1.1 Background and context for this document
In April 2023, the UK Government published a draft ‘Border Target Operating Model’, applicable to imports from all countries into Great Britain, including the EU. In it, we outlined how our proposals sought to balance the need for effective border controls with the need to support businesses with import processes that are as simple as possible. We explained that with our new approach, we would harness our new freedom to set our own border policy and integrate the technological transformations set out in our 2025 UK Border Strategy.
There were over 10,000 registrations for workshops and seminars over the engagement period and over 200 stakeholders provided written feedback. This feedback welcomed many of the innovative elements of the model, and the importance of implementing robust security and biosecurity controls. Vets and the agricultural sector recognised the growing threat from animal and plant disease, such as African Swine Fever & Xylella fastidiosa, the potential economic and environmental consequences of these threats, and the importance of robust controls to combat them. However, businesses and the border industry highlighted where further detail was needed to prepare for the model, and set out a range of challenges that implementation of the new model would present. These were focussed both on new complexity and cost that would be introduced into the supply chain, as well as the timing of the introduction of new controls. In particular, businesses highlighted that their supply-chains would need time to adapt to new controls. This was particularly important in relation to the requirement for health certification which will require action from EU suppliers.
In response to this feedback we have decided to push back some of the implementation milestones for the Border Target Operating Model in order to give businesses more time to prepare. We will implement the Border Target Operating Model from January 2024 onwards, beginning with the introduction of health certification on relevant EU goods. This will bring the launch of the Border Target Operating Model closer to the upcoming simplification of border requirements through the new UK Single Trade Window. We have also sought to respond to stakeholder feedback to improve the wider model and provide further detail on its implementation.
This document sets out our final plans for a new Border Target Operating Model that incorporates and responds to feedback from stakeholders wherever possible. It has been developed with further collaboration across the UK, Scottish and Welsh Governments, and engagement with officials from the devolved administration in Northern Ireland. It is designed to set out to importers, the border industry and wider stakeholders the processes they will need to go through in order to import goods once the Border Target Operating Model is implemented. This sits alongside the ongoing review of customs declarations announced at Spring Budget 2023, which is exploring potential simplifications for both import and export customs declarations.
1.2 A new model for imports
The Border Target Operating Model sets out our new approach to Safety and Security controls (applying to all imports), and Sanitary and Phytosanitary controls (applying to imports of live animals, germinal products, animal products, plants and plant products) at the border. It sets out how controls will be delivered through simplification, digitisation and the UK’s new Single Trade Window.
For Safety and Security controls, the new model will minimise trader burdens and maintain border security while remaining aligned with international standards. Under our new model, we will:
- reduce the Safety and Security data requirements down from the current 37-field dataset to 20 mandatory fields. There are also up to 8 conditional fields, which may need to be completed in certain circumstances. The remaining 9 fields will be optional;
- make it easier to submit Safety and Security data through the UK Single Trade Window;
- improve the use of data by the UK Government to remove duplication (for example by allowing the use of Transit Security Accompanying Documents in place of separate Safety and Security and Transit declarations).
- remove Safety and Security requirements for the following categories of movement: certain outbound freeport goods leaving Great Britain, outbound transit for Great Britain and fish from UK waters landed in non-UK ports.
For Sanitary and Phytosanitary controls, our approach under the new model will have the following three key elements:
- A new 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, with controls appropriately weighted against the risks posed both by the commodity and the country of origin;
- Simplified and digitised health certificates: we will digitise phytosanitary certificates from 2023 with take-up depending on our trade partners’ readiness. We published simplified export health certificates in spring 2023 for animal products, and will deliver digitised export health certificates in 2024 leading to more automated use of data;
- Use trust: we will pilot schemes with industry where authorised importers of plants, plant products and some animal products may be eligible for facilitations to make importing easier. To qualify they will need to provide the enhanced assurances and evidence that they are meeting the regulatory requirements and standards.
The development of the UK Single Trade Window will underpin this new approach to controls. When fully operational, this will provide a single digital gateway for users to provide the data needed to trade and apply for licences and authorisations for trusted trader schemes. We recognise the complexity of the food-supply chain and will strive to ensure the introduction of new controls to mitigate biosecurity risks does not negatively impact the resilience or reliability of the UK’s food supply chain which is important to consumers. We appreciate that businesses and their supply chains will need to adapt their business models in response to the introduction of these new controls, and particularly the new Sanitary and Phytosanitary regime. We will support them wherever possible to do so. Businesses that use different models of groupage will be most impacted. We have worked with them over the engagement period to develop approaches that will facilitate groupage as far as possible. These are set out in Section 1.3.
