Exporting to the UK: the Border Target Operating Model

Since 1 January 2020, the European Union (EU) sees incoming trade from the UK as trade from a third country, a country outside the EU. The UK has also drawn up its own trade rules. This is separate from the trade agreement between the EU and the UK. Below is an overview of the changes to the rules and border controls that will apply to products when exporting to the UK in 2024.

Changes for imports into the UK in 2024

The United Kingdom is gradually introducing its new Border Target Operating Model (BTOM) throughout 2024. This means additional customs rules and checks when exporting goods to the UK. The system will be implemented in multiple stages.

• 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.
• 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.
• 31 January 2025 - Safety and security declarations for EU imports will come into force. Alongside this, the UK will introduce a reduced dataset for imports. The goal is to reduce duplication in customs declarations.

31 January 2024: Health certification

Since 31 January 2024, the first step for exporters was to obtain health certificates for the shipment of animal, plant, and plant-based products to the UK. Your clients in the UK need these from you. This law only applies to products that are known to have a medium to high risk for the health of humans, animals, and nature. For example:

• Fresh, cooled, or frozen meat or meat products.
• Animal food that contains animal products.
• Sea animals and fish products.
• Other goods that contain animal products.

The British government has a list of which animals and animal products have a medium or high risk. The UK Department for Environment, Food & Rural Affairs (DEFRA) also has a list of plant and plant products and their risk level.

30 April 2024: Physical checks

Since 30 April 2024, British customs also physically checks these animal, plant, and plant-based products. These checks take place at so-called Border Control Posts (BCP). These can be found, for example, at UK ports and airports. A map of these locations is published in Annex F (page 128-133) of the Border Target Operating Model guidance.

31 January 2025: Safety and Security declarations

The final stage will start on 31 January 2025 (postponed from October 2024). From this date, a declaration to UK customs will apply to all import shipments from the EU. This is called a Safety and Security declaration. Your carrier, or logistics provider, will take care of this declaration for you. But you must first provide the correct information. For example, a copy of the health certificate. This can be scanned and sent as a PDF file to your carrrier.

Please note: this applies to all products, not only animal, plant, or plant-based products.

UK import rules introduced in 2021 and 2022

Following Brexit, the UK's initial changes to its import rules were set out in the original Border Operating Model proposal. The initial stages were introduced in 2021 and 2022. These included:

BOM Phase 1: valid from 1 January 2021

• Import rules and border controls apply to a limited group of products on the so-called 'controlled list'.
• Some examples of goods on the 'controlled list' are alcohol, tobacco, (bio) fuel, medicines, and protected animal and plant species.
• Import regulations and border controls apply to certain animal and vegetable products. This includes plants and vegetable products, packaging wood, (high-risk) animal by-products, products of animal origin subject to safeguard measures, live animals and fish products, and shellfish and crustaceans.
• Registered importers may postpone the import declaration for ‘standard goods’ (goods that are not on the controlled list) for 6 months.

BOM Phase 2: from 1 October 2021 and 1 January 2022

In Phase 2, new import rules apply to agricultural products and foodstuffs such as vegetables, fruit, cut flowers, plants, dairy, eggs, meat, and certain fishery products.

• From 1 October 2021, products of animal origin, such as cheese, meat, and dairy products, must have a veterinary health certificate.
• From 1 January 2022, agricultural products such as cut flowers, fruit and vegetables must have a phytosanitary certificate for export to the UK.
• The Netherlands Food and Consumer Product Safety Authority (NVWA) or another inspection service issues phytosanitary and veterinary health certificates, based on UK prescriptions. Certificates are arranged via E-CertNL, the official application for Dutch exporters. Check the Agriculture, fisheries & food page for an overview of inspection bodies.
• From 1 January 2022, for products with phytosanitary and veterinary health certificates, your trading partner, the UK importer, must pre-notify the shipment in the UK IT system known as the 'Import of products, animals, food and feed system' (IPAFFS).

Want to know more?

If you have any questions about the Border Target Operating Model, we advise you to consult the British government, see the links below. You can also contact the NVWA in the Netherlands.

The NVWA also has a tool available, the export assistant (in Dutch). You can use it to see what the requirements and export procedures are for each country and product.

The website Get ready for Brexit will guide you through the latest customs rules for all transport of goods between the EU and the UK.

Information for businesses in the Netherlands

• Dutch Food and Consumer Product Safety Authority (NVWA, in Dutch). Some information is available in English. There is also an FAQ (in Dutch) available.
• Rules for exports to the UK, provided by the Netherlands Enterprise Agency (in Dutch).
• KVK provides the latest information and advice for doing business with the UK.

Information from the UK government

• GOV.UK: Border Target Operating Model.
• GOV.UK: Overview for EU exporters.
• British Embassy in The Hague, or send your questions by email to the British Embassy in The Hague: DITNetherlands@fco.gov.uk.
• GOV.UK: a series of webinars about border requirements.