Post-Brexit import controls delayed again but new model will bring 'considerable benefits' to trade

Tue 29 Aug 2023
Posted by: Phillip Adnett
Trade News

Freight containers on either side of the EU and UK borders

The government has announced another delay to the introduction of post-Brexit border controls on EU goods entering Britain.

The Border Target Operating Model (BTOM) includes the UK’s plan for introducing a “simplified and digitised” approach to implementing controls, including sanitary and phytosanitary (SPS) checks on agrifood products.

In a statement today (29 August), the government confirmed that proposed border checks on live animals, animal products, plants and plants products would be delayed by three months and will now come into effect from 31 January 2024 onwards.

The original checks were supposed to come into force in 2021, but have been delayed five times due to the pressures businesses have faced as a result of the pandemic and the war in Ukraine.


A draft of BTOM – which includes a risk-based approach to conducting SPS checks – was published in the spring.

Under the plan, SPS goods will be sorted into three categories – ‘low’, ‘medium’ and ‘high’ – which will determine the level of checks and documentation that will to enter Great Britain.

The government was expected to publish the final version of BTOM earlier in the summer, with the first new checks due for introduction from the end of October onwards.

Wider picture

The government says that the most recent delay was due to industry feedback and hopes that the additional three months will give traders more time to prepare for the new checks.

Baroness Neville-Rolfe DBE CMG, Cabinet Office minister, said:

“By making maximum use of data and new technologies, our innovative yet risk-based approach is key to delivering a world-class border system.

“Once fully implemented, these important post-Brexit measures will, I believe, bring considerable benefits to the UK economy and to UK trade, and the government stands ready to support businesses through this transition.”

Digital approach

The government says the new model will lead to controls being “simplified and digitised” and is complemented by its “ambitions for the UK’s new Single Trade Window” to be introduced in the coming months.

The model also coincides with the passing into law of the Electronic Trade Documents Act, which enters into force on 20 September 2023.

New timeline

The government has announced the new timeline as follows:

  • 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 – New 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 October 2024 - New safety and security declarations for EU imports will come into force


Labour had previously criticised the government’s delay in publishing the full BTOM plan, saying it was causing “huge uncertainty” to businesses.

Institute of Export & International Trade (IOE&IT) director general Marco Forgione welcomed the “innovative approach set out in BTOM”, adding that the plans should not be looked at in isolation:

“There are several other key initiatives taking place as part of the Border 2025 strategy aimed at making the UK border one of the most effective and efficient. This approach has the potential to convert our borders into engines which support economic growth.

“In addition, we encourage the government to move as fast as possible to implement the findings of the customs initiatives announced at the Spring Budget.”

You can read more of Forgione ’s comments here. IOE&IT will also be running a webinar about the new timeline and what traders need to do to prepare on 4 October 2023, which you can sign up to here.