Border Target Operating Model (BTOM) – new UK border control rules [2026]

After Brexit, the United Kingdom introduced Border Target Operating Model (BTOM) – new border control system that replaced previous procedures used within the European Union. BTOM defines what documents, controls and procedures are required when importing goods into the UK.

For companies exporting from Poland to the UK, BTOM means new formal requirements, additional controls, and potential border delays. This article explains what BTOM is, the changes it introduces, and how to prepare.

Issue: New requirements = New challenges

Why was BTOM introduced?

Before Brexit, the UK was part of the EU single market, allowing free movement of goods without customs controls. After Brexit, the UK became a third country, necessitating full border controls.

BTOM was designed to: 1. Protect the UK border against smuggling, dangerous goods and diseases (animals, plants). 2. Ensure compliance with British standards (UKCA, UKTR, UK REACH). 3. Simplify procedures for companies through gradual implementation of requirements.

Practical issue: BTOM enters: - New documents (ENS, phytosanitary certificates, veterinary certificates). - New controls (physical, documentary, laboratory). - New penalties for non-compliance.

What is BTOM?

Definition

Border Target Operating Model (BTOM) is framework model of border controls introduced by the UK government after Brexit. BTOM defines: - Which goods require inspection. - What documents are required. - Where and when inspections are conducted. - What penalties penalties for non-compliance.

Key BTOM milestones for sanitary and phytosanitary (SPS) goods from the EU: 1. 31 January 2024 – health certificates introduced for medium risk animal products, plants, plant products and high risk food and feed of non-animal origin from the EU. 2. 30 April 2024 – documentary checks and risk-based identity and physical checks introduced for medium risk goods from the EU.

Key elements of BTOM

1. ENS (Entry Summary) declaration

An ENS declaration (Entry Summary Declaration) is a safety and security declaration that must be submitted before goods arrive in Great Britain. Check the current requirements and deadlines for your route on GOV.UK (safety and security declarations for imports).

More information: ENS declaration – guide for carriers

2. Phytosanitary inspections (plants)

Plants and plant products from the EU are placed in risk categories (high, medium A, medium B, low). Requirements depend on the category: - Phytosanitary certificate – for high, medium A and medium B goods. - Pre-notification in IPAFFS and documentary, identity and physical checks where needed – for high and medium A goods. - Low risk goods do not go through plant health controls.

Important: plants and plant products are not automatically high risk – check the category of your specific commodity. Medium risk A and B fruit and vegetables from the EU are temporarily being treated as low risk: no phytosanitary certificate, no notification and no checks. Where checks are needed, they take place at a Border Control Post (BCP) or control point.

3. Veterinary inspections (animals and animal products)

Requirements for products of animal origin (meat, dairy, fish) from the EU depend on the BTOM risk category: - Low risk – no health certificate; the goods travel with a commercial document. - Medium risk – a health certificate and notification in IPAFFS (Import of Products, Animals, Food and Feed System); documentary checks and risk-based identity and physical checks.

Important: check the risk category of your specific product before shipment – not every product of animal origin needs a health certificate or a physical check.

4. Customs inspections (duty and VAT)

All goods imported into the UK require: - Customs declaration (Import Declaration) with MRN number. - Customs duty payments (if applicable). - VAT settlements (standard or via Postponed VAT Accounting).

5. Compliance checks (UKCA, UK REACH, UKTR)

Some goods require compliance with British standards: - UKCA (UK Conformity Assessed) – for electronic products, machinery, toys. - UK REACH – for chemicals. - UKTR (UK Timber Regulation) – for timber and wood products.

Goods risk categories in BTOM

BTOM risk categories (low, medium, high) apply only to sanitary and phytosanitary (SPS) goods: live animals, animal products, plants, plant products, food and feed. Industrial goods such as furniture or electronics are not placed in BTOM risk categories – they go through standard customs clearance.

The category of an SPS product is set in the official Defra lists and depends on the product and the country of origin. It determines whether you need a certificate, a pre-notification and which checks may apply. Do not assign a category based on the everyday name of a product.

