRC trade stats requirements) and an aggregated monthly/quarterly duty payment. The consortium would make the declaration in their own records available, via a dashboard-type interface, where HMRC officials could review them without the consortium’s knowledge. Supplementary declarations could only be aggregated to the degree that they still allow departments to fulfil their functions e.g. HMRC trade statistics requirements.

Summary: The consortia need to demonstrate the ability to successfully aggregate duty payments and data requirements for consignments. Therefore we need to do:

These benefits are discussed in the remainder of this section:

Figure 7: Benefit release from examples

Industry provides trade data which HMG could in principle ingest which provides greater supply chain visibility, upstream and downstream from the UK border to HMG enabling better-informed risking and compliance. Impacts #1-4, 6

Industry provides commercial documents which HMG systems could in principle automatically review, or officials could remotely review without the trader’s knowledge, before the goods are presented at the UK border. Impacts #1-6

Industry could deploy smart security technology which provides HMG with sufficient levels of security of the consignment/ load’s integrity, HMG could allow the consignment/ load to continue to a secure trusted traders’ premises to be held until it can be inspected by officials and/or released into free circulation. Impact #6

Industry with EIDR authorisation could complete a declaration in their own records and notify government before completing a monthly aggregated supplementary declaration (satisfying HMRC requirements) and an aggregated duty payment.

Reduction in administrative burden for traders. The EoT pilots have demonstrated the possibility of making existing trade documents available in a machine readable way. Noting the complexities associated with doing so, if in the future government systems can ingest this data, this could reduce the number of data fields that need to be manually populated as part of the current declarations process, equating to a reduction in the administrative burden to traders.

To quantify the scale of opportunity, we have focused on import declarations as a case study. This is one of many applicable use cases - including, for example, S&S declarations and SPS pre-notification - and as such, the benefits should be considered as only a portion of the total potential reduction in administrative burden from the EoT.

Analysis of data provided by two consortia during the pilots indicates that between 38-42% (with a midpoint of 40%) of the data fields required for an import declaration were made available during the pilots.

The cost of an import declaration ranges from £20-£56, depending on trader size and method of declaration, although these estimates are from 2018 and therefore may not truly reflect current costs. The total number of import declarations in 2022 was 73.4m. The administrative burden associated with submitting declarations is split into an internal and external cost, as follows:

UK government analysis demonstrates that scaling a 40% reduction in the internal cost of submitting customs declarations would result in an annual average cost saving of between £15m - £225m.[footnote 17] The impact on an individual business would be dependent on whether an intermediary is used to submit customs declarations, the type of declarations that are typically submitted and the volume of declarations which are submitted. This analysis only applies to import declarations (rather than S&S, or SPS pre-notification, for example) and can therefore be considered an underestimate when considering the benefits of the EoT in aggregate. The assumptions underpinning this analysis are detailed in Annex A.

Consortia have indicated that if the right commercial incentives were in place, all government data requirements could be made available through supply chain platforms. Building in 20% contingency but assuming all data requirements are fulfilled, Cabinet Office analysis suggests that an 80% reduction in costs would equate to an associated average annual cost saving for traders over a 10-year period of £365m.

Reduction in route 1 and 2 checks for participating compliant businesses. With an EoT model providing sufficient upstream insight, government could carry out more accurate targeting of non-compliant consignments and avoid particular checks (and associated delay/cost for traders). Legitimate trade would be less likely to be selected for customs clearance Route 1 checks, because equivalent checks could be completed without having to engage with traders, or Route 2 checks, where the government could be made sufficiently confident that they are not necessary.

Route 1 checks require all documentation to be sent to the National Clearance Hub (NCH) for clearance.

Route 2 checks also require documentation to be sent to the NCH for clearance, but physical examination of the goods by a Customs Officer is also required.

Better fiscal outcomes. The EoT would enable government to better target all forms of fiscal risk arising at the border and its associated processes. The pilots have shown that it is possible for additional data and insight to be made available for the purpose of “risking” border traffic, providing government with a wider range of risking inputs and thus potentially leading to improvements in identification of issues. The EoT could also enable the UK customs regime to focus its resource-intensive interventions on those higher risk traders that would be outside of the scope of EoT, and hence potentially improve fiscal outcomes at the border and from its associated processes.

Better security outcomes. The UK faces a considerable amount of risk at the border, including national security risks. Border security plays an integral role in promoting the prosperity of the UK, preventing cross-border harms whilst underpinning legitimate business. Of the £37bn (FY 2015/16) in socioeconomic cost of serious and organised crime, border smuggling accounted for a significant portion.[footnote 18] To secure the border, the government uses targeting to more effectively determine when to conduct physical inspections and effective targeting requires advanced data to make the right decisions. Higher quality data can result in more effective targeting, reducing delays at the border while simultaneously reducing harm. Similarly, additional data can be used to corroborate existing sources or reveal inconsistencies, making it more difficult for organised crime groups to evade checks.

