The Border Target Operating Model effective from January 31st, 2024

The Border Target Operating Model (BTOM) impacts you if you import animal products, products of animal origin (POAO) or composite products from the EU or EFTA.

 

Does this impact your business'

If you import any derivative of animal product, you need to understand the changes, mitigate potential disruptions, and adapt to the new trade landscape.

BTOM impacts a range of individuals and groups involved in the UK's cross-border trade ecosystem, both directly and indirectly.

 

In brief here's a summary:

  • Exporters are required to be able to classify their goods into the risk categories - low, medium and high and follow the regulation for each risk level.
  • Import notification on IPAFFS (import of products, animals, food and feed system) 24 hrs prior crossing the border will be required for low-risk category goods.
  • Health certificate (EHC) and import notification on IPAFFS (import of products, animals, food and feed system) 24 hrs prior to crossing the border will be required for all medium and high-risk category goods.

The Border Target Operating Model (BTOM) categorises imports into three risk categories based on the potential threat they pose to human health, animal health, plant health, public safety and the environment. These categories determine the level of checks and controls applied to each import.

 

High Risk:

  • Live animals (excluding pets)
  • Products of animal origin (POAO) like meat, dairy, eggs, honey and animal by-products
  • Certain plant products with high pest and disease risks (e.g., fruits, vegetables, seeds)
  • Industrial goods with potential safety hazards

 

High-risk imports require the most stringent controls, including:

  • Full customs declarations with detailed documentation
  • Physical checks by border control officials
  • Potential laboratory testing for contaminants
  • Additional sanitary and phytosanitary certification

 

Medium Risk:

  • Some POAO from countries with less risk of animal diseases
  • Certain plant products with moderate pest and disease risks
  • Some industrial goods subject to safety regulations

 

Medium-risk imports undergo a moderate level of checks, including:

  • Simplified customs declarations
  • Potential physical checks based on risk profiling
  • Less frequent laboratory testing compared to high-risk goods

 

Low Risk:

  • Most processed food products with minimal animal content
  • Plant products with low pest and disease risks
  • Industrial goods posing minimal safety concerns

 

Low-risk imports benefit from the most streamlined procedure:

  • Simplified frontier declarations through the Customs Declaration Service (CDS)
  • No physical checks unless randomly selected
  • Minimal documentation requirements

 

Determining Import Risk:

The specific risk category of an import depends on several factors, including:

  1. Product type: The inherent risk associated with the product itself
  2. Country of origin: The prevalence of pests, diseases, and safety hazards in the exporting country
  3. Trader compliance history: The past record of the importer complying with customs regulations

 

Impact on Importers:

Understanding the risk categorization is crucial for importers as it determines the level of preparation and resources needed:

  • High-risk goods require extensive documentation, potential delays, and higher costs due to additional checks.
  • Medium-risk goods require moderate preparation and may experience some delays depending on specific checks.
  • Low-risk goods offer the fastest and most efficient clearance process.

Resources:
HMRC import customs declaration page: www.gov.uk/guidance/making-a-full-import-declaration

 

Who will be directly impacted and how'

Importers: Businesses and individuals bringing goods into the UK, particularly those importing medium and high-risk products like live animals, meat, plant products and certain industrial goods. They face stricter controls and potential delays with additional documentation and checks.

Exporters: While BTOM's main focus is on imports, UK exporters should be aware of potential indirect and direct impacts on their operations. You’ll need to adapt to the new Customs Declaration Service (CDS) for all export declarations and prepare for potential indirect effects from changed supply chains or future trade agreements.

 

  • Customs Declaration Service (CDS): All export declarations now need to be submitted through CDS. If you haven't already migrated from the CHIEF system, you need to do so before March 30th, 2024.
  • Safety and security controls: Existing safety and security controls for exports remain in place under BTOM. Ensure you understand and comply with these regulations for smooth clearance of your goods.
  • Future-proofing your operations: BTOM lays the groundwork for a more digital and risk-based approach to border controls. Adapting your processes and documentation to align with these evolving trends will prepare you for future trade scenarios.

 

The Spatial Global Freight Team are here to help!

Our aim is to help you stay informed, work with you to understand how the changes impact on your products, and adapting accordingly so you can minimise disruptions and continue importing and exporting your goods efficiently. Helping businesses navigate customs processes, will need to ensure their services and systems are compatible with BTOM and the new CDS platform.



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