Border Target Operating Model: how will it affect imports into the UK?

UK exports have been subject to new EU rules. but there is no reciprocal arrangement for goods coming the other way. The BTOM plans to address that.

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The Border Target Operating Model (BTOM) has been introduced from January 2024, after multiple delays. It is a new system of checks on all goods imported into the UK.

It has most relevance to goods imported from the EU because, due to Brexit, that is the part of the border model that has changed. But it also replaces the system applied to goods imported from the rest of the world.

Since Brexit was implemented in January 2021, goods leaving the UK face new EU controls, but there has been no reciprocal arrangement to check goods arriving from the other direction. 

“It’s hugely frustrating that the government has yet again delayed the implementation of vital checks on goods entering from the EU for the fifth time,” said NFU President Minette Batters in a statement.

Delays are to allow businesses further time to prepare and for the government to incorporate feedback from stakeholders, including from the agricultural sector who cited the growing threat from animal and plant disease, such as African Swine Fever and Xylella fastidiosa.

A change to importing rules of this scale requires investment for businesses to prepare. Businesses said their supply chains would need time to adapt to new controls.

But with rules introduced for UK importers but no reciprocal arrangements, UK businesses face a trading disadvantage. 

What is the BTOM?

The BTOM is a global protocol for biosecurity controls and is the UK’s new system of import controls for goods from the EU. The system is supposed to mean less bureaucracy and more digitisation than would have been the case using the original post-Brexit model.

New rules will be introduced in stages through 2024. It has a specific emphasis on sanitary and phytosanitary (SPS) measures for goods like live animals, plants, and animal products, so particularly impacts farmers, food importers and bio-science industries.

“There are three distinct milestones,” said William Bain, Head of Trade Policy at the British Chambers of Commerce (BCC) in a phone interview. “The first two only affect importers bringing in products of animal, plant and foodstuffs origin.” However, delays here could impact businesses from any sector.

In January, new rules for sanitary and phytosanitary controls or ‘health certification”, and full customs controls for non-qualifying Northern Ireland goods were introduced. 

By the end of April, checks on medium-risk animal products, plants, plant products and high-risk food (and feed) of non-animal origin from the EU will be implemented. Qualifying goods will face documentary, identity, and physical checks and imports of sanitary and phytosanitary goods from outside of the EU will adopt a new risk-based approach.

Safety and security declarations for EU imports will be  mandatory from the end of October 2024 and there will be a more streamlined dataset for imports. The government said this Milestone 3 will be tied into the rollout of single trade portal.

The aim is to reduce the safety and security data requirements from businesses, make it easier to submit data and improve how the data is used.

What does it replace?

The new rules do not replace an operating system that is still used. The BTOM is being introduced because legally there must be post-Brexit trading arrangements in place for goods imported from the EU.

When new Brexit trading arrangements took effect in January 2021, the UK did not have a replacement system for imports in place, nor an agreed reciprocal arrangement with the EU.

A draft version of the BTOM was published in April 2023 but businesses warned they would not be able to absorb the extra costs of the new checks and these would be likely passed onto consumers.

Why is it being introduced?

Part of the reason for the delay is to shield businesses from these costs, but also because the extra costs could raise food prices and increase already high inflation, which has contributed to the UK’s cost of living crisis.

There is also an issue around the UK’s food security, which, according to the NFU, is around 60%. New checks on EU imports could disincentivise EU food exporters to export to the UK, affecting supply, potentially further raising prices and causing food shortages.

There are other reasons why parts of the UK farming community think a new system needs implementing without further delays. 

Rob Mutimer, a Norfolk pig farmer and chair of the National Pig Association, recently warned border rules are needed to protect the UK’s biosecurity to ensure African swine fever (ASF) does not reach the UK. It’s highly contagious and fatal for pigs. New cases have recently emerged in wild boar in Sweden and commercial pigs in northern Italy. 

The government acknowledges that an ASF outbreak would be “a fundamental threat to the viability of our pig industry”.

What changes will it bring about?

Import checks will likely raise costs for EU farmers. This will stop UK producers being undercut but could incentivise EU producers to stop exporting to the UK, opening up the market to cheaper alternatives, from countries with less stringent rules on quality and provenance. 

The government says digitisation of the process will save businesses £500m annually because by using electronic certificates, there will be fewer checks.

However, any new system inevitably brings extra costs and more paperwork that could affect competitiveness. The NFU is concerned about the impact to the UK’s biosecurity.

How does it affect businesses?

Currently, when UK businesses trade animal and plant products with EU businesses they face new post-Brexit rules that increase the cost of trading. EU companies can still export goods without reciprocal checks, giving them a commercial advantage as they can undercut British businesses.

Horticultural businesses are affected because they are no longer the hub for controlling rules and product quality. Instead, this will be handled by border control posts. NFU President Minette Waters sees this “as a major point of jeopardy, with unknown costs and heightened biosecurity risks.”

The government confirmed in Parliament that extra costs to businesses will be £330m annually. The cost alone of export health certificates is £160m. The BCC wants a veterinary deal to remove the requirement for export health certificates for both UK and EU businesses.

What about Northern Ireland?

Businesses in Northern Ireland may welcome the delay of BTOM due to the unique pressures they have experienced from Brexit with the introduction of the Windsor Framework in October. BTOM rules will be implemented as part of the Windsor Framework.

Rules regarding food products will change to ensure goods made outside the UK are not relabelled as ‘from Northern Ireland’ to gain access to the UK. This means most goods in Northern Ireland will qualify for full access to the UK, though food and animal feed products will need to be owned or processed in Northern Ireland by an NI registered business to qualify.

What should startups and SMEs do?

Businesses need to ensure their EU suppliers are prepared for the new system, that suppliers have their export health certificates for meat and dairy products ready to use.

“Speak to your suppliers in the EU,” said Bain. “If you haven’t, do it today to ensure there is enough slack in the supply chain in case of delays and in the sourcing journey time to minimise waste.” 

The NFU said the government must use the delay wisely to “raise awareness among EU exporters and to address the concerns expressed by many in the supply chain.” One sector particularly affected, horticulture, will experience a shift of control away from them to border control posts. This represents a major biosecurity risk.

One potential way to make integrating Milestone 2 in April easier is to see if your business qualifies for the ‘Trust a trader’ scheme, being set up for heavy users.

The obligation is on the importer to follow the new regulations but it depends on the specific type of contract businesses have. Some large supermarkets use a ‘delivery duty paid’ (DDP) system that obliges suppliers to deliver direct into warehouses. In this case the onus for following regulations is on the exporter, who could also qualify for the ‘Trust a trader’ scheme.

According to the UK government, “Traders welcomed the model as an improvement over the model inherited from the EU, particularly the proportional approach to risk and the ambition to use Trusted Trader schemes as part of the model,” it said in its updated Border Target Operating Model.

Benjamin Salisbury - business journalist

Benjamin Salisbury is an experienced writer, editor and journalist who has worked for national newspapers, leading consumer websites like This Is Money and, business analysts including Environment Analyst, AIM Group and written articles for professional bodies and financial companies. He covers news, personal finance, business, startups and property.

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