Increasing the attractiveness of trade with the UK. A reduction in the burden to traders, and the enhanced protection of legitimate trade - through the EoT - are likely to promote the reputation of the UK border, improving its perceived efficiency and resilience among international importers and exporters. The costs of trading can act as a barrier for some firms looking to operate across the UK border.

On average across the Commonwealth, it costs around £378 for a shipment of £18,148 worth of goods (roughly equivalent to a 40-foot container) to cross borders[footnote 19].

The implementation of smoother border crossings alone would reduce costs to an estimated £72 per £18,148 shipment.[footnote 20] This is an estimated average 81% reduction in border costs.

The amount of paperwork associated with trading across borders costs, on average across the Commonwealth, US$79 (£57) per US$25,000 (£18,148) shipment.

These estimates suggest an average cost reduction of 75% from digitising the processes of documentation associated with border crossing and rules of origin.

If these findings were aggregated, they could enable an additional $90bn (£65bn) in trade across the Commonwealth. This effect could be multiplied through the use of Single Trade Windows and Digital Identities, as these would enable excluded groups to access trade more readily.

Improved view of the provenance of goods. Over the past several decades, globalisation has led to unprecedented complexity in global supply chains, which has brought huge benefits, but also aggravated concerns about disruptions, delays, inefficiencies, or fraud and consequently brought challenges for businesses, regulators and consumers. For various industries within the EU, mandatory frameworks have already been adopted requiring businesses to conduct due diligence on the provenance of their supply chains but for the majority a voluntary approach is relied upon, leading to suboptimal outcomes.[footnote 21] The introduction of legislation does not necessarily equate to compliance throughout the full supply chain. As a result, there is a clear case for the value of a technology driven solution, such as the EoT, to provide a mechanism for accountability. The EoT could provide essential visibility into the supply chain, and to whether a good is being produced legally and ethically. It could reduce information asymmetry in purchase decisions and encourage the parties involved to make more ethical decisions around supply chains/the goods that they choose to consume. The potential benefits are :

Reduced disruption at the border. Disruption can result in significant financial and reputational damage to businesses, and particularly so those which have extensive supply chains. Disruption at the border can happen for a number of reasons, some of which being outside of the government’s control - including bad weather, industrial action, or failure of transport mode, for example. clearBorder (based on a survey of 300 businesses with experience using the border covering the period January to November 2022) find, however, that of the 58% of traders who experienced delays at the border in 2022, 60% cited the time taken for checks on goods,55% problems with paperwork from suppliers outside of the UK, 27% problems with paperwork from their own firm, and 48% a lack of border capacity.[footnote 22]

On average, disruption causes financial costs of between 6%-8% of annual revenue as a result of increases in the cost of operations, delayed cash flows, loss of productivity, and loss of sales and market share. Businesses are as likely to report damage to brand reputation as a consequence of supply-chain disruption as it increases costs of operations: disruption increases the number of customer complaints received, as well as loss of regular customers.[footnote 23]

Whilst a unit of freight is awaiting a check to be completed, it may incur costs. For accompanied freight, the majority of these costs will be generated by the waiting time of the haulier due to a direct impact on the driver’s time.This waiting time will add to the driver’s hours and impact the availability of both the driver and the HGV / trailer assets. Hauliers have now become aware of this situation and are starting to add a ‘waiting time’ rate to their contracts. We estimate that for each hour an accompanied consignment is delayed the incurred costs would be between £35 - £50 per hour.

For unaccompanied freight, the additional duration the consignment stays at the port may result in the following charges:

Table 15: Combined demurrage and detention tariff at all UK ports, terminals and depots[footnote 24]

Table 16: Storage tariff for UK ports, terminals and depots, excl. Liverpool, Teesport & Belfast [footnote 25]

During the pilots, one consortium stated that official checks cause 13% of all consignments to take more than an hour to be cleared to leave the ports in question[footnote 26] and that physical border checks increased UK port and broker fees by up to 234%.[footnote 27]

Figure 8: The impacts of disruption at the border

The EoT could improve current processes and reduce the impact of disruption when it occurs. The benefits of an integrated data source that is immutable, secure, shared and trusted across the supply chain include: reduction in data duplication and the need to manually enter data yields, a corresponding reduction in administrative overhead and submission errors, and improved data visibility, traceability and tracking. The opportunity to perform processes away from the border minimises delays at the border. The EoT could therefore improve current processes, therefore acting as a buffer during periods of disruption. These impacts would be ‘multiplied’ for those traders most integrated in global supply chains.

Businesses and customers have taken a number of actions to mitigate disruption like inventory management and employment strategies, diverse and long-term partnerships with producers, and deeper investment in digital tools. As demonstrated in Figure 9, the EoT could be a valuable addition to this list. Consortia evidence suggests that reduced order to delivery lead-time variability enables companies to reduce the cost of carrying additional inventory. Median inventory carrying costs are found to be approximately 10% of inventory value[footnote 28], presenting a significant saving for traders if inventory levels can be reduced through border predictability.

