Final BTOM Broadly Welcomed

5 September 2023


The final version of the government’s Border Target Operating Model (BTOM) was released on 29 August, and has been broadly welcomed by British importers, particularly importers of fresh produce.

Sanitary and phytosanitary (SPS) checks will come in on 31 January 2024, with physical checks and other requirements coming onstream later that year.  This new date represents a fifth delay in implementation. 

The Cabinet Office said: “Having listened to the views of industry, the government has agreed to a delay of three months for the introduction of remaining sanitary and phytosanitary controls, as well as full customs controls for non-qualifying Northern Ireland goods, which will now be introduced from January 2024.”

Importers of fresh fruit and vegetables from Europe are pleased that these will not be subject to pre-notification requirements, or inspections at the UK border.

The final BTOM says that import controls will be implemented in three main steps, during 2024:

31 January – introduction of health certification for imports of medium-risk animal products, plants, plant products and high-risk food (and feed) of non-animal origin from the EU.

30 April – 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.  Imports of Sanitary and Phytosanitary goods from the rest of the world will begin to benefit from the new risk-based model.

31 October - Safety and Security declarations for EU imports will come into force, along with a reduced dataset for imports.

New checks and controls will be introduced for Irish goods moving from Ireland directly to Great Britain. Northern Ireland businesses will retain unrestricted access for NI goods to their markets in Great Britain, whether they come directly from Northern Ireland or indirectly through Irish ports.

William Bain, Head of Trade Policy at the British Chambers of Commerce, said:

“Businesses will be pleased with this clarity as they prepare for the challenging shift to a digital trade system. The focus must now be on delivering the Single Trade Window to the timescales set out. The new approach to digitalising borders for goods movements could bring real benefits to the SMEs we represent, to trade, and to the economy.

“The critical thing is preparedness. Businesses are making investment and supply chain decisions for the long term and need to be confident that the physical and digital infrastructure around the GB border is going to be in place on time."

Chamber International’s trade director, Tim Bailey, said: “Even with this delayed implementation, some importers will struggle to get ready for 31 January.  It seems that the government has listened to the concerns of importers, particularly with regard to streamlining procedures for fresh produce coming from the EU.  UK businesses need to learn about their obligations and prepare thoroughly, with respect to BTOM – we’re helping companies do that already, and recently announced some targeted workshops to help”.

Full text of the final BTOM can be read here.


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