BTOM “Phase 5” and UK Border Controls in 2026: What Actually Applies

What is BTOM — the Border Target Operating Model?

The Border Target Operating Model (BTOM) is the UK government's model for import controls into Great Britain, first published on 29 August 2023. It sets out a risk-based approach to sanitary and phytosanitary (SPS) controls and safety and security requirements, introduced progressively from the end of January 2024.

BTOM groups animal products, plants and plant products into risk categories. The category of each commodity decides whether a health certificate is needed and how often checks take place:

• Low risk — no health certificate, but the goods travel with a commercial document and still need an IPAFFS pre-notification where required.
• Medium risk — a health certificate signed by the competent authority in the exporting country, plus risk-based documentary, identity and physical checks.
• High risk — certificates and a higher level of checks at a border control post.

Is there a “BTOM Phase 5”?

No official document uses that name. The BTOM sets out milestones, not five numbered phases, and the UK government has not published a “Phase 5” timetable. Articles that list fixed “Phase 5” dates for a mandatory Single Trade Window or for the end of paper certificates are not based on GOV.UK announcements. The practical question is which controls apply now and which announced changes are still pending.

What is already in force for EU goods entering Great Britain

31 January 2024 — health certificates for medium-risk goods

From this date, medium-risk animal products, plants and plant products imported from the EU need a health certificate. For animal products the certificate must be issued in the country where the product was last exported, processed or checked. Polish exporters obtain these certificates from the competent Polish authorities.

30 April 2024 — checks at border control posts

Documentary, identity and physical checks on SPS goods began at border control posts (BCPs). Goods called for checks must be presented at the BCP linked to their point of entry. Exception: on 2 June 2025 the UK government extended the easement for medium-risk fruit and vegetables from the EU until 31 January 2027, pending a UK-EU SPS agreement. Confirm the current status on GOV.UK before shipping.

IPAFFS pre-notification

Imports of animal products must be pre-notified in IPAFFS (Import of Products, Animals, Food and Feed System) at least one working day before the goods are expected at the point of entry. Exporters using a system approved to produce verifiable PDF certificates do not need to send the paper original with the consignment; otherwise the original travels with the goods and an electronic copy is uploaded to IPAFFS.

31 January 2025 — safety and security declarations for EU imports

The temporary waiver on safety and security (S&S) declarations for goods imported from the EU ended on 31 January 2025. Entry summary declarations (ENS) for goods arriving in Great Britain are made through HMRC's S&S GB service, before the goods arrive and within HMRC's time limits for the mode of transport.

The Single Trade Window — paused

The UK Single Trade Window (STW) was planned as a single digital gateway where traders could meet their import, export and transit obligations by submitting information once. In its published overview, the government stated that development of the STW service for the 2025 to 2026 financial year has been paused and that the first strategic release would not be launched that year. There is no confirmed date for a mandatory STW. Until the government announces otherwise, declarations continue to go through the existing systems: CDS for customs declarations, IPAFFS for SPS notifications, the S&S GB service for entry summary declarations and GVMS for Goods Movement References (GMRs) at GVMS ports.

Common user charge at Sevington

Imports through the Port of Dover or Eurotunnel that are eligible for SPS checks at the government-run Sevington BCP pay a common user charge, introduced on 30 April 2024. It applies even when the consignment is not selected for checks:

• Low-risk animal products: £10 per commodity line in a CHED (capped at £50 per CHED).
• Medium- and high-risk animal products, high-risk food and feed of non-animal origin, medium-risk A and high-risk plants: £29 per commodity line (capped at £145 per CHED).
• A maximum of 5 commodity lines are charged per CHED.

These are government charges set by Defra, not customs agency fees. Whoever raises the IPAFFS notification is responsible for paying unless the importer and agent agree otherwise in advance.

Who should pay attention?

Exporters to the UK

• Check the BTOM risk category of each commodity you ship.
• Make sure health certificates are issued in time for the importer to complete the IPAFFS pre-notification.
• Keep commercial invoices and transport records accurate and consistent with the declarations.

Importers into Great Britain

• Agree who raises IPAFFS notifications and who pays the common user charge.
• Confirm that your customs declarations and SPS notifications match.

Carriers and freight forwarders

• Make sure safety and security declarations are lodged before arrival.
• At GVMS ports, create a GMR that links the declarations for the vehicle movement.

Preparation checklist

1. Keep invoice and transport records in order — commodity codes, descriptions and consignee details should match across the commercial invoice, transport documents, customs declaration and IPAFFS notification.
2. Designate a compliance owner — someone in the business should track border changes and brief the team.
3. Follow official announcements — BTOM easements, the UK-EU SPS negotiations and any Single Trade Window decision are published on GOV.UK.
4. Check your customs representative's process — ask how they handle ENS, GMR and IPAFFS coordination for your consignments.

If you need entry summary declarations, see our ENS/SSD services. For SPS notifications, see our guide to CHED-P and CHED-PP checks on food, and for GVMS see how to get a GMR.

FAQ — frequently asked questions

Is there an official BTOM Phase 5?

No. The UK government's Border Target Operating Model (August 2023) does not define a "Phase 5". The term is used informally for the next stage of UK border changes. The controls that apply are the ones already introduced and published on GOV.UK.

Which BTOM controls already apply to EU imports into Great Britain?

From 31 January 2024 medium-risk animal products, plants and plant products from the EU need health certificates. From 30 April 2024 documentary, identity and physical checks apply at border control posts. The temporary waiver on safety and security declarations for EU imports ended on 31 January 2025.

Do I need to pre-notify SPS goods in IPAFFS?

Yes. For animal products, an IPAFFS import notification must be submitted at least one working day before the goods are expected to arrive at the point of entry. Low-risk products need no health certificate but must travel with a commercial document.

Has the UK Single Trade Window been launched?

No. Development of the Single Trade Window service was paused for the 2025 to 2026 financial year and its first strategic release was not launched. Declarations are still made through the existing systems, such as CDS, IPAFFS, the S&S GB service and GVMS.

How much is the common user charge at Sevington?

For imports through Dover or Eurotunnel that are eligible for checks at the Sevington border control post, the charge is £10 per commodity line for low-risk animal products and £29 for medium- and high-risk lines. It is capped at £145 per CHED (£50 for low-risk animal products). These are government charges, not customs agency fees.

Are checks on EU fruit and vegetables in force?

Not for medium-risk fruit and vegetables from the EU. On 2 June 2025 the UK government extended the easement for these goods until 31 January 2027, pending a UK-EU SPS agreement. Check GOV.UK for the current position before shipping.

Current regulatory status

BTOM easements and the UK-EU SPS negotiations can change what applies to EU goods. The information in this article reflects the position as of October 2026 — check the latest announcements on GOV.UK.

Official sources

• GOV.UK: The Border Target Operating Model (August 2023) — Cabinet Office
• GOV.UK: Import or move food and drink from the EU and Northern Ireland to Great Britain — Defra
• GOV.UK: Common user charge rates and eligibility — Defra
• GOV.UK: Fruit and veg import checks scrapped ahead of UK-EU deal — Defra, 2 June 2025
• GOV.UK: Making an entry summary declaration — HMRC
• GOV.UK: Overview of the Single Trade Window — HMRC
• GOV.UK: Create a Goods Movement Reference — HMRC