Example of a trader burden being ameliorated through the EoT model

Trader insight: “We are responsible for helping one of our customers import large amounts of containerised freight into the UK on a daily basis. To ensure that the goods can be unloaded, a physical Bill of Lading is required upon arrival. Frequently these physical documents do not arrive on time and the goods are subsequently held at the port, incurring costly demurrage charges and preventing goods flow. Working with the UK government to improve the use of legally recognised digital Bills of Lading would help to alleviate these issues”

The collation of commercial documents related to import/exports is a challenge for industry because documents are owned by different supply chain organisations working in an international environment that creates timezone, language, technology and related communication issues. The EoT model provides a mechanism for these organisations to collaborate on the provision of data in a way that breaks down some of these barriers and makes possible new incentives to improve data collection and sharing. For instance, documents can be uploaded once by the originating party and at the point they are first created, and then shared onwards with many parties, reducing communication costs for the parties involved.

Figure 9: The EoT and the cost of mitigating disruption

1. Digitalisation of supply chain allows firm to balance a trade off between efficiency and resilience.

Source: Economist Intelligence Unit (2021) The Business Costs of Supply Chain Disruption.

The EoT increases supplier visibility - allowing traders to monitor their suppliers and subcontractors more quickly and in more detail.

2. High revenue firms are equally concerned about reputational damage and increased operational costs of supply chain disruption.

Source: Economist Intelligence Unit (2021) The Business Costs of Supply Chain Disruption.

Closer monitoring of the supply chain and fewer unexpected delays could improve consumer confidence in traders.

3. Inventory optimisation, supply planning and demand planning have grown as a priority for traders.

Source: McKinsey (2022) Taking the pulse of shifting supply chains.

By reducing the overall time taken to cross the supply chain, the EoT allows traders’ to hold less inventory at one time.

4. Large inventories are associated with significant costs, including carrying costs.

Smaller inventories enabled by the EoT will allow firms to be more flexible with their capital and resources

We have established that there are data and technology capabilities with the potential to meet government’s assurance needs and provide value to all border users, and that they ought to be integrated into an EoT model. But getting to a point where these capabilities are deployable at scale is the challenge.

This chapter deals with the blockers to tech and data capabilities’ deployment at scale - technical, interoperability and governance challenges - and what we think government and industry ought to do next to tackle them.

Industry is already using third party software to more efficiently manage their supply chains and provide data needed for current border requirements, including discrete declarations, to government departments. The challenge is to build these data exchange models into a more ambitious and transformative model where we use a variety of methods to get data to departments and where other categories of data (like assurance data from devices) can be added and made visible to the government without undue burdens on industry. We’ll need to address interoperability challenges - like governance - which are currently preventing the model from being scalable, adaptable and flexible enough to suit different user groups. Given the pace of technological change and the stand-up of the STW, it is important that EoT model design is open from the outset.

Accessibility of data proved a challenge in the pilots. Supply chain participants predominantly made unstructured data accessible, like PDF formatted digital files, sometimes accompanied by physical copies. While convenient for trade, unstructured data:

Government systems require structured, machine readable data - organised into separate data elements so that each item can be retrieved and processed separately by software - to enable automation of the processing of official border requirements. Industry and government have a mutual interest in this automation as it allows data to be quickly organised and assessed, and this in turn reduces costs and allows rapid decisions to be made about the status of goods crossing the border.

A number of standards bodies including UN/CEFACT, WCO, ICO and W3C have developed standards which support data interoperability for trade processes. These for example support the exchange of structured digital data in relation to the purchase, financing, shipping, payment and trade compliance regarding the international movement of goods, and digital identity and credentials. Collectively these can provide the basis for fully digitised trade. However, the practical challenges to the standardisation of business data are far from trivial. The majority of the business documents presented in the pilots did not conform to international interoperable data standards and we understand why: ultimately the unstructured (PDF/paper based) approach to exchanging data prevalent in the supply chain today, while inefficient, is tried-and-tested and works regardless of the location, technical maturity and legislative constraints on the organisations involved.

The outcome of limited progress towards cross-border paperless trade means governments continue collecting data for border controls using procedure-specific declaration data formats that businesses must comply with in order to move goods across the border. These requirements often duplicate data contained in standard business documents. The lack of progress towards the use of structured, standardised, fully digital processes for cross-border trade leaves businesses a choice between low-technology solutions (paying someone to key in the data) or integration (arranging systems and processes within an individual business) to capture the necessary data in government-specified structured formats before submitting it to government systems. Both carry a cost to business.

