The Border Target Operating Model: Key Takes For 2024

The landscape of international trade is ever-evolving, and as we step into 2024, the implications of the Border Target Operating Model (BTOM) are at the forefront.

The final Border Target Operating Model sets new measures for all imports to the UK and introduces new sanitary and phytosanitary controls for live animals, animal products, plants, and plant products at the border.

Notably, the BTOM seeks to streamline and digitise processes, alongside implementation of the UK’s Single Trade Window.

In a departure from the original timetable for controls on EU imports in April 2022, the government collaborated with businesses to forge a new approach. This final BTOM will govern imports into Great Britain (GB) from all nations, including the EU, aligned with the 2025 UK Border Strategy.

The goal of the BTOM is clear: balancing efficient border controls with simplified import processes. The final document, though, is anything but. So read on, as we provide an executive summary designed to give UK importers all the information they need at a glance.

Or, if you’re interested in customs compliance consultancy, or import/export training, don’t hesitate to get in touch.

Background

In April 2023, the UK Government introduced a draft Border Target Operating Model. This blueprint, applicable to imports from all countries including the EU, aimed to:

• Fortify effective border controls
• Provide support for businesses through streamlined import processes

An extensive engagement period ensued, 10,000+ registrations for workshops and seminars, coupled with written feedback from over 200 stakeholders.

The response was varied. Stakeholders, particularly from the veterinary and agricultural sectors, applauded the most innovative elements of the model, recognising a need for robust security and biosecurity controls.

Some concerns were raised by businesses and the border industry though, emphasising the additional burden and detailed information required.

Updates To the BTOM

And so, adjustments were made.

Certain implementation milestones for the Border Target Operating Model were deferred, to afford more time for preparation. The revised plan, active from the end of January 2024, began with the introduction of health certification on relevant EU goods.

August 2023 saw publication of the updated Border Target Operating Model. This document encapsulates the final iteration of the BTOM, incorporating feedback, and fostering collaboration across the UK, Scottish and Welsh Governments, and officials from the devolved administration in Northern Ireland.

A New Model For Imports

The Border Target Operating Model aims to change the way safety, security, and sanitary and phytosanitary controls are approached for UK imports. It is intended to be innovative and forward-facing, in alignment with the vision for modern trading.

Safety and Security Controls

In a bid to strike a delicate balance between robust security measures and trader convenience, the Border Target Operating Model details a new approach to Safety and Security controls.

Highlights:

• Data Requirements Transformation: The model significantly trims down the Safety and Security data requirements. The previous 37-field dataset reduced to only 20 fields as mandatory, with 8 conditional fields (depending on circumstances). 9 fields became optional.
• Data Submission: Traders will find it easier to submit Safety and Security data through the UK Single Trade Window.
• Data Utilisation: The model eliminates data duplication by allowing the use of Transit Security Accompanying Documents in lieu of separate Safety and Security and Transit declarations.
• Exemptions for Certain Movements: These include outbound freeport goods leaving Great Britain, outbound transit for Great Britain, and fish from UK waters landed in non-UK ports.

Sanitary and Phytosanitary Controls

As it applies to Sanitary and Phytosanitary (SPS) controls, the Border Target Operating Model is aimed at innovation, risk mitigation, and digital transformation.

Highlights:

• Global Risk-Based Approach: Live animals, germinal products, products of animal origin, animal by-products, plants, and plant products will be categorised as high, medium, or low risk. Controls will be tailored to align with the perceived risks associated with both the nature of the commodity and the country of origin.
• Digitisation of Health Certificates: The model envisages the digitisation of SPS certificates, subject to the readiness of trade partners. The goal is to achieve a higher level of automation in data utilisation, reducing manual interventions and expediting the import process.
• Building Trust Through Industry Pilots: Authorised importers dealing with plants, plant products, and select animal products may be eligible to pilot streamlining facilitations. To qualify, importers must provide enhanced assurances and evidence of compliance.

The Timeline

See below the government’s planned implementation and rollout schedule for the BTOM, comprising three key milestones:

31 January 2024

Introduction of health certification on imports of medium risk animal products, plants, plant products and high-risk food and feed of non-animal origin from the EU.

The removal of Pre-notification requirements for low risk

plant and plant products from the EU removed.

30 April 2024

Introduction of documentary, risk-based identity and

physical checks on medium-risk animal products, plants, plant products and high-risk food and feed of non-animal origin from the EU.

Existing inspections of high-risk plants / plant products from the EU move from destination to Border Control Posts.

Simplification of imports from non-EU countries begins, including removal of health certification and routine checks on low-risk

animal products, plants, plant products from non-EU countries, and reductions in physical / identity check levels on medium-risk animal products from non-EU countries.

31 October 2024

Requirement for Safety and Security declarations for imports into Great Britain from the EU / other territories (where waiver

applies) becomes effective.

Introduction of reduced datasets for imports, and use of the UK Single Trade Window will remove duplication (where possible) across different pre-arrival datasets.

Irish Goods & Northern Ireland Qualifying Goods

The Border Target Operating Model introduces an updated framework for managing movement of Irish goods. Qualifying goods from Northern Ireland are dealt with under the Windsor Framework.

These measures aim to strike a delicate balance, ensuring the integrity of regulatory controls while safeguarding the streamlined movement of goods critical to the interconnected markets of Ireland, Northern Ireland, and Great Britain.

Key Aspects of Irish Goods Movement:

1. Biosecurity and Security Controls: New checks and controls for Irish goods moving directly from Irish ports to Great Britain will come into effect. This includes the implementation of biosecurity and security controls outlined in the model.
2. Customs Controls: Full customs controls will be instituted for goods from the Republic of Ireland moving directly to Great Britain.

Qualifying Northern Ireland Goods:

1. Unchanged Definition: The definition of Qualifying Northern Ireland Goods, unchanged since January 2021, remains effective. NI Qualifying Goods are for sale in Northern Ireland only (not the Republic), and can be traded between NI and GB without customs checks..
2. New Arrangements for Food and Feed Products: New arrangements are introduced for traders dealing with food and feed products. To qualify as a Qualifying Northern Ireland Good for Sanitary and Phytosanitary purposes and be exempt from relevant import requirements, food and feed products must be owned or processed in Northern Ireland by a registered or approved Northern Ireland food or feed business.

Phased Controls on Non-Qualifying Goods:

From January 2024, controls on non-qualifying goods, including EU goods moving directly from Irish ports to Great Britain and excise goods, will be phased in.

How To Ensure Ongoing Customs Compliance

As the Border Target Operating Model unfolds and ushers in a new era of border controls and regulatory frameworks, ensuring ongoing customs compliance is paramount for businesses navigating the complex landscape of international trade.

Non-compliance can lead to penalties and fines, adversely impacting your bottom line.

It ensures the smooth movement of goods across borders, preventing delays and disruptions that can tarnish your reputation and disrupt your supply chain.

At clearBorder, we offer dedicated customs compliance consultancy services, ensuring that your business stays ahead of the curve. Choose us for:

• Specialised knowledge
• Tailored solutions
• Proactive support

Don’t let the complexities of new BTOM customs regulations act as stumbling blocks for your business. Contact us today and fortify your business for the challenges and opportunities that lie ahead.