The Border Target Operating Model (BTOM) represents the most significant overhaul of UK border controls since Brexit. Published in August 2023 and rolled out from the end of January 2024, this 140-page policy document fundamentally changes how goods — particularly food, animals and plant products — enter the United Kingdom. Every UK importer needs to understand what BTOM means for their supply chain, compliance obligations, and costs.

What is the Border Target Operating Model?

BTOM is the UK Government’s comprehensive framework for managing imports at the border. It establishes a risk-based approach to physical inspections, replacing the previous temporary easements that had been in place since the end of the Brexit transition period. The model covers two main areas:

• Security and Safety controls — applying to all imports, requiring Entry Summary Declarations
• Sanitary and Phytosanitary (SPS) controls — applying to animals, animal products, plants, and plant products

The official document is available on GOV.UK: The Border Target Operating Model.

Risk Categorisation Under BTOM

One of BTOM’s central innovations is risk categorisation for both EU and non-EU commodities. Under this system:

• High-risk commodities: Require pre-notification via IPAFFS and are subject to physical checks at designated Border Control Posts (BCPs). This applies particularly to products of animal origin (POAO) and high-priority plants.
• Medium-risk commodities: Subject to documentary checks and potentially identity checks. Physical checks are carried out on a risk-assessed basis.
• Low-risk commodities: May enter with minimal checks, though documentary requirements still apply.

Importers must determine the risk category of their products and ensure they meet the applicable requirements before shipment departs. Failure to do so can result in delays, rejection at the border, or financial penalties.

SPS Controls — Key Changes for Food and Agricultural Imports

The SPS element of BTOM has been particularly impactful for importers of food and agricultural products from the EU. Key requirements include:

• Health certificates issued by competent authorities in the country of export
• Pre-notification via the Import of Products, Animals, Food and Feed System (IPAFFS)
• Physical presentation at an approved Border Control Post
• Compliance with UK-specific maximum residue levels (MRLs) and compositional standards

Importers should note that the BTOM controls apply equally to EU and non-EU imports, ending the previous lighter-touch approach to EU goods that existed during the transition period.

The UK Single Trade Window

A key component of BTOM’s longer-term vision is the UK Single Trade Window (UKSTW). This digital platform aims to allow traders and intermediaries to submit border-related data once, with that information being shared across relevant government departments and agencies — including HMRC, Border Force, DEFRA, and the Animal and Plant Health Agency (APHA).

The UKSTW reduces the administrative burden of dealing with multiple separate systems and aims to speed up border processes for compliant traders. Integration with the UKSTW is a phased process, with full functionality expected over several years.

Practical Implications for Importers

For businesses importing goods into the UK, BTOM means:

1. Advance planning: Pre-notification requirements mean you must submit information hours or days before arrival, depending on commodity type.
2. BCP routing: High-risk goods must arrive via designated Border Control Posts equipped to carry out the relevant checks — not all ports have BCPs for all commodity types.
3. Documentary compliance: Health certificates, phytosanitary certificates and other supporting documents must be in order before goods leave the exporting country.
4. Cost implications: Physical inspections, certification costs and potential delays increase the cost of importing, which must be factored into pricing and supplier negotiations.
5. System registration: Importers and their agents need to be registered on IPAFFS and familiar with the relevant notification procedures.

BTOM and Northern Ireland

Northern Ireland operates under a distinct set of rules due to the Windsor Framework. GB-to-NI movements of certain goods, including animals and food products, may be subject to different requirements compared to GB-to-EU or non-EU-to-GB movements. Importers moving goods into Northern Ireland should seek specific guidance on the applicable rules for their commodity.

Working with experienced border compliance experts ensures your supply chain is structured correctly from the outset. For end-to-end support on BTOM compliance, trusted import clearance services can manage the documentation and notification process on your behalf.

FAQ — Frequently Asked Questions

Source: GOV.UK — The Border Target Operating Model