Despite the existence of data standards, legal frameworks and promises of improved business operations, private sector businesses often perceive standardisation as having limited value because:

Although there are challenges getting international trade to move more quickly on the adoption of data standards, the opportunities are significant. Government has taken action and is on course to shortly enact the Electronic Trade Documents Bill. A collaborative effort between standards bodies, government and industry to promote and incentivise adoption is now warranted. Experts in the field project that increasing volumes of commercial supply chain documents will be exchanged digitally. The Impact Assessment for the Electronic Trade Documents Bill projects that 45% of UK exporting firms will adopt trade processes which use digital trade documents within 10 years and many international commercial trade bodies have committed to ambitious targets for digitalisation:

The UK government can help drive digitisation and standardisation of commercial trade data, across both the negotiable trade documents covered by the Electronic Trade Documents Bill, and other key commercial documentation. Government will work through the National Trade Facilitation Committee, to promote trade digitisation, including working with industry to ensure the new opportunities for digitisation, and resulting efficiencies afforded by the Electronic Trade Documents Bill are exploited fully and flexibly, in ways which support goals for wider trade document digitisation.

A further step is welcoming the World Trade Organisation/International Chambers of Commerce’s Standards Toolkit. It is an industry-led and international effort to equip every supply chain participant, both public and private, with the most notable and widely used standards and interoperability frameworks to digitise cross-border trade. The toolkit provides an overview of over 100 available standards, frameworks and initiatives which allows new adopters to identify and invest in the most appropriate standards for their organisation.

The design of data standards reflects the needs of the organisations that use them and - because these needs evolve over time and vary between industries and the local legislative they operate under - we expect new standards to continue to emerge and that others will be deprecated or require ongoing updates to reflect these developing needs. No single universal standard for borders data has emerged that covers all these needs and it is not clear that such a model would be possible given the diverse range of business requirements that must be catered for. We heard from experts in international standards bodies that requiring all international trade and government agencies to update their technology to handle new standards was not a realistic goal given the likely high costs involved. A more feasible approach is to accept that some level of translation between standards is inevitable and to focus efforts on minimising the costs and disruption when it is necessary.

By providing users with a core set of standards, and frameworks for aligning these standards, the toolkit has the potential to enable the parties in global supply chains to make informed choices on standards when purchasing or creating border software, encouraging business to converge on a recommended set of common standards whenever possible. The toolkit aims to promote the use of common semantic data standards that reduce the cost of translating between the data standards where converging on specific standards is impractical. Several UK government departments have already aligned to the toolkit, and a critical mass of more departments aligning to it, would instil confidence in industry and ultimately lead to trade data being more interoperable and usable by the wider economy, which is a key goal of the National Data Strategy. The UK government will also support international organisations in promoting the adoption of these standards and provide guidance and technical information on their implementation to companies wishing to adopt them.

In promoting the toolkit as a useful resource for standard adoption we recognise that some countries have already adopted other standards frameworks (and there are many existing standards, catalogued at Annex C); development of the EoT model needs to take account of this reality. But given the merits of greater global harmonisation of data standards, we believe standards should be internationally aligned wherever possible (e.g. where domestic standards haven’t been adopted and hard coded into legacy systems, or where new categories of information appear that require the development of new standards).

In operating the EoT model, the UK government and trade will need to be able to interoperate with other countries’ data and systems. Therefore, the government will work with other countries to promote and share evidence on the benefits of trade digitisation, and is already in regular contact with jurisdictions with a mutual interest in testing interoperability, discussing future projects with Thailand, Kenya and others.

Some of the consortium members used or were experimenting with machine learning techniques to extract machine readable data from unstructured business documents. A number of techniques are potentially relevant, including automatic document classification, statistical machine translation and the automated identification of named individuals, organisations, places and other entities referenced in unstructured text. Some of these techniques are already used in government risking systems, however this is a technical area that is improving rapidly and needs to be continually monitored. For instance the recent developments in the Large Language Models popularised by services like ChatGPT create interesting potential for summarising and identifying themes in large sets of documents, and for interrogating individual documents to isolate particular data elements of interest. The potential for these technologies, both as an input to human decision making or as the basis for automated decisions, creates ethical and safety considerations and should conform to relevant legislation and government guidelines.

Through the pilots, we learnt what data is contained in commercial systems but the next step is to test whether government systems can use the data that has been extracted from industry documents.

Enable opportunities for government departments to share insights and decisions with one another where this is not possible today without running expensive data integration projects.

Before commencing the pilots, data sharing agreements were concluded between industry and each government department and agency so that industry data could be sent to departments via operational data transfers or accessed on dashboards. This proved challenging and resource intensive for both government and industry. There are a series of legal and governance issues to unpick but overall, in order to effectively operate a scaled model of multilateral commercial data sharing which underpins the EoT model, we need to make the legal/governance issues clear and easy to navigate.

Firstly, the government should explore what powers it needs to collect and use new supply chain data to best suit its border processes. Government may need new powers to collect, use and share (within government) supply chain data as it sets up the STW, and as part of this, develops capabilities for the enhanced data provision from the supply chain. For example, some central government border departments may require new powers to collect additional data from the supply chain and transmit of information from and to supply chain actors (for instance to collect new types of data in an automated way from new sources of information, and providing additional, more granular feedback to supply chain actors). In determining whether legislative changes are required, departments will carefully consider the future data collection activity they will need to operate the EoT model.