1.3 Timeline for implementation
After engaging with stakeholders and considering the implementation challenges they raised, alongside the need to manage biosecurity risks, we have adapted the timeline we originally published in the draft version of the Border Target Operating Model in order to give businesses and their supply-chains more time to prepare.
We will introduce the new model in a phased approach that balances several factors: the need for effective management of biosecurity, public health, food safety and security risks; the need to give businesses sufficient time to prepare; the need to ensure supply chains have time to adapt and are not disrupted; and the speed at which we can work with stakeholders to build the systems and infrastructure required under the new model, including the rollout of the UK Single Trade Window. We will make any required changes to legislation to support delivery of the Border Target Operating Model when parliamentary time allows. A full implementation timeline can be found in Section 4.
We intend to implement the model through three major milestones (for goods moving from the island of Ireland, refer to Section 2 of this document):
- 31 January 2024 – The 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.
- 30 April 2024 – The introduction of documentary and 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 will move from destination to Border Control Posts. We will also begin to simplify imports from non-EU countries. This will include, the removal of health certification and routine checks on low risk animal products, plants, plant products from non-EU countries as well as reduction in physical and identity check levels on medium-risk animal products from non-EU countries.
- 31 October 2024 – The requirement for Safety and Security declarations for imports into Great Britain from the EU or from other territories where the waiver applies will come into force from 31 October 2024 as set out in the original Target Operating Model. Alongside this, we will introduce a reduced dataset for imports and use of the UK Single Trade Window will remove duplication where possible across different pre-arrival datasets – such as pre-lodged customs declarations.
Importers and their supply chains should already be preparing for the first milestone, with more time now available to ensure readiness. They should begin to prepare for the second and third milestones now.
We will publish further detail to support businesses and their supply chains to prepare. We will publish this detail through supplementary annexes to the Border Target Operating Model, and further guidance, that will be published on GOV.UK. A timeline for the publication of this further detail can be found in Section 4. We intend to work closely with importers and the border industry and will create a business readiness group that we will use to continue consultation with businesses on the further guidance and support they require to prepare.
1.4 How this applies to Irish goods and Northern Ireland Qualifying Goods arriving from Ireland
For goods moving from Great Britain into Northern Ireland, arrangements are set out under the recently agreed Windsor Framework. The Windsor Framework delivers a new system of green and red lanes at Northern Ireland ports for movements from Great Britain, in order to protect the UK’s internal market, whilst also providing reassurances on goods destined for the EU. At the same time, Northern Ireland businesses and citizens will continue to be able to purchase goods from the EU with no new barriers. None of the additional checks or controls set out in this Border Target Operating Model will apply to imports into Northern Ireland from the EU, providing Northern Ireland traders with full access to the EU market.
There is separate guidance for businesses on the new arrangements under the Windsor Framework, which can be found on GOV.UK. As such, this is not covered in further detail within this document.
In line with the introduction of border controls on EU imports set out within the Border Target Operating Model, businesses will face new checks and controls when moving Irish goods (i.e any goods other than Qualifying Northern Ireland Goods) from Irish ports (e.g. Dublin Port and Rosslare Europort) directly to Great Britain (e.g Liverpool port and Holyhead port). As well as implementing the new biosecurity and security controls set out in this Border Target Operating Model on Irish goods moving direct from Ireland to Great Britain, we will also bring in full customs controls for these movements, changing the current arrangements that apply when these goods arrive into Great Britain ports receiving traffic from Irish ports.
In line with the Windsor Framework, we will ensure that Northern Ireland businesses have unfettered access when moving qualifying goods to their most important market in Great Britain. These arrangements will be enshrined and further strengthened in domestic legislation, avoiding burdens for Northern Irish goods on both direct Northern Ireland-Great Britain and indirect Northern Ireland-Ireland-Great Britain routes.
