From 31 January 2024, the UK will implement changes to import procedures for food and drink from the European Union (EU), introducing a categorisation system based on risk levels under the Border Target Operating Model. The move is part of the UK government's measures to improve regulatory standards in the post-Brexit era.
From 31 January 2024, importers wishing to bring food and drink from the EU into the UK will still need to follow the current Animal and Plant Health Agency (APHA) process.
However, for those in the medium Border Target Operating Model (BTOM) risk category, an additional step will be to obtain a health certificate from the EU exporter, where available. Certain products may require an official declaration by the importer, with the health certificate indicating when such a declaration is required. Importers may also need an import licence or authorisation.
Between January and April 2024, random documentary checks will be introduced on animal products with a medium BTOM risk originating from the EU, Iceland, Switzerland, Norway and Liechtenstein. Importantly, goods subject to these checks will not be subject to inspection delays or additional fees. For low BTOM risk imports, a commercial document will be required and importers may also need an import licence or permit.
At the same time, from 31 January 2024, the UK will introduce sanitary and phytosanitary (SPS) checks on live animals or animal products entering the UK from the EU and European Free Trade Association (EFTA) countries.
Understanding the Target Operating Model
CustomsLink has previously explained to Trans.iNFO that to comply with the new measures, importers must first determine the Target Operating Model (TOM) risk category for the commodity being transported.
TOM classifies live animals, germplasm, products of animal origin (POAO) and animal by-products (ABPs) into high, medium or low-risk categories, each with different requirements.
Two documents provide access to the TOM risk categories via summary tables and a searchable list of commodity codes. Composite products from the EU and EFTA countries either fall into the low TOM risk category or are exempt from import controls.
For consignments in the low TOM risk category, the Import of Products, Animals, Food and Feed System (IPAFFS) should be used to notify the authorities and no export health certificate is required. However, for medium and high TOM risk categories, an export health certificate from the competent authority in the country of origin may be required. Goods in the high TOM risk category are subject to ongoing physical import controls.
In the absence of an export health certificate issued by the exporting company, importers may require an import licence or authorisation. CustomsLink recommends contacting the Animal and Plant Health Agency (APHA) Animal Imports Team for guidance.
Looking ahead, from 30 April 2024, new border controls will be introduced for medium BTOM risk goods from the EU. All medium and low BTOM risk goods will need to enter through a designated point of entry with the appropriate border inspection post, marking the next step in the post-Brexit customs regime.