Given the number of actors across industry and government who need to access the data it is critical that access control, liability, ownership and other key concerns are addressed sufficiently well by business, contractual and governance arrangements.

The ability to accurately link the digital footprint with the physical movement and ownership of goods is critical to the rapid identification of the source of a problem in a supply chain. As these goods move between multiple parties (exporter, shipper, haulier, importer etc.), building a golden thread of traceability information that can be easily exchanged is a challenging process. Individually negotiating legal documentation underpinning point to point data transfers at each stage of the supply chain is a lengthy and resource intensive process.

Most E​​oT consortia provide their data through a shared system of record. This captures authoritative information incrementally as supply chain actors contribute the data they are responsible for, and provides second hand access (mostly) to ecosystem participants who need to see it. For example, the FSA might want to onward share insights it gathers from supply chain data with PHAs and Local Authorities. Individual point to point data sharing agreements with hundreds of local authorities can make that process of sharing very challenging. Most point-to-point agreements will only allow for information to be onward shared on a case-by-case basis. This approach is neither scalable nor feasible with an ecosystemic approach to information sharing.

The next stage of EoT needs to focus on alternative data governance mechanisms, and governance that is co-designed and co-evolved cooperatively by regulatory authorities, industry and trade associations and other external experts so it meets the needs of modern data sharing.

Industry and government will need to work together to find solutions to the legal issues around new capabilities, including: data access and acquisition, data ownership and liabilities, privacy and permissions, anonymisation, data interpretation and how far data can move in a supply chain. Government will work with the International Chambers of Commerce who have created a core set of techno-legal resources to understand whether these can be endorsed by industry and government. For example, multilateral share agreements (i.e. collaboration agreements) may solve some of these problems for business-to-business and business-to-government transactions, and can be deployed repeatedly in a number of ecosystems. A prototype exists which can be tested with departments and consortia. In the longer term there is industry desire to transition to more digital forms of information governance, with multilateral share agreements potentially governing individual digital transactions in a more adjustable way.

Multiple systems for businesses to share assured supply chain data to support trade processes were demonstrated through the pilots, and some are already making supply chain data accessible to the government. The task now is to open this opportunity to all and to set the conditions for further supply chain data sharing networks, or EoT hub systems. to be created and scaled. Therefore, we have to prioritise producing clarity around what an EoT is and set formal requirements.

To do this we need ongoing industry and government collaboration to ensure the EoT model meets requirements for both. During the pilots we established an EoT Interoperability Working Group to tackle the technological issues arising in setting up and running the live supply chain data sharing networks between commercial participants and government. We want to continue this, broadening it out to include participants and issues from other sectors - like trade finance - who want to be part of trade ecosystems and who face similar issues.

While we know we need to extend participation as we establish a pathway for the EoT model to operate at scale, we want the six EoT pilot consortia to remain core contributors to this work. The pilot consortia have been indispensable for the last year - giving us their energy, expertise and time - and many of the consortia remain intact and will continue delivering data to the government even as the pilots end. We want all consortia to stay in our working group.

Government must work with other countries to encourage them to collaborate with industry and government in developing the emerging EoT approach with a special focus on working with other countries when trade digitalisation and interoperability issues arise. The pilots included international partners but working with more countries will allow us to increase trader confidence that trade corridors support their digitalisation efforts on both sides. Trade needs to know that regulatory authorities are in this for the long game. A concerted effort with regulatory authorities, trade associations and standards bodies advising and enabling trade via the EoT approach will be far more likely to meaningfully increase adoption.

We want to encourage trade digitisation and the proliferation and deepening of EoT hub systems. Government can support both by taking practical steps, for example providing a framework of what is required in order to be part of the model to make it easier for industry and for international partners to understand how to interoperate with government. The UK has an opportunity to be influential (and to encourage particular models and standards, and digitisation) if it acts quickly. In order to create the correct environment for digitisation and more supply chain data sharing networks, we recommend that:

Government should agree an EoT transition plan for the next year so existing consortia, and new industry partners, know they are operating and information sharing sustainably, with government endorsement and help.

We must clarify the value proposition that developing and participating in the EoT model will provide to government and to trade.

The pilots have shown the EoT carries material benefits for government and trade, but there are significant uncertainties on their exact magnitude. There are up-front costs to the system and process changes which will be required in implementing the EoT model and government and particularly industry will need a compelling business case.

For government, industry can provide most of the data fields wanted and at the right time, so there are opportunities to have an enhanced set of information available. To use the S&S regime as an example, during the pilot a number of the consortia established prototype solutions to demonstrate how data derived from commercial documents could be used to provide the minimum data set proposed for S&S entry summary declarations (ENS). Deriving this data from business documentation, when contrasted with the existing process used to submit ENS data, suggests possibilities for improvements to the current pre-arrival data collection process:

For industry, we have laid out how the model could create material savings, for example reducing the ongoing costs to industry of providing data to government to meet official border requirements. However, there remain gaps in our overall understanding, including the level of compliance improvements that the EoT model could enable. Furthermore, for many parts of industry, much of the value is likely to come when government crafts new Trusted Trader schemes around tech and data capabilities and new assurance flows, and when government has the confidence to offer trusted traders new facilitations. The TOM notes government’s long-term aspiration for a single cross-government Trusted Trader scheme but in the short term departments like Defra are designing their own specific schemes.