Since January 2021, the definition of a Qualifying Northern Ireland Good has remained unchanged with this status conferred on any good that is or has been present in Northern Ireland without being subject to customs supervision, restriction or control or Northern Ireland processed products. This will remain the case for many businesses, however new arrangements will apply for traders moving food and feed products. To ensure the benefits of unfettered access are more squarely focussed on Northern Ireland traders, and taking on board feedback from agri-food and farming stakeholders in Northern Ireland, food and feed products will need to be owned or processed in Northern Ireland by a Northern Ireland registered or approved food or feed business in order to be considered a Qualifying Northern Ireland Good for Sanitary and Phytosanitary purposes and exempt from Sanitary and Phytosanitary import requirements.
This approach will entrench a significant competitive advantage for Northern Irish businesses on the island of Ireland, reflecting Northern Ireland’s integral place in the United Kingdom’s internal market.
We will phase in controls on non-qualifying goods, EU goods moving directly from Irish ports to Great Britain and goods such as excise goods. This will start, from January 2024, with customs controls and Sanitary and Phytosanitary pre-notification and certification where relevant. We will work with stakeholders, and the Scottish and Welsh Governments, to ensure this is done in a way which is fully compliant with the legal obligations in the UK Internal Market Act. Further detail and a timeline for implementation is set out in Section 2 of this document. ##Stakeholder feedback on the draft Border Target Operating Model
Following the launch of the draft Border Target Operating Model in April 2023, the Government ran a 6-week stakeholder engagement period. In addition to Government-led events for UK and international traders, and for our trading partners, various trade bodies organised their own events to which Government officials were invited. Around 10,000 participants registered for Government-led events and we received over 200 written responses to our online portal. We also received over 650 responses to our Sanitary and Phytosanitary focussed sessions from a wide range of stakeholders including food retailers, producers, the logistics sector and many more. Around half of respondents to the online portal were traders, with the majority involved in moving Sanitary and Phytosanitary goods. The majority of responding businesses identified as small or medium-sized enterprises.
There was considerable variation in views on the model across different groups of stakeholders. On the four questions we posed to stakeholders a summary of views is as follows:
Question 1: What are your views on the new model for Safety and Security controls, their impact on businesses and their implementation? Stakeholders broadly welcomed the reduction in the core data fields of the Safety and Security declaration and the ambition to use the UK Single Trade Window to simplify pre-arrival data submission. However, stakeholders pointed out that we needed to be clearer about which fields are mandatory and which are conditional, so we have clarified the details. They also asked that we look again at liability and the responsibilities of the carrier, and whether further facilitations of Safety and Security requirements are possible on certain types of movements. Due to the need to balance trader facilitations with protecting national security, we have not been able to accept all of the facilitations suggested, such as waiving the Safety and Security requirements for inbound empties, but further detail is provided in Section 1.2 on where we have gone further. Finally, stakeholders noted that without further technical detail on the operation of the Single Trade Window it was not yet possible to prepare systems for its introduction. Further detail on the timeline for development of the Single Trade Window is set out in Section 4.
Question 2: What are your views on the new model for Sanitary and Phytosanitary controls, its impact on biosecurity, animal health and welfare, food safety, businesses, as well as its implementation? The new risk-based approach to biosecurity controls was in general recognised for being innovative and an improvement on the model we would have introduced in 2022. The agricultural sector, veterinary groups and consumer groups noted the criticality of controls to protect the UK environment and human health. They noted the importance of ensuring that data and science was used to monitor and review the new regime to ensure it continued to provide robust biosecurity protections. Some exporters also welcomed the parity of treatment with UK exports to the EU, where full biosecurity controls have already been implemented by the EU on UK goods. Traders welcomed the model as an improvement over the model we inherited from the EU, particularly the proportional approach to risk and the ambition to use Trusted Trader schemes as part of the model. However, traders were clear that implementing new controls would make importing more difficult, and would particularly impact groupage models used for import. This in turn was likely to increase costs throughout the supply chain. While robust biosecurity controls necessarily introduce new requirements and costs we have set out refinements to the model in response to these concern in Section 1.3.
Question 3: What challenges exist for the private sector in meeting the proposed timeline for introducing the new model, and how can specific business models for importing be further supported to prepare? Businesses noted that the timeline for introduction presented a significant challenge. In particular they highlighted the need to give EU supply-chains sufficient time to prepare for new controls. The introduction of health certification and the need for EU exporters to put in place new processes to produce these was seen as the greatest challenge. Vets and the agricultural sector noted the threat from animal and plant disease, such as African Swine Fever & Xylella fastidiosa, continues to grow. They highlighted the economic and environmental consequences of these threats and the importance of biosecurity controls in combating them. Recognising the concerns of businesses balanced with the views of experts on biosecurity, we have responded to this feedback through a slight revision to the the implementation timeline of the draft Border Target Operating Model. Instead of the originally planned date of 31 October 2023 we will introduce health certification on 31 January 2024. Physical and documentary checks on Sanitary and Phytosanitary goods will be introduced on 30 April 2024 rather than 31 January 2024. This new timeline will ensure that biosecurity controls are introduced in a timely fashion, but will allow businesses the time needed to prepare.
