The Border Target Operating Model (BTOM) is the UK government's framework for implementing post-Brexit border controls on goods imported into Great Britain. It introduces a risk-based approach to customs procedures, sanitary and phytosanitary (SPS) controls, and safety and security measures for imports from both EU and non-EU countries. The model aims to balance trade facilitation with regulatory compliance, ensuring that the UK’s borders remain secure while minimizing unnecessary trade disruption.
Border Target Operating Model (BTOM)
Risk-Based Categorization of Goods
Under the BTOM, imported goods are classified into three risk categories, which determine their level of border checks and import requirements.
Animal Products Risk Categories:
Risk Level | Example Products | Health Certificates | Pre-notification | Document Checks | Identity & Physical Checks |
| High Risk | Live animals, germinal products, safeguard measure products | Required | Full requirements | 100% | 100%* |
| Medium Risk | Raw meat, meat products, medium risk fishery products | Required | Full requirements | 100% | 1-30%** |
| Low Risk | Shelf-stable products, certain composites, canned meat products | Not required | Pre-notification data only | 0% | 0% |
*Certain live animals (e.g., high health equines) may be subject to reduced levels of ID and physical checks.
**Many products will only require 1% identity and/or physical checks, but some products may require up to 100% on ID checks.
Plants and Plant Products Risk Categories:
| Risk Level | Plant/Product Type | Document Checks | Identity & Physical Checks |
| High Risk | Plants for planting - woody/commercial production | 100% | 100% |
| High Risk | Plants for planting - non-woody for retail (outdoor) | 100% | 30% |
| High Risk | Plants for planting - non-woody for retail (indoor) | 100% | 5% |
| Medium Risk | Plant products with identified risk | Generally 5% (RoW) and 3% (EU) | Generally 5% (RoW) and 3% (EU) |
| Low Risk | All other regulated plant products | 0% | 0% |
Sanitary and Phytosanitary (SPS) Controls
The BTOM introduces new rules for animal and plant-based imports to protect public health, animal welfare, and biosecurity. These replace the EU’s internal market requirements with UK-specific regulations.
Goods requiring physical checks must enter the UK through designated BCPs, where they will be inspected by UK authorities.
The UK government is introducing digital health certification, allowing businesses to submit compliance documents electronically.
SPS goods are categorized as high, medium, or low risk, aligning with the broader risk classification system under BTOM.
Streamlines certification process for animal products, allowing an Export Health Certificate to be used from the point of origin without re-certification at a consolidation hub in the EU.
Allows frequent importers of products of animal origin and animal by-products to reduce routine physical checks at Border Control Posts by taking responsibility for carrying out checks at other locations.
A pilot scheme where a trader with appropriately trained personnel and internal control systems can achieve authorization to perform physical and identity import checks.
Trusted Trader Schemes
BTOM introduces new pilot Trusted Trader schemes for SPS goods:
Groupage Facilitation
The BTOM includes provisions to support businesses using groupage (transporting multiple consignments on a single lorry or container):
- Low-risk animal products will not require an export health certificate, simplifying groupage loads containing these products.
- Medium-risk animal products will be subject to reduced levels of intervention at the border.
- Simplified export health certificates include 'inclusive and/or' statements allowing products meeting different conditions to be certified together on a single certificate.
- Vehicle registration details can be replaced with "Groupage" on Export Health Certificates for individual consignments.
Movements from Ireland
Special provisions apply to goods moving from Ireland to Great Britain:
Will continue to benefit from unfettered access to the Great Britain market without new checks and controls. Food and feed products will need to be owned or processed in Northern Ireland by a Northern Ireland registered or approved food or feed business to qualify.
From 31 January 2024, will face full customs controls and pre-notification requirements when moved directly from Ireland to Great Britain. From 31 October 2024, documentary and physical checks will be introduced at west coast GB ports.
The UK Single Trade Window will provide a simplified gateway for traders and intermediaries to meet their border obligations by submitting information to Government in one place. Initial functionality will include:
UK Single Trade Window
Liability and Compliance Responsibilities
Importers must understand their liability:
- The operator named on the CHED is liable for SPS charges and compliance. If an agent is named as the responsible operator on the CHED, they will assume this liability.
- For animal products, the operator completing the CHED must be UK-established. This may require ALS to act as an indirect representative on behalf of non-UK established clients.
- For plant products, the importer will be liable for associated SPS charges. If an agent submits the CHED, the liability may still rest with the end importer.
Impact on Businesses
The BTOM introduces significant changes to UK import procedures. Businesses trading with Great Britain should:
- Ensure customs declarations are accurate and comply with evolving documentation rules.
- Identify whether their goods fall into high, medium, or low-risk categories to determine inspection requirements.
- Route applicable shipments through designated Border Control Posts to avoid disruptions.
- Understand and mitigate liability under UK SPS legislation.
- Stay updated on implementation timelines and regulatory changes to remain compliant.
By preparing for the phased rollout of BTOM controls, businesses can minimize trade disruptions and maintain efficient cross-border operations.