Another way to provide value back to trade is to apply new capabilities to areas we know are a “trader pain point” or where there are stoppages to goods flow. That will take ongoing government-industry collaboration so that we can collectively work out where it is best applied to border processes. So far we have worked with a core of Defra, FSA, Home Office, Border Force, HMRC but we know there are other use cases for better data (within the Office of Product Safety and Standards or the Forestry Commission for example).

The economic analysis developed as part of the evaluation of the EoT pilots provides a good starting point for robust, consistently specified quantitative assessment of value of the EoT model both at an individual department or businesses level, and system-wide level. Government will build on this as we develop our assessment of the value released and upfront costs of the EoT model, providing business and government with the basis for better informed, more certain decisions on whether and when they should invest in the range of capabilities which underpin the EoT model.

Government needs to identify precisely what data and assurances it needs in order to operate high quality border processes, so that industry can attempt to provide them. Equally, reducing trade frictions is a priority and government will continue to work with industry to identify ways to incentivise trade so that new information flows between industry and government can be established and adopted.

Test at greater scale, in a real-time operational environment, the value of data fields, not currently provided through border control regimes, in improving the outputs of risking systems.

The STW will become the single digital gateway at the UK border for traders to complete their import, export and transit obligations. It is a fundamental enabler for a range of ambitious government border transformations including supply chain data integration into the UK border model. STW aims to be fully operational by 2027, and to support data provisions from commercial supply chain systems by 2025. Supply chain data provided to the STW will be accessed and used by government departments and agencies. Diagrams at Annex B illustrate how the EoT interacts with the global trading landscape and the STW respectively.

There is a synergistic relationship between the program to design and deliver the STW, and the development and implementation of the EoT model. The findings of the EoT pilots help inform the design of the STW functionality, supporting more automated provision of high quality supply chain data directly from businesses’ systems, which when implemented will be a key enabler of the EoT model.

The STW user research and co-design that will be undertaken to further develop the design of this planned functionality will help inform the design and refine our understanding of the benefits of the EoT. For example it will assess how the integration of supply chain data integration into the UK border model could best support the reduction in administrative burden from providing formal declarations and support more accurate and timely data for performing government risking operations. The EoT pilots have shown us that border agencies want to receive data in various ways, supporting different operational use cases. Government built, owned and operated APIs should be the key mechanism for providing supply chain data to the STW, enabling accessibility to all without conferring competitive advantage on particular companies.

Some border departments and agencies want to receive data in other ways, through the receipt of “signals” (see Chapter 4 for description) or through amalgamating newly available, raw supply chain data into central risking systems where it can be processed with other data to inform decisions. In these cases, the delivery of different supply chain data integration patterns will be addressed by the STW programme in planning the scope of future Strategic Releases. That means working between industry and departments, with support from the STW programme, to design the protocols and infrastructure that departments will require in order to receive data they need.

Each reason for rejection was allocated either:

By using these allocations, we were able to calculate the proportion of preventable rejection under the EoT. For goods with multiple reasons for rejection, it is assumed that:

It should be noted that the data analysed covers only the rejections of POAO consignments from one BCP and those of consignments received from countries outside of the EU. Other BCPs which received fewer containers and higher numbers of imports via air or road transport are likely to differ in terms of the rates seen for each type of rejection; specifically initial data indicates that whilst cold-chain interruptions make up 2% of rejections at this BCP, this number rises to 9% at one airport BCP. There has been no testing of the sensors that monitor temperature and environmental conditions on airfreight through the EoT pilots to determine whether they would work for imports received via this method. Further, it is reasonable to consider that goods received from the EU may differ in terms of rejection issues to those received from other countries, for reasons which include, but are not limited to, companies being less familiar with processes and different challenges due to the nature of the product such as “just in time” consignments. As such these figures in terms of the number of rejections which could potentially be reduced by the EoT model, are not necessarily scalable to the whole import market as well as being untested.

These conclusions implicitly assume that the cause for rejection is not malicious intent, which may not necessarily be the case in reality. Furthermore, changes to government IT systems, processes and legislation may be required in order for these results to be accurate, rather than the EoT model being developed in isolation. Business documentation is also assumed to be available, timely and accurate and accessible to government early enough to allow for corrective action.

These conclusions should be treated as hypothesised outcomes rather than an analysis based on known capabilities and outcomes.

The table below summarises the impact that the EoT is expected to have on the various reasons for rejection. This is based on analysis of 746 rejected POAO consignments from non-EU countries at one BCP, observed from January 2020 to December 2022.

Table 17: Potential impact of the EoT model on rejections of SPS imports

Table 18: Caveats and assumptions to consider alongside this analysis.

