The Border Target Operating Model (BTOM) is the UK's target border control model, rolled out in stages from 2024, which sorts plant and animal products into risk categories — low, medium and high — and bases the scope of required documents and physical checks on them. Medium- and high-risk goods require a declaration in the IPAFFS system before arrival and may be subject to inspection at a designated Border Control Post (BCP). Below we explain how to check your goods' risk category and prepare for inspection.
Contents
In brief — what you'll learn
- ✓ How to prepare the process and documents
- ✓ How the declaration and check are carried out
- ✓ How to maintain compliance and settlements
How to prepare the process and documents
Division of responsibility between the parties
Minimum data set for the declaration
The minimum data set for a customs declaration should include: an EORI number, the CN code of the goods, the customs value, the country of origin, and identification details for all parties to the transaction. Checking this data is complete before submitting the declaration eliminates the need for corrections and speeds up the release of goods by the customs authority.
Find out more about UK customs agency services.
How the declaration and check are carried out
Operational stages from pre-notification to release
The most common risk points and how to reduce them
How to maintain compliance and settlements
Record-keeping, corrections and evidence of due diligence
Customs documents must be kept on file for a minimum of 4 years under section 23 of TCTA 2018, or 5 years for businesses registered for VAT. Corrections to declarations must be submitted promptly once an error is found — a delayed correction can be treated as negligence and result in a higher financial penalty and the import VAT deduction being challenged.
Working with a customs agency and internal audit
Regular cooperation with a customs agency and an annual internal audit help catch discrepancies between operational practice and official requirements before they become the subject of a check. Reviewing procedures against current HMRC and KAS guidance reduces the risk of non-compliance and makes it easier to defend your settlements during any tax or customs inspection.
Summary
In summary: in the area of 'Border Target Operating Model', what matters most is running the process according to current official guidance, with a clear division of responsibility and documentation of every decision. This approach reduces delays, cuts the number of corrections needed and makes it easier to defend your settlements during a check. If any requirement is unclear, check the current guidance from GOV.UK, HMRC and KAS.
Legal basis and sources
- CIRCABC: TARIC database extraction notes
- Ministry of Finance (Poland)
- KAS: Polish National Revenue Administration
If the regulations or system announcements are updated, check the current GOV.UK or KAS guidance before submitting a declaration.
Frequently asked questions
What is the Border Target Operating Model and who does it apply to?
The Border Target Operating Model (BTOM) is the UK government's operational framework governing the control of goods crossing the UK border. It applies to all businesses importing or exporting goods between the UK and the EU, including Polish exporters, forwarders and customs agencies handling this trade corridor.
What documents are needed for customs clearance under BTOM?
The minimum set of documents includes: a commercial invoice, a packing list, a certificate of origin (where required), phytosanitary or veterinary certificates for regulated goods, and an MRN confirming the customs declaration has been submitted. For T1 transit, a transit guarantee is also required.
How can I effectively avoid delays at the UK border?
It's essential to submit the customs declaration before the vehicle arrives (pre-lodgement), ensure the data on the invoice and the customs declaration match, and give the driver the MRN and release document before departure. Introducing an internal checklist that verifies document completeness at least 24 hours before clearance significantly reduces the risk of a shipment being held.
Who is responsible for the accuracy of a customs declaration — the importer or the customs agency?
Legal responsibility for the accuracy of the declaration rests with the importer holding the EORI number, even when the declaration is submitted by a customs agency. Under direct representation, responsibility stays with the importer; under indirect representation, it is joint. This is why it's essential to precisely define the scope of the customs power of attorney before the first declaration is submitted.
How long must customs documents be kept, and what are the consequences of not keeping records?
Customs documents must be kept for a minimum of 4 years under section 23 of TCTA 2018, or 5 years for businesses registered for VAT. Missing documentation during a check can result in the import VAT deduction being challenged, outstanding duty being charged with interest, and the loss of Authorised Economic Operator (AEO) status.
Related guides
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