Importers Brace for BTOM Impact
15 December 2023
With the new Border Target Operating Model (BTOM) starting to come online on 31 January 2024, many UK traders appear to be unclear about how it impacts their business operations.
For instance, a straw poll taken earlier this autumn at an event by the Institute of Export and International Trade indicated that less than a fifth of participants were clear about what the impact would be on their own businesses.
According to the government’s own website, BTOM “sets out a new approach to security controls (applying to all imports), and sanitary and phytosanitary controls (applying to imports of live animals, animal products, plants and plants products) at the border. It sets out how controls will be simplified and digitised, and our ambition for the UK’s new Single Trade Window.”
Varying impacts
The impact of BTOM on businesses will vary greatly, depending on what they trade. From 31 January, it promises to simplify procedures for those who import goods with sanitary and phytosanitary (SPS) requirements, such as Products of Animal Origin (POAO); plants and plant products; animal feed; and High-Risk Food of Non-Animal Origin (HRFNAO). For many other types of goods, though, the implications may be minimal until October 2024.
Import controls will be introduced in three main steps, during 2024:
On 31 January, health certification requirements will be added for imports of medium-risk animal products, plants, plant products and high-risk food (and feed) of non-animal origin from the EU.
On 30 April, documentary and risk-based identity and physical checks will start to be mandatory for imports of medium-risk animal products, plants, plant products and high-risk food (and feed) of non-animal origin from the EU. Imports of SPS goods from the rest of the world will begin to benefit from the new risk-based model.
Then, on 31 October, Safety and Security declarations for EU imports will come into force, together with a reduced dataset for imports.
Consignment risk
BTOM involves a risk-based system, based on “consignment risk” (determined by calculating the product of both “country risk” and “commodity risk”). Affected businesses will need to understand how the new risk categories apply to their products; an explanation of these categories can be found in the final 140-page BTOM document, which is available for download.
Consignments classified as “high risk”, including live animals, will all require Export Health Certificates (EHCs) and full pre-notification; documentary, ID and physical checks will be required without exception.
“Medium risk” consignments, including raw, chilled and frozen meat, will also require EHCs and pre-notification; documentary checks will be mandatory, but the rate of ID and physical checks will vary, and should be lower than under the previous regime.
EHCs will not be required for “low risk” consignments, including processed shelf-stable products, and there will be no documentary ID or physical checks – a significant change from the current arrangement. However, pre-notification data will be required, to allow traceability to take place.
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.
Eighteen Months of Change for Traders
The next eighteen months will be a time of significant change for UK traders, with a host of changes to adapt to: not only BTOM, but also the migration of the system for customs declarations from CHIEF to CDS; changes to trade between Great Britain and Northern Ireland under the Windsor Framework; and the new NCTS5 system for transit users (which HMRC announced, in October, will be moved back to 1 July 2024).
Chamber International’s director Tim Bailey comments “Importers of low, medium and high-risk goods need to be liaising with their suppliers and forwarders. If they’re unsure of the category their goods fall into, they can get help from DEFRA.”
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