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Labour has written to government demanding clarity on the Border Target Operating Model (BTOM) – the UK’s plan for bringing in remaining post-Brexit controls.

A draft of the model – which includes a risk-based approach to conducting sanitary and phytosanitary (SPS) checks – was published in the spring. The government was expected to have published the final version of the model earlier in the summer following a period of public consultation.

However, the first new checks in the draft model are due to be introduced from the end of October and the official version of the plan is yet to be published.


It was reported earlier this month, originally in the FT, that the government was looking to delay the implementation of the model to January 2024. These reports have not been denied by government.

Labour’s shadow international trade minister, Gareth Thomas MP, has called the delays “absolutely shambolic” in a letter sent to the government today (23 August). He wrote:

“They have delayed new border checks time and again, creating huge uncertainty for businesses, who are already struggling as a result of Conservative economic mismanagement.  

“With the deadlines for new checks just months away, it is unacceptable that businesses have not received a clear update from the government on whether the new border arrangements are even going to be introduced. The Tories’ trade barriers are stunting economic growth.

The first version of the government’s plans for introducing import checks on goods entering the country from the EU – the then-titled Border Operating Model (BOM) – was first published in July 2020.

“Labour will turn this around as part of our mission to secure the highest sustained growth in the G7,” Thomas added.

Certainty needed

Marco Forgione, director general of the Institute of Export & International Trade (IOE&IT), agreed that traders “require certainty and clarity to be able to plan for the future”, saying that the implementation of BTOM was a “key aspect of this”.

He added that it was important that the current asymmetry between import and export controls – with UK exporters having been required to comply with EU import controls since Brexit, over two and a half years ago – needed to be addressed.

“The full implementation of the BTOM is important to address imbalance which currently sees UK businesses exporting to the EU subjected to checks which EU businesses exporting to the UK are not.

“This disparity presents a real commercial disadvantage for UK businesses and the BTOM is an important step in levelling the playing field.

“As the continued delays will prolong this uncertainty for all those involved in the import of SPS goods to the UK, from the EU and the rest of the world, it is important that this is taken into account when timings are being considered.”

Publication imminent

A Cabinet Office official has responded to Thomas’ letter by telling Politico that it will be publishing the final version of BTOM “imminently”.

A government spokesperson said: “We are reflecting on the valuable feedback provided by a range of businesses and industry stakeholders and will publish the BTOM shortly."

A Conservative Party told Politico that the opposition was “just shouting from the side-lines with no plan yet again”.