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Borders Target Operating Model (BTOM) Update August 2023

Background

The BTOM sets out how Government will check imports from the EU and Rest of the World (RoW). The Government, unlike the EU, has not implemented full border controls since Brexit for goods from the EU. The BTOM will both introduce those checks and align policy with imports from the RoW.

There have been a number of delays to introducing border controls on imports from the EU and the latest update, with the final BTOM, has pushed the proposed dates back by another 3 months. It also believes this will give more time for businesses operating in Northern Ireland to adapt to the requirements of the Windsor Framework in October.

The BTOM is a large document which you will need to ensure your business and particularly your global supply chains understand. You can read a full copy here 

This briefing builds on previous ones and provides an update on the key changes.

Timetable

The Government believes EU exporters needed more time to be ready for the new border and has pushed the key dates back by 3 months

31 January 2024 – All medium risk animal products, plants and plant products will need certification, signed by a suitably qualified person and lodged with the UK ahead of import.

30 April 2024 – Introduction of physical and documentary checks of medium risk animal products, plants and plant products at ports. Also checks on RoW imports will be aligned in terms of risk which will reduce some paperwork and frequency of checks.

31 October 2024 – Introduction of safety and security checks on EU imports. Also a reduced dataset required for imports through the Single Trade Window (STW) to reduce duplication.

Republic of Ireland Imports

You will be aware imports from ROI are not currently subject to pre-notification of imports of animal and plant products as is the case with the rest of the EU. From 31 January 2024 ROI imports will require pre-notification and export health certification of imports. However, there is currently no date for the implementation of full documentary and physical checks at the ports, only they will be introduced from October 2024 with a final date confirmed by the UK Government later in 2023.

Changes to the BTOM

Responding to feedback on the draft BTOM published earlier in 2023, the Government has added more detail to the final document.

  • A section explaining how the BTOM works with the Windsor Framework
  • Clarification on the responsibilities of hauliers and carriers in terms of the safety and security controls
  • Updated commodity code level guidance on which risk level animal and plant products are placed
  • Guidance on how the Single Trade Window will operate
  • Provision of Groupage to reduce costs of health certificates

Trusted Trader

The Government wants to introduce an accredited trusted trader scheme for businesses which can demonstrate good traceability and an excellent record of compliance. These would apply to either animal or plant imports. The main benefit would be the ability to make physical and certification checks away from the border speeding up transport.

Initially the scheme will be piloted from January 2024, with the ability to do checks away from the border by April 2024. The Government is already working with some businesses who will be invited to join the pilot but it will be open to any eligible business.

The Government wants to work on more relaxation of controls from April 2024. Ultimately its are to evolve the work it has been doing on the ecosystem of trust to introduce a more comprehensive trusted trader scheme for all imports, but there is no date when that will be available.

Certification

The Government has already published simplified export health certificates (EHCs) for products of animal origin. Once these have been adopted by EU exporters they will be available to RoW exporters.

The Government will from January 2024 accept digitalised EHCs, however this is dependent on the IT support available in EU countries, so it will not be immediately available for every EU country.

Support

The Government wants to use the additional 3 months to ensure EU exporters are ready for the first major change, certification, from January 2024. It intends running a number of sector specific food webinars through September which it hopes retailers will attend and share with their supply chains.