Question 4: What further detail is needed in order for businesses to prepare for and implement the new Border Target Operating Model? Throughout the consultation process, stakeholders requested a range of further details to help them prepare and plan for the new model. We have set out below where this further detail was requested and where in this document it can be found.
| Safety and Security Controls | |
|---|---|
| Further detail was requested on the specific roles and responsibilities of both the carrier and the haulier when submitting S&S declarations. | Information on liability is outlined in Section 1.2. |
| Clarity on the mode/goods conditionality of certain fields with the S&SGB dataset outlined in the draft Border Target Operating Model. | An updated dataset showing conditional fields, as well as those optional and mandatory, is published in Annex A. |
| Importers sought further detail on the design and delivery of the UK Single Trade Window to allow them to prepare for the new S&S controls | Further detail on the UK Single Trade Window delivery approach is set out in Section 4. |
| Sanitary and Phytosanitary Controls | |
| Logistics providers, floriculture and food importers, retailers, PHAs, port operators and the agriculture sector requested more granular risk categorisation, down to each individual commodity code, to make necessary adjustments to their operations. | An updated commodity-code level breakdown of the risk categorisation for most animals and animal products of EU and EFTA origin, can be found here. For EU, Lichtenstein and Switzerland origin plants and plant products, the risk-categories can be found here. Risk categorisation for other trading partners has been published as a supplementary annex to this document. |
| Food importers fed back that the introduction of third country border controls on a subset of goods classified as medium risk would likely compound food inflation. | Following publication of the commodity-code level breakdown of EU and EFTA origin goods, most Sanitary and Phytosanitary goods will be deemed ‘low risk’ when the model comes into force, limiting the administrative burden required to import them as low risk goods do not require health certification. More information on the costs and benefits of the model can be found in Section 1.1. |
| Trade associations raised the impact of certification and checks on the use of groupage for imports. They highlighted that the additional cost and delay is likely to result in fewer groupage loads impacting smaller businesses in particular. | Facilitations for groupage movements and a pilot on health certification have been developed and are outlined in Section 1.3. The UK Government will continue to work with businesses to implement the new groupage schemes, including small and medium size businesses. |
| Businesses sought specific detail and are keen to see ambition on DEFRA’s Trusted Trader pilots. Many are keen to take part and understand the detailed requirements for approvals. | Further detail about the Trusted Trader assurance schemes and the approach to pilots is included in Section 1.3. |
| Transit | |
| Importers and the border industry asked for further clarity on how the new Border Target Operating Model would interact with transit movements used to import or move goods through Great Britain. | A new section setting out the operation of Transit movements can be found at Section 1.4. |
| Infrastructure and port operations | |
| Impacted businesses sought more information on the charging regime for HMG-run Border Control Posts to prepare for the second and third milestones. | A consultation on future charging arrangements for government-run Border Control Posts was open from 12 June until 9 July 2023.
A summary of responses will be published on GOV.UK following the consultation. Following the consultation Ministers will make the final decision on any legislative changes, taking into account responses received, and further information will be provided as supplementary guidance to this document. |
| Businesses importing goods requested detailed information about infrastructure at the short straits to allow them to understand where goods will be diverted. | Further information about the infrastructure at the short straits will be published as supplementary guidance to this document outlining wider plans for operational BCPs at the short straights in October 2023. |
| Systems and IT | |
| The border industry, intermediaries and customs technology firms sought more detail on upcoming systems changes to support delivery of the Border Target Operating Model, and the wider transformation of the border. | Further detail and systems maps are set out in Section 3. |
| Interactions with the Windsor Framework | |
| The border industry and importers sought more detail on the interaction of the Windsor Framework and the Border Target Operating Model, including clarity on the timing of West Coast checks as well as more clarity on how unfettered access is operationalised. | A new section has been added to this document setting out further detail on the interaction between the Windsor Framework and the Border Target Operating Model. This can be found in Section |