Figure 10: Systems diagram showing how multiple systems are organised, share data and provide data to government to enable the Ecosystem of Trust.

Frontline regulatory authority port system: E.g. Authority port health systems

This is explained further below.

This systems landscape diagram captures at the highest level all of the systems that are part of a number of trade corridors, demonstrating how they interrelate and what their responsibilities are.

This is a non exhaustive set of standards, using the Digital Standards Initiative as its principal source. Additional sources consulted include:

Figure 11: Depiction of how the EOT model scales and uses feedback

The diagram above shows how government and industry might begin building and scaling an EoT. The interoperability feedback loop is first driven by small amounts of timely, validated supply chain data feeding into a single compliance regime (initially) which can then be evaluated by government and subsequently with industry in collaborative forums such as the Ecosystem of Trust Interoperability Working Group. Any learnings and requirements that are found from this evaluation are fed back into the feedback loop to help drive further positive impacts - continuing the cycle. This emerging model should also help develop a further set of critical capabilities underpinning the model, which have been identified as being necessary for a mature EoT, which are described below.

Shared system of record - All the solutions have a mechanism for recording information about the business processes related to the buying, selling and transportation of goods internationally. The technical architecture of these solutions varies and these details are not particularly important for understanding the model. The key properties of the solutions are:

These features help avoid some of the issues we see in the current declaration processes where data is typically subject to complex collection and processing activities - which can result in the degradation of parts of the data, which commonly occurs in good descriptions and buyer and seller details - prior to arranging it for it to be delivered according to government deadlines that are not always synchronised with business processes trade are involved in. Specifically we know through prior projects and consultation with industry that the information regulatory authorities can omit important details, such as true buyer and seller details (agent to agent details are provided instead), that are available earlier in the supply chain through upstream systems.

Some aspects of the EoT Systems of Record vary between deployments. This is important to understand when instances of the model are assessed to understand maturity and fit.

Augmenting technology - Many of the EoT deployments use internet-enabled devices (also known as Internet of Things or “IoT” devices) to help secure and track the movement of goods. However there are many limitations to these devices that are detailed in chapter 3. These IoT devices can be broadly classified into two categories:

This type of technology can also be permanently built into transportation equipment, and are called “smart containers” or “smart trailers”.

Two types of “passive” devices (i.e. devices that do not requiring a power source) are used:

The telemetry data generated by augmenting technology is available inside the EoT solutions and allows data about the physical status of the goods to be combined with data and business documents associated with the commercial transaction which helps provide a more complete picture of the import or export event.

Utilising existing due diligence processes - Many industries have well established controls that increase transparency for supply chain participants and provide assurances that goods are delivered as per the original invoice. Although these processes are generally designed to protect the commercial interests of the organisations involved, this information might also be utilised to inform government decisions about the application of border controls.

EoT systems provide a mechanism for the events associated with this type of due diligence - for instance the result of in market checks, commercial due-diligence, supplier life-cycle management etc - to be shared with other parties operating within the ecosystem. There would need to be exploration of how consumers would receive and access this information as well as in-depth investigation into the requirements of the schemes and whether they aligned with participant needs, to determine if there is any benefit to be unlocked through utilising such data.

There is a risk that attempting to utilise the processes in place for commercial and quality purposes for SPS and public health purposes creates additional work, due to the need to continually audit external parties, ensure outside controls do not deviate from government legislation, and ascertain which processes would need to be performed by government as they are not relevant to other procedures.

Through the incremental collection of more highly assured and transparent supply chain data EoTs can synthesise new information from the data they accumulate, for instance by making connections between events or parties involved that were not obvious in the original transactions or by overlaying analytics to help corroborate information or to identify patterns or anomalies.

This move to leveraging the results of the deployment of expertise over data at remote sites will benefit all parties participating within EoTs, reducing the volume of data that regulatory authorities and industry must make sense of. The potential for a smaller “data footprint” has the potential to reduce the associated data security risks, and the financial and environmental cost of collecting and storing data.

Three frameworks support the development of EoT solutions:

Interoperability framework - This framework ensures interoperability between the systems of all participants operating in information sharing networks, permits a broad range of technologies and information sources to be used in the EoT environment and guarantees that regulatory authorities and industry may communicate across many trade corridors in a world where technology is rapidly evolving. This framework covers:

We have begun to tackle aspects of the Interoperability Framework through the pilot, but one of our core recommendations is to prioritise and complete this work by joining up cross-government in the Borders digital space.

Governance framework - This framework will attempt to move beyond MoU-based data sharing solutions - which tend to be bespoke, inextensible and point-to-point solutions that are hard to repeat or scale - towards a Collaboration Agreement (multilateral information sharing agreement). Government solicitors are currently considering the proposed Governance Framework.

The Governance Framework looks to augment the legal and technology-legal public contractual work being undertaken by the ICC an example of which is the Electronic Trade Documents Bill.

