Logistics & freight · United Kingdom · SPS imports

The per-CHED tax UK SME importers can't dodge: the BTOM Common User Charge.

Since 30 April 2024, every commercial SPS consignment — animal products, plants, high-risk food and feed — entering Great Britain via Dover or Eurotunnel and eligible for checks at the Sevington Border Control Post is billed the Common User Charge: £29 per commodity line on a Common Health Entry Document (CHED), capped at £145 per CHED for medium and high-risk goods, payable whether the consignment is physically inspected or not. The Horticultural Trades Association called it "a cost hike for no material gain" announced "at the eleventh hour". The EFRA Committee's report on UK-EU trade records IT failures, workload pressure on inland authorities, and Defra data-quality limits that left imports under disease-control measures clearing the border for six days. Operators on groupage routes — small horticulture and food importers, customs brokers, freight forwarders — feel the per-line charge on every load.

01The pain

The Common User Charge is the per-CHED, per-commodity-line fee Defra introduced under the Border Target Operating Model to recover the operating cost of the government-run Sevington Border Control Post. The official gov.uk guidance states the rate verbatim: "The £29 import common user charge applies to each commodity line in a common health entry document (CHED)", with "The maximum charge for one CHED…limited to 5 commodity lines, even if there are more than 5 commodity lines present in the document", meaning "the maximum you will be charged for medium and high risk common health entry documents is £145".¹ The same guidance dates the introduction precisely: "As part of changes to import controls under the Border Target Operating Model (BTOM), the common user charge was introduced on 30 April 2024", with rates calculated against "the estimated operating costs of the government-run Sevington Border Control Post for the 2024 to 2025 financial year".¹ The flat-rate, cost-recovery structure applies whether or not a consignment is physically inspected — every eligible CHED issued through IPAFFS for goods routed through Dover or Eurotunnel attracts the charge.

The trade-body objection at announcement was framed in operator-cost terms, not abstract policy terms. The Horticultural Trades Association — chairman James Barnes — called the announcement "a cost hike for no material gain" delivered "at the eleventh hour", and warned it would be "a huge new cost burden for many, hitting SMEs hard", particularly those using groupage arrangements.² The HTA's published context is the part operators outside horticulture also recognise: nearly 100% of UK growers are SMEs, around 90% import plants at some stage of the growing cycle, and typically pay the maximum £145 charge per consignment because complex multi-line CHEDs blow through the five-line cap on almost every shipment.² The HTA also recorded that the policy was developed "without a full year of data for accurate cost-recovery calculations", which is the operator-side framing of why the rate landed where it did.² Trade bodies have repeatedly argued that the structural exposure — pay-per-line, cap-per-CHED, charged regardless of inspection — is the part that compounds against groupage operators consolidating multiple SME shipments into a single CHED.^2,4

The Environment, Food and Rural Affairs (EFRA) Committee's UK-EU trade: towards a resilient border strategy report is the parliamentary record of the operational pain alongside the cost. Trade-press coverage of the report records the Committee's explicit findings: BTOM has "fallen short of expectations due to inconsistent enforcement, flawed digital systems, inadequate consultation and limited support for local authorities"; the Committee was "not confident that Defra has effective oversight of border controls, particularly at the Short Straits, where enforcement is weakened by flawed IT systems, data gaps and limited support for inland authorities"; that during a German foot-and-mouth disease food-import ban in early 2025, "imports within the scope of disease control measures were being automatically cleared through the UK border for six days until digital systems were updated"; and that inland local authorities were "overlooked during consultation, planning and rollout of the BTOM, with no additional funding allocated to support them".³ Defra's response to the Committee acknowledged the data picture problem directly, undertaking to "review how data are recorded and analysed within port health authority and Defra IT systems and how these can be combined to create a reliable and complete data picture".³ What the operator on a groupage trailer experiences is the downstream of all three findings simultaneously: a per-CHED charge, billed against a system whose own oversight body cannot reliably report check volumes, with port health authorities running on inadequate IT and no additional funding to absorb the workload.^2,3

A regime operators describe by what it costs them per shipment: £29 per commodity line on every eligible CHED, capped at £145 per CHED for medium and high-risk SPS goods entering GB via Dover or Eurotunnel;¹ billed whether or not the consignment is inspected;¹ introduced on 30 April 2024 to recover the operating costs of the government-run Sevington Border Control Post;¹ hitting groupage operators and SMEs hardest — ~100% of UK growers are SMEs, ~90% import plants, typically paying the £145 cap per consignment;² on top of mandatory IPAFFS pre-notification at least one working day before arrival;⁴ against an enforcement system the EFRA Committee found "weakened by flawed IT systems, data gaps and limited support for inland authorities", with imports under disease-control measures cleared for six days during a 2025 German food-import ban before the digital systems were updated.³

