UK Import Controls: The Border Target Operating Model (TOM)

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, while the second has been in place since 30 April 2024.**

From 30 April 2024, the UK introduced 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 do not impact traders exporting goods from Ireland directly to GB, they 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 are now subject to documentary checks, exit identification and inspection controls and are required to confirm that consignments have exited the UK.
• Exporters transiting goods from Ireland across the GB landbridge to the EU must pre-notify GB authorities via IPAFFS before their consignment enters GB. This pre-notification should be done by a GB-based entity. The UK authorities have indicated that those who are not UK entities and currently do not have a UK address for pre-notifying, can register and pre-notify using their address in Ireland, allowing Irish entities to act as the person responsible for the load for a period of 6 months from 30 April 2024 until 30 October 2024. Further UK guidance regarding the impact of this temporary easement on the administration requirements for CUC charges will follow.
• Transit consignments to Ireland from the rest of the EU entering GB via east coast ports are now subject to documentary checks, entry identification and inspection controls.

These controls 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 are subject to fees.

For the Government-run BCP at Sevington, the UK Government introduced a Common User Charge for commercial movements of animal products, plants and plant products. The charge applies to both imports and transit movements. DEFRA has communicated that the first round of invoices were issued on 5 August 2024. Further information on the UK's Common User Charge, including instructions on invoicing and payment, is available here.

Commercial (private) British ports and relevant Port Health Authorities 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, there are a number of things you should do to comply with the UK import controls introduced on 30 April 2024:

• 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.

Information leaflets from the UK Government to help you comply are available here. You can also browse a set of previous DEFRA webinars here.

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:

• Import risk categories for animals and animal products from 31 January 2024
• Import risk categories for plants and plant products from 31 January 2024
• UK Guidance Notes on the import, export, and distribution of food

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:

• How to create an EU login and Operator Role Request
• How to create an Export Health Certificate

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. Guidance on submitting these declarations for goods entering GB from outside the EU is available here.

UK Government Resources

General Resources

Making an Entry Summary Declaration

Summary of Border TOM operational learnings and commonly asked queries since 30 April

Agri-food resources

Customs resources

UK Helplines and Contact Details

The Animal and Plant Health Agency (APHA) can be contacted at 0300 322 9434. Queries regarding GVMS can be directed here.

Any queries regarding plants and plant products should also be directed to APHA by email at phsi-importers@apha.gov.uk or by telephone at +44 (0) 3000 200 301.

General queries regarding IPAFFS can be directed to +44 (0) 300 1000313. Technical queries regarding IPAFFS can be directed to +44 (0) 330 041 6999 or email APHAServiceDesk@apha.gov.uk.

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.

In urgent scenarios where goods continue to be held at a port, DAERA has advised emailing servicetransformation.support@defra.gov.uk. The email subject must be: ‘SPS Customs Hold’ and you must include the Common Health Entry Document (CHED) Reference Number and the Movement Reference Number (MRN).

DAERA states that traders will need to continue to comply with any instruction to attend a BCP or CP for further Sanitary and Phytosanitary (SPS) inspection. Continue to monitor IPAFFS for updates.

Irish Government Resources

Any queries in relation to Export Health Certification in Ireland can be directed to BrexitCall@agriculture.gov.ie.