BTOM After Brexit - What an Importer Should Check Before Moving Goods

BTOM is not a topic "for later" if you ship goods to the United Kingdom that are subject to sanitary or phytosanitary controls. It is the risk category, the documents and the pre-notification obligation that determine whether a consignment goes through smoothly or gets stuck on operational gaps.

This guide organises the topic from the perspective of a business bringing goods into the British market: what BTOM is, what needs to be checked before goods move, and where mistakes most often occur in documents and delivery preparation.

What is BTOM

BTOM, or the Border Target Operating Model, is the UK's border model based on risk assessment. Obligations such as a certificate, pre-notification, and document, identity or physical checks depend on the type of goods and their assigned risk category. For goods from the EU the new controls were introduced in phases: from 31 January 2024 (certificates for medium-risk goods), from 30 April 2024 (documentary, identity and physical checks and the Common User Charge) and from 31 January 2025 (ENS safety and security declarations). The model is described in GOV.UK: The Border Target Operating Model, and how it fits with the ENS and GMR is covered in ENS, GMR and BTOM.

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Risk categories

Plants and plant products from the EU are divided into high risk, medium risk A, medium risk B and low risk; low-risk goods do not go through plant health controls (GOV.UK). Animal products (risk categories for animal products) and high-risk food and feed of non-animal origin are categorised in a similar way. Risk assessments are reviewed on an ongoing basis, so the category should be checked before every shipment. Medium risk A and B fruit and vegetables from the EU are temporarily treated as low risk – no phytosanitary certificate, notification or checks.

What to check before goods move

1. The risk category of the goods and whether they are subject to SPS checks.
2. The certificate: for high-risk and medium risk A and B plants, the EU exporter must obtain a phytosanitary certificate from the plant health authority of its country, issued no more than 13 days before or after the consignment leaves; medium- and high-risk animal products need a health certificate (Export Health Certificate, EHC), while low-risk products do not.
3. IPAFFS pre-notification: the importer on the UK side must be registered in IPAFFS and notify high-risk and medium risk A consignments at least 4 working hours before arrival (ro-ro and air) or 1 working day (other freight). Details: IPAFFS notification and when goods need IPAFFS.
4. Checks: whether the consignment will be sent for a document, identity or physical check at a border control post.
5. Charges: imports through Dover or Eurotunnel are subject to the Common User Charge, and fees are charged for plant health checks.
6. Accompanying declarations: the ENS, the customs declaration in CDS and – at GVMS ports – a GMR (import clearance into the UK step by step).
7. Agreement with the supplier and haulier – whether everyone has the same picture of the border obligations.

Where businesses most often lose time

• assuming that because the goods went through without issue before, nothing has changed,
• not checking the current risk category before the next shipment,
• confusing the obligations relating to IPAFFS, certificates and commercial documents,
• bringing in an agency or haulier to confirm the requirements too late,
• not establishing who on the UK side lodges the pre-notification and what data the exporter must supply.

What to do before shipping

The safest approach is to close the matter off before goods move: check the risk category, the full set of documents, and whether the transport and the recipient on the UK side know how the rest of the process runs. This is especially important for fresh produce, plants, goods subject to SPS controls, and deliveries carried out under time pressure. How the UK–EU SPS agreement may change these rules in future is covered in the UK–EU SPS agreement and food exports.

See also the video material

This material organises the BTOM changes and shows why, after Brexit, general knowledge of trade rules alone isn't enough without checking the current border requirements.

Official sources

• GOV.UK: The Border Target Operating Model
• GOV.UK: Import plants and plant products from the EU to Great Britain
• GOV.UK: Risk categories for animal and animal product imports to Great Britain
• GOV.UK: Common user charge – rates, eligibility and invoices

Related guides

• Exporting food to the UK — EHC, IPAFFS requirements and SPS checks
• When goods require IPAFFS
• UK–PL customs consultations for import and export

Summary

BTOM isn't compliance theory — it's a real operational filter for consignments to the UK. If you want to check the risk category, documents and obligations for a specific product before shipping, get in touch with us.

Frequently asked questions