The Border Target Operating Model (BTOM) is the framework HMRC and Defra are using to phase in full sanitary, phytosanitary and customs controls on imports from the EU. After several delays and adjustments, the model is now substantially in force. Importers who treat EU trade as if it were still the easy ride of the early Brexit years are now seeing the consequences at Border Control Posts (BCPs). Here is the current state of play.
What BTOM actually covers
BTOM applies to three streams of controls:
- Customs controls — full declarations and safety and security data on all imports from the EU
- Sanitary and phytosanitary (SPS) controls — checks on animal products, plants, plant products and high-risk foods
- Safety and security controls — ENS declarations through the GB S&S service
Each stream has its own risk categorisation (low, medium, high) which determines the type of check required at the border.
Where things stand in 2026
The risk-based SPS regime is now fully active. Medium-risk plant and animal products require pre-notification on IPAFFS and may be selected for documentary, identity or physical inspection at a designated Border Control Post. High-risk products almost always face inspection. Low-risk products require pre-notification but rarely face physical checks.
Common Health Entry Documents (CHEDs) — IPAFFS notifications — must be submitted before the goods reach the UK. Late notification is a frequent cause of trucks being held.
What importers of EU goods must do
If you import from the EU you should now have in place:
- An EORI number, registered to CDS
- A clear understanding of whether your goods are in scope for SPS controls
- An IPAFFS account if you handle animal or plant products
- A nominated Border Control Post for each commodity stream
- A duty deferment account or PVA setup for VAT and duty
- A reliable customs broker who can file declarations and notifications 24/7
Importers who consolidate from multiple EU suppliers should also review their groupage arrangements. A single non-compliant line in a groupage load can hold the entire truck.
Common BTOM mistakes
- Assuming all food products are low risk
- Submitting an IPAFFS pre-notification but failing to update it when the consignment changes
- Routing through a port without an appropriate BCP for the goods
- Forgetting that organic products may require additional certification
Looking ahead
HMRC and Defra continue to fine-tune the BTOM risk categories. Expect periodic reclassifications and new commodity-specific controls. Importers should not rely on a static checklist — every shipment needs to be reviewed against the latest published lists.
Need help?
PCS Port Clearance Services Ltd handles BTOM-compliant clearances at every UK port with appropriate BCP capability. We can submit IPAFFS pre-notifications, advise on commodity risk levels, and align your declarations with the latest BTOM requirements. Call +353 1 960 2215 or email customs@pcsl.uk.com to talk to an AEO-licensed broker.