On 29 August 2023, the UK Government published its finalised Border Target Operating Model (BTOM) which sets out new rules for exporting food goods from the EU, including Ireland, to or through the UK.
The Border Target Operating Model highlights important dates and changes to UK import rules, including pre-notification requirements, risk categorisations for imported goods, and requirements for export health certificates, which will impact Irish exporters. A key change in the final BTOM, from the draft document published in April, is the postponement of the introduction of new SPS requirements for agri-food goods from Ireland and the EU. The application date for these new requirements will now commence from 31 January 2024 and not 31 October 2023 as previously stated.
It is important to note the requirements that these new import rules bring. For example, foods in all risk categories will require pre-notification on the UKs Import of Products, Animals, Food and Feed System (IPAFFS) to notify authorities before the food goods arrive in Great Britain. For pre-notification of consignments on the UK IPAFFs, all food businesses must be registered on TRACES (The Trade Control and Expert System).
There are 3 main dates that should be noted:
31 January 2024
- Export health certificates and phytosanitary certificates will be required for medium risk animal products, plants and plant products imported to Great Britain from the EU, including from Ireland.
- Prenotification of imports of SPS goods from Ireland on the UK’s SPS import system (IPAFFS) will be required (this requirement already applies to imports of such goods from the rest of the EU since 1 January 2022).
30 April 2024
- Documentary checks and physical and identity checks at the border will be introduced for medium risk animal products, plant and plant products imported to Great Britain from the EU, excluding those goods being imported from Ireland.
- Existing inspections of high-risk plants/plant products from the EU will move from point of destination in GB to UK Border Control Posts.
31 October 2024
- Safety and Security declarations for EU imports will come into force.
- 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 Ireland will be introduced at ports on the west coast of Great Britain (the date for the commencement of physical checks for non-qualifying goods moving from the island of Ireland will be confirmed in autumn 2023).
To support stakeholders and food business operators, FSAI have published a comprehensive explanation of how the model impacts Irish exporters on their website. This includes an FAQ which may provide businesses with some additional clarity on how they can best prepare for the upcoming changes. Additionally, the UK government is offering a series of sector specific webinars for EU audiences running from September 7th to 18th September. The details of these sessions are available here. Specifically for Ireland: There will be a 1 hour session held at 16.00 Thursday 21st September which will help traders who move goods from Ireland to GB to understand the actions they need to take to prepare for these changes. Sign up for this webinar here.