The operational layer underneath the charge is the IPAFFS / CHED / BCP routing pipeline that every SPS importer now lives inside. Every plant import pre-notification — since the former PEACH system was permanently closed in April 2024 — has to be submitted through the Import of Products, Animals, Food and Feed System (IPAFFS), which generates the CHED reference that has to be lodged on the accompanying customs declaration; "Pre-notification via the Import of Products, Animals, Food and Feed System (IPAFFS)" is, per the trade-press explainer, the gateway action the importer or their agent has to perform "one working day ahead of a consignment's arrival in GB".⁴ A CHED that is mis-coded, late, or routed against the wrong commodity reference triggers the consignment being directed to a BCP for further checks; the £29-per-line charge has already been incurred regardless of outcome.^1,4 What used to be a frictionless EU import — for a small horticulture firm in Lincolnshire bringing in liners and young plants during the spring growing window, for a specialist food importer running mixed-line groupage from Calais, for a freight forwarder consolidating ten SME shipments into one trailer — is now a per-shipment compliance and cost event that has to be priced into every job, paid against an enforcement system the Committee that scrutinises it has publicly described as inadequately funded and inadequately instrumented.^2,3,4

¹ UK Government / Defra — "Common User Charge: rates and eligibility" (gov.uk guidance) — verbatim £29 per commodity line, £145 cap, 30 April 2024 introduction, Sevington BCP cost-recovery basis: gov.uk/guidance/common-user-charge-rates-and-eligibility
² Horticultural Trades Association — "Common User Charge announcement" — chairman James Barnes' "cost hike for no material gain", "eleventh hour", "huge new cost burden for many, hitting SMEs hard", ~100% SME / ~90% importer / £145 cap context: hta.org.uk/news/common-user-charge-announcement
³ Environment, Food and Rural Affairs Committee, House of Commons — UK-EU trade: towards a resilient border strategy, HC 1297 — BTOM oversight, IT failures, six-day disease-control clearance gap, no additional funding for inland authorities, Defra data-quality limits: publications.parliament.uk/pa/cm5901/cmselect/cmenvfru/1297/report.html (parliament.uk blocks automated fetchers; report content independently confirmed via UK trade-press and CIEH summaries.)
⁴ Plutos (UK customs / freight trade-press explainer) — "Border Target Operating Model (BTOM): What UK Importers Need to Know" — IPAFFS pre-notification, BCP routing, one-working-day pre-notification window, system registration: plutos.org.uk/border-target-operating-model-btom-what-uk-importers-need-to-know/

02Who solves this today

UK-market vendors that publicly self-market on their own homepage to SPS importers on the IPAFFS / CHED / BTOM niche — customs brokers and import agents whose service surface explicitly addresses CHED pre-notification, BTOM risk-categorisation, and Sevington-routed consignments. Each entry verified live and self-marketed in the niche on the date of writing. Inclusion is not endorsement. The list is intentionally narrow.

OTS Broker — IPAFFS service

UK customs brokerage with a dedicated IPAFFS service page describing the platform as "the UK's mandatory pre-notification platform", offering to "handle IPAFFS notifications on behalf of importers across the UK and EU" and to "handle CHED notification and customs declaration under one roof, ensuring perfect data alignment between IPAFFS and CDS". Marketed explicitly against the BTOM risk-category framework — "Determining the correct BTOM risk category for your commodity is essential" — with seven-day-a-week notification submission for outside-business-hours arrivals. The route a UK SPS importer takes when they want IPAFFS / CHED submission and customs clearance run by a single agent against the per-line, per-CHED charging surface.

otsbroker.com

EORI (UK) — IPAFFS declarations

UK customs and EORI-services provider with a dedicated IPAFFS page positioning itself as a registered submitter: "EORI (UK) are registered to complete IPAFFS declarations on your behalf", framing the system explicitly as the source of the CHED that drives the per-CHED charge — "IPAFFS are used to generate UK CHED declarations" — with the workflow note "Once completed, the IPAFFS system will return a 'CHED' reference which should then be lodged on the accompanying GB import declaration". The route a UK importer without an in-house customs team takes when they need someone authorised to file the IPAFFS pre-notification and recover the CHED reference for the customs declaration.

eori.uk

Listed providers publicly market to UK SPS importers on the IPAFFS / CHED / BTOM niche from their own homepages. Inclusion is not endorsement. Several adjacent vendors were considered and excluded — GB Customs Clearance's IPAFFS page was reachable but its self-marketing surface was thin (a single line on import-agent IPAFFS handling, no explicit BTOM / CHED / Sevington framing), and Strong & Herd's IPAFFS page is a training / advisory surface rather than a live submission service. Both were dropped under the precedent that two verified entries beat three with a weak link. Trade press, the gov.uk guidance, the HTA announcement, and the EFRA Committee report are cited above in section 01 as the source of the operator-side narrative, not as solution providers.