Assurance Framework - A good assurance framework will incentivise the onboarding of users to an EoT model through guarantees of a level playing field, information accuracy, an understanding on how liability works and the ability to resolve issues. The framework will cover:

It is the Assurance Framework that will bridge from deployments of the EoT model to the relevant requirements in government Trusted Trader schemes and potentially to the business, operational, policy and scheme needs of regulatory authorities across multiple jurisdictions.

Further work is needed to establish the Assurance Framework (departmental engagement will be crucial since this framework will outline any easements or facilitations offered to EoT participants and will permit participants in EoTs to form their position in terms of confidence in the information being made accessible by them and therefore inform on how supply chain data may be used in risking).

This refers to the initial decision only. When subsequent movements present the same assurances, these would be acted on quickly and consistently regardless of the time taken on the initial decision so this improvement in time may not apply on subsequent movements. This figure is illustrative from limited testing and does not represent a typical value. This should not be used in further analysis without prior consultation.↩

For this assessment the consignments tested were from highly compliant traders willing to participate in the EoT and provide additional transparency into their supply chain information at no immediate gain to themselves. As a result a higher level of confidence for a specific data field or supply chain document should not be directly attributed to any measurable or quantitative measure of targeting accuracy, rather it should be considered a proxy for an improvement in positive targeting outcomes such as a reduction in false positives or an increase in the identification of potentially non-compliant consignments.↩

Commodity Code, Consignee EORI, Declarant name & EORI, Entry date, Preference, VAT value, Net Mass, Previous Document type, Previous Document reference, Additional procedure code, Customs Procedure code, APC, Entry number, Item number↩

ID and Physical check rates for goods from non-EU countries are expected to change under the TOM, which will impact this analysis.↩

clearBorder (2023). The State of the Border - Business Experience of the UK Border 2022. Based on a survey of 300 businesses with experience using the border covering the period January to November 2022.↩

When considering SPS goods, we stress that the EoT should not be restricted to goods that require notification, our economic evaluation should be considered a lower bound. For example: Illegal, unreported and unregulated (IUU) catch certificates are required to confirm that fish have been caught under an approved fishing regime (these can be an additional requirement for SPS consignments); All organic imports are subject to a documentary check; and Plastic Declaration Documents (PDDs) are required on imports of kitchenware from China or Hong Kong, that contain polyamide or melamine, to ensure that the goods have been subjected to appropriate tests. In addition to documentary checks, these consignments may be subject to identity/physical checks and sampling.↩

We note that this and the following data is based on RoW trade with the UK, since we will not have data on EU trade until the TOM is implemented.↩

Based on anecdotal evidence.We note that during this period the port did experience industrial action, and therefore we consider these estimates as an upper bound.↩

The State of the Border - Business Experience of the UK Border 2022↩

This analysis is based on rejected goods data of imports from countries outside the EU arriving at one BCP between January 2020 - December 2022. This provided a list of 30 different reasons that goods are rejected, with goods sometimes being rejected for multiple reasons.↩

ID and Physical check rates for goods from RoW countries are expected to change under the TOM, which will impact this analysis.↩

Figures provided by the FSA.↩

Eyre and Barbrook (2021). The eradication of Asian longhorned beetle at Paddock Wood, UK↩

Hill et al (2019). The £15 billion cost of ash dieback in Great Britain↩

clearBorder (2023). The State of the Border - Business Experience of the UK Border 2022.↩

HMRC (2023). Data tables for customs declaration volumes for international trade in goods in 2022↩

It is assumed that there is no effect on external costs.↩

Home Office (2018). Understanding organised crime April 2015 to March 2016 second edition.↩

Commonwealth Institute (2021). Quantitative Analysis of the Move to Paperless Trade.↩

Costs are estimated from the Ease of Doing Business survey.↩

European Parliamentary Research Service (2020). Towards a mandatory EU system of due diligence for supply chains (PDF, 930 KB)↩

clearBorder (2023). The State of the Border - Business Experience of the UK Border 2022.Based on a survey of 300 businesses with experience using the border covering the period January to November 2022.↩

Economist Intelligence Unit (2021). The business Costs of Supply Chain Disruption (PDF, 780 KB)↩

Source: Maersk. Charges are applicable per container, per day. Non-refrigerated range applies for 20’ Dry, 40’ Dry & 40’HC & 45’ Dry, 20’ Flat & Open top, 40’ Flat & Open top. We note that both detention and storage charges can vary by port, region, and shipping line.↩

Source: Maersk. Charges are applicable per container, per day. Non-refrigerated range applies for 20’ Dry, 40’ Dry & 40’HC & 45’ Dry, 20’ Flat & Open top, 40’ Flat & Open top.↩

Data covers all 106 UK maritime ports and frontier locations services serviced by Destin8 for Jan, Feb and Mar 2022. This includes both temporary storage and pre-lodgement models.↩

Evidence from the pilots provided by IBM and Maersk. This analysis considers the costs incurred per consignment rather than per container.↩

Inventory carrying costs include cost of capital, storage space costs, insurance, handling/administration of inventory, shrinkage, and obsolescence↩