Border Target Operating Model - a new approach to importing goods to Great Britain

What is the Border Target Operating Model?

The Border Target Operating Model sets out the new approach to importing goods into Great Britain from all countries, including the EU. These customs controls have been progressively introduced from the end of January 2024.

Sanitary and Phytosanitary (SPS) controls

If goods transit through the UK and pose a biosecurity and public health risk they will need to follow Sanitary and Phytosanitary (SPS) controls.

The SPS controls used are those recognised and applied around the world. This will provide biosecurity as well as using trusted trader and assurance schemes to reduce checks at the border. You will need to know the risk category of the goods you are transiting, and you may need a health certificate.

Animal products

From 31 January 2024: Animal products required pre-notification, and some required health certificates.

From 30 April 2024: as above but some imports may also be subject to non-routine or intelligence-led checks, and some will require 100% documentary checks and identity seal checks on entry and exit.

Live animals

After October 2024: Additional documentary, identity and physical checks for live animals from the EU and entry/exit will take place at specific Border Control Posts (BCPs).

Plants and plant products

No pre-notification necessary, but your signed declaration needs to meet SPS controls.

Goods from Ireland

There are slightly different timelines to those above - from 31 January 2024 there has been a requirement to pre-notify before the consignment enters UK.

No earlier than October 2024: Identity, physical and seal checks will commence.

How to prepare for the new import controls

We recommend that you undertake an analysis of the goods moved within your supply chain to understand their category from an SPS perspective, and what controls are applicable to those goods at the border.

We also recommend that you speak to your manufacturing operations and suppliers to collate the necessary information in advance of the changes to make sure there is no hold up at the border due to missing evidence and documentary requirements.

Common problems with goods moving in and out of the UK

Incorrect SPS classification of products e.g. designating as composite product incorrectly
Multiple health certificates attached to single shipments causes clearance delays
EU address details being used instead of a UK address for entity or person introducing the goods into GB/NI
Documentation errors – documents are dated incorrectly, not signed or without an official seal if it’s a wet ink paper version.

How can we help?

For help and advice on any trade-related issues between GB and NI or the EU, please get in touch. We can offer direct declaration support with no need for any IT implementation lead times or costs.

We can also help you to review historical movement of goods and identify where supplementary declarations should be submitted, and support you in the submission process.

Speak to a customs expert

Frequently asked questions

Is there a timetable for how long we can continue to use ‘Importer's knowledge’ as proof or origin?

The facility to use importer’s knowledge as an alternative to a statement of origin from the exporter is written into Article 54 of the Trade and Cooperation Agreement (TCA).There is no time limit or expiry on this - any change would likely require a renegotiation of the TCA.

Is there a requirement to evidence importer's knowledge?

Yes. You must hold sufficient records (4 years) to prove that the goods originate in the exporting territory. TCA Article 59 states this – and this is a common area of audit by HMRC and risk for importers. More detailed guidance can be found on GOV.UK.

Is transporting materials or equipment using our own van for them to be used to perform services abroad subject to customs and declaration changes?

Depending on several factors - the type of equipment, the time that it will spend outside GB and the exact purpose of the equipment, etc. – customs controls might apply. To avoid paying unnecessary duties, customs procedures may be utilised in the form of an ATA Carnet, Temporary Admission and Returned Goods Relief.

If the duties on import into the EU are nil for a product, are you still required to produce a statement of origin?

A statement of origin will not be required to claim preferential origin if the tariff is 0%. However, the importer might ask for statement of origin for different purposes, e.g. the goods are imported for processing or manufacturing and the goods will be re-exported again or will be incorporated into another product. The importer will need proof from the supplier about the origin of that product. The supplier has control and the knowledge of the originating status over the delivered goods and, therefore, the supplier is in the best position to give information about the originating status of the goods.

As a retailer we arrange for manufacture of goods in the EU. These goods are shipped to our UK distribution centre. When we export these goods back to the EU, do they have UK, EU or no known origin?

This is a complicated area. Under the TCA, the general principle is that if goods that are manufactured in one Party meet the relevant origin rules, they obtain preferential origin status for that Party - i.e. EU. It is the 'preferential' status which allows for their duty-free import into the other Party, i.e. UK. If goods are not further processed in the UK and are subsequently returned to the EU in the same state, they would, in principle, still be considered to be of EU origin, but they lose their 'preferential' status so that duty does become due on 're-import' into the EU. There may be solutions to this issue, but they are subject to supply chain criteria.

If two items are sent to EU, one UK origin and one not UK origin, how should that be declared? And how will it be treated by EU customs?

It depends on whether preferential origin rules are met and whether preferential origin is claimed or not during importation. For example, if only one of the products meets the preferential origin rules and the other doesn't, then that product should be declared as claiming preferential origin and the other just as a normal import (which might be subject to customs duty payments if the goods are subject to positive duty rate).

With regard to Long-term Supplier’s Declarations (LTSD) for goods having preferential origin status, where goods are of UK origin can a UK company issue an LTSD to a UK company for evidence or should they be issuing a statement of origin?

It depends on the circumstances. A supplier’s declaration is issued for single consignments and must be repeated for each consignment. If regular supplies are made, then an LTSD can be issued. It is a one-off declaration valid for supplies delivered during a period up to a maximum of 2 years and valid for all the goods mentioned in the supplier’s declaration that are delivered within the specified period. The LTSD should be reviewed regularly, and any changes must be communicated immediately to all parties involved.

As a trader in the UK, we send goods to the EU. Sometimes we use polystyrene chips or bubble wrap inside the box, is this still subject to tax? If so, are we responsible to pay this?

You will be liable to the tax if you manufacture the polystyrene chips or bubble wrap that you place in the boxes.

If you buy the Polystyrene chips and bubble wrap as packaging and then use it, you do not have to pay the tax as it falls due on the manufacturer (although the cost will probably be passed on to customers in the costs of the packaging). However, if the supplier defaults on their payment of the PPT then you may have a liability under the joint and several liability rule. To avoid a charge in this scenario, you should undertake regular supplier checks that they have paid the tax and evidence this for production to HMRC. If you are exporting, then there may be an exemption applicable if certain time limits are met and evidenced.