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UK Import Controls: The Border Target Operating Model (TOM)
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In 2024, the UK is introducing new customs and SPS requirements on all goods imported into Britain from the EU, including Ireland, as part of its Border Target Operating Model .
These new rules impact all Irish traders exporting goods to Great Britain or via the UK landbridge to the rest of Europe and are in addition to the existing formalities that apply when exporting goods from the EU.
The first phase of the new UK import controls have been in place since 31 January 2024, with the next stage taking effect on 30 April 2024.
From 30 April 2024, the UK is introducing documentary and risk-based identity and physical checks on imports of medium risk animal products, plants, plant products, and high risk food and feed of non-animal origin from the EU except for the island of Ireland.
While these changes will not impact traders exporting goods from Ireland directly to GB, they will impact traders moving goods under transit to or from Ireland across the UK landbridge to or from the rest of the EU.
- Transit consignments from Ireland travelling across GB and exiting GB via east coast ports will be subject to documentary checks, exit identification and inspection controls and will be required to confirm that consignments have exited the UK.
- Transit consignments to Ireland from the rest of the EU entering GB via east coast ports will be subject to documentary checks, entry identification and inspection controls.
These controls will take place at designated UK Border Control Posts (BCPs). A full list of designated UK BCPs can be accessed here .
For more information on the new UK requirements, review the UK Government's guidance on transit movements.
The new UK checks and controls will be subject to fees.
For the Government-run BCP at Sevington, the UK Government is introducing a Common User Charge on 30 April for commercial movements of animal products, plants and plant products. The charge applies to both imports and transit movements Further information on the UK's common user charge is available here .
Commercial (private) British ports and relevant Port Health Authorities will set their own charging structure and rates for traders using their services.
UK guidance is that medium and high risk SPS goods being moved across the UK landbridge in either direction should be sealed with commercial seals. Seals may be checked at East Coast ports either on entry or exit from GB.
For goods moved across the UK landbridge from Ireland to the rest of the EU, confirmation that the goods have exited Great Britain must be provided to the exit BCP.
All requirements previously introduced in January 2024 (see below) continue to apply.
Further UK Government guidance on their new requirements can be found below .
If your company uses the UK landbridge to export or import goods from the rest of the EU, you should take steps to ensure you are ready for the next stage of UK import controls on 30 April:
- Familiarise yourself with the UK transit guidance and all other guidance issued by the UK and review your business practices to ensure that you can comply with the new requirements.
- Engage with everyone in your supply chain, including your logistics or transport provider, to make sure they are aware of the new requirements and what they have to do.
- Ensure all consignments travelling across the UK landbridge are sealed with commercial seals. Failure to do so may result in a physical inspection of the consignment if it is called to attend a UK BCP for an identification check.
- If you move goods through the Port of Dover or Eurotunnel, factor the new common user charge into the cost of transporting the consignment. If you transport goods through a commercial port, engage with the relevant Port Health Authority to determine if a fee will apply.
- If you move goods across the landbridge from Ireland to the rest of the EU, determine who in your supply chain will issue confirmation to the exit BCPs that the consignment has exited Great Britain.
Since the UK’s new import controls came into effect on 31 January 2024, when you are exporting goods to Great Britain or via the landbridge to the rest of Europe, you will need to have completed all of the following UK import requirements in addition to the existing formalities that apply when exporting goods from the EU:
- Ensure your GB importer or GB-based agent has registered with the UK Customs Declarations System (CDS) and has made a customs declaration. Hauliers need the UK import declaration reference number to generate a Goods Movement Reference (GMR).
- Use the UK Goods Vehicle Management System (GVMS) to add the import declaration reference and generate a GMR before departing for ports in Ireland.
- For live animals and animal products and high and medium risk category plant products, ensure your GB importer or GB based agent has pre-notified each consignment on the UK’s food and feed SPS import system (IPAFFS ) in advance.
- Ensure any products that require an Export Health Certificate have one, including when using the GB landbridge. The requirement for an Export Health Certificate is based on the UK’s new low, medium, and high-risk categorisation .
Drivers should not travel to any port in Ireland without a GMR as boarding will be refused and there is no capacity at ports to wait while the formalities are completed.
There are 8 things you need to do to comply with the UK import controls introduced on 31 January 2024:
1. Familiarise yourself with the UK Customs and SPS requirements. Read the Border Target Operating Model and find more information and supports on the UK websites listed in the Key Links and Resources section.
2. Engage with everyone in your supply chain including your customers/importers in Great Britain and your transport and logistics providers to make sure they are aware of the new rules and what they have to do to comply with them.
3. Make sure your GB importer or agent is registered with the UK Customs Declarations System - this can take time so needs to be done in advance of exporting goods.
4. For agri-food and animal exports, check the UK’s rules and risk categories to find out if you need an Export Health Certificate – you can find more information at these websites:
5. For agri-food and animal exports, make sure your GB importer or agent is registered on IPAFFS and that the IPAFFS reference number is included in the customs import declaration.
6. If you are exporting live animals or products of animal origin, you must be registered as an approved exporter on the EU TRACES System . This registration is necessary to allow IPAFSS pre-notification to be completed by your GB importer or agent and for the provision of export health certification to GB. The following TRACES training videos provide further information on the process:
7. Engage with your local competent authority supervisory team responsible for your food business – whether that be the Department of Agriculture, Food and the Marine , Health Service Executive , Sea Fisheries Protection Agency or local authority veterinary service to confirm whether export certification to GB is required and to agree how this certification can be provided to your business.
8. Talk to your haulier, transport or logistics agent to make sure they are aware of the rules and responsibilities.
For more information on the new UK rules for the agri-food sector, watch these previous webinars from the Department of Agriculture, Food and the Marine.
The new UK requirements do not apply to goods moving between Ireland and Northern Ireland, North-South on the island of Ireland.
Qualifying Northern Ireland goods will continue to have unfettered access to Great Britain. If moving Qualifying Northern Ireland Goods to Great Britain via a port in Ireland, access to the GVMS system will be required in order to generate a Goods Movement Reference (GMR).
Further information on moving qualifying Northern Ireland goods to GB through Ireland is available in the UK Government guidance on moving qualifying goods from Northern Ireland to the rest of the UK .
The UK requirements will apply to goods from Ireland whether transported directly from Ireland to Great Britain or indirectly via Northern Ireland to Great Britain.
You should also start to get ready for the third stage of UK import controls.
From 31 October 2024 , the UK Target Operating Model provides for the introduction of 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, including from the island of Ireland. However, the date for the start of physical checks in ports on the west coast of Great Britain has yet to be confirmed.
Additionally, the requirement for Safety and Security declarations for imports into Great Britain from the EU, including Ireland, will come into force from 31 October 2024.
The Animal and Plant Health Agency (APHA) can be contacted at 0300 322 9434. Queries regarding GVMS can be directed he.
General queries regarding IPAFFS can be directed to 0300 1000313. Technical queries regarding IPAFFS can be directed to 0330 041 6999.
Customs-related queries for the UK can be directed to UK HM Revenue & Customs online chat here or HMRC Customs & International Trade Helpline on +44 (0) 300 322 9434.
Queries relating to Sanitary and Phytosanitary (SPS) requirements can be directed to the UK Department for Environment Food and Rural Affairs or the DEFRA helpline on +44 (0) 3459 33 55 77. The UK IPAFFS webpage provides contact details for technical help with import notification.
UK Cabinet Office Border Bulletin with list of UK helplines (30 January 2024)
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Any queries in relation to Export Health Certification in Ireland can be directed to BrexitCall@agriculture.gov.ie.