Border Target Operating Model (BTOM)

The final Border Target Operating Model (BTOM) was released in August 2023. The document sets out a new approach to Safety and Security controls (applying to all imports), and Sanitary and Phytosanitary controls (applying to imports of live animals, germinal products, animal products, plants and plant products) at the border.

As part of post-Brexit arrangements, the BTOM aims to streamline cross-border trade processes and ensure the smooth functioning of goods movement while maintaining regulatory compliance. It has been developed with further collaboration across the UK, Scottish and Welsh Governments, and engagement with officials from the devolved administration in Northern Ireland.

In this post, we provide a summary of the key changes introduced by the BTOM and what it means for businesses engaging in trade across the borders.

What is the timeline for BTOM implementation ?

31 January 2024 – The introduction of health certification on imports of medium risk animal products, plants, plant products and high risk food and feed of non-animal origin from the EU. The removal of pre notification requirements for low risk plant and plant products from the EU.
30 April 2024 – The introduction of documentary and risk-based identity and physical checks on medium risk animal products, plants, plant products and
high risk food and feed of non-animal origin from the EU. Existing inspections of high risk plants/plant products from the EU will move from destination to Border Control Posts. We will also begin to simplify imports from non-EU countries. This will include, the removal of health certification and routine checks on low risk animal products, plants, plant products from non-EU countries as well as reduction in physical and identity check levels on medium-risk animal products from non-EU countries.
31 October 2024 – The requirement for Safety and Security declarations for imports into Great Britain from the EU or from other territories where the waiver applies will come into force from 31 October 2024 as set out in the original Target Operating Model. Alongside this, HMRC will introduce a reduced dataset for imports and use of the UK Single Trade Window will remove duplication where possible across different pre-arrival datasets – such as pre-lodged customs declarations.

Movements of Irish goods and Northern Ireland Qualifying Goods arriving from Ireland

For goods moving from Great Britain into Northern Ireland, arrangements are set out under the recently agreed Windsor Framework. The Windsor Framework has established green and red lanes at Northern Ireland ports for goods moving from Great Britain to protect the UK’s internal market and provide reassurance on goods destined for the EU. Northern Ireland businesses and citizens can continue to purchase goods from the EU without new barriers. No additional checks or controls will be applied to imports into Northern Ireland from the EU, allowing Northern Ireland traders full access to the EU market.

You can get more information about the Windsor Framework in this post.

In line with the introduction of border controls on EU imports set out within the Border Target Operating Model, border controls and customs checks will be implemented on Irish goods moving directly from Irish ports to Great Britain. This includes biosecurity, security controls and full customs controls for these movements.

Qualifying Northern Ireland Goods will have unfettered access to the Great Britain market, with these arrangements strengthened in domestic legislation. However, food and feed products must be owned or processed in Northern Ireland by a registered or approved Northern Ireland business to be considered a Qualifying Northern Ireland Good for sanitary and phytosanitary purposes.

Movements of non-qualifying goods arriving from Ireland

From 31 January 2024 non-qualifying goods will face full customs controls and the requirement for pre-notification and certification when moved directly from Ireland via Irish ports to Great Britain

Guidance on which goods qualify for unfettered access when moving from Northern Ireland to the rest of the UK is available here and will be updated in due
course to reflect the latest operating arrangements as set out in the Border Target Operating Model.

Assessing the risk of your animal and plant products