How to prepare for BTOM?

For exporters from Poland

1. Check the risk category of your goods: - Visit gov.uk/guidance/import-controls and check what requirements apply to your goods.

2. Prepare the required documents: - commercial invoice (Commercial Invoice). - Certificates (phytosanitary, veterinary) – if applicable. - Statement of origin (if using TCA customs preferences).

3. Ensure your UK client has an EORI GB: - Without GB EORI, the importer will not be able to perform customs clearance.

4. Cooperate with a customs agent: - A customs agent will assist in preparing the customs declaration and ENS.

For carriers

1. Register in the system GVMS: - Generate number GMR before entering the UK.

2. Ensure you have all the required documents: - ENS, customs declaration (MRN), certificates (if applicable).

3. Allow extra time for inspections: - Physical inspections may take several hours or days.

For importers in the UK

1. Register for VAT in the UK (if you plan regular import). 2. Obtain EORI number GB. 3. Consider using Postponed VAT Accounting (PVA) – to avoid paying VAT at the border.

Frequently Asked Questions (FAQ)

Does BTOM also apply to exports from the UK?

No. BTOM applies only to imports into the UK. Exports from the UK are subject to different procedures.

Does BTOM apply to courier shipments?

Yes, but courier companies (DHL, FedEx, UPS) have their own simplified procedures. If you send goods by courier, contact the courier company regarding requirements.

Can I avoid physical inspection?

You cannot guarantee no inspections, but you can minimise the risk: - Ensure all documents are correct. - Use a customs agent. - Avoid high-risk goods (if possible).

What happens if my goods are held for inspection?

The goods will be held at the Border Control Post until inspections are completed. This may take several hours or days. The carrier may charge additional waiting fees.

Will BTOM change?

Yes. The UK government regularly updates BTOM in response to evolving threats and business needs. We recommend regular checks gov.uk/guidance/import-controls.

How can easyclearance.pl assist?

BTOM consultancy

Our team can help you: - Determine which BTOM requirements apply to your goods. - Prepare required documentation (ENS, certificates). - Plan logistics considering potential inspections.

Customs clearance coordination

We can perform customs clearance in the UK using our GB EORI number, eliminating the need for registration by the Polish company.

Support in case of inspection

If your goods are held for inspection, our team can: - Contact Border Force to clarify the situation. - Assist in preparing additional documents. - Coordinate with the carrier and importer.

Distinction: easyclearance.pl is a customs agency based in the UK. We directly handle clearances in the United Kingdom, including BTOM procedures. If your shipment requires customs clearance in Poland or another EU country, we coordinate the process through our network of local partners with the required customs authorisations.

Summary

Border Target Operating Model (BTOM) is the new UK border control system post-Brexit. Key principles:

1. ENS – a safety and security declaration submitted before the goods arrive. 2. SPS controls – certificates, pre-notification and checks depend on the risk category of animal and plant goods. 3. Risk categories – low, medium, high; they apply only to SPS goods. 4. Preparation – check requirements, prepare documents, cooperate with a customs agent.

Need help with BTOM?

If you export goods to the UK and need support meeting BTOM requirements, contact easyclearance.pl. We will assist in preparing documentation and conducting customs clearance.

easyclearance.pl is a customs agency based in the United Kingdom. We directly handle clearances in the UK, including BTOM procedures. Customs clearances within the EU are carried out in cooperation with our network of local partners with the required customs authorisations.

What the current official guidance means in practice

For operational work, the current procedural rules, declaration fields and relief conditions should be checked directly against the official guidance. For this topic, the core reference points are GOV.UK / HMRC.

Official sources

• UK GOV (Safety and Security declarations) — GOV.UK / HMRC, 2026-03-04
• UK GOV (Get a GMR) — GOV.UK / HMRC, 2026-03-04
• GOV.UK: Goods Vehicle Movement Service — GOV.UK / HMRC, 2026-03-04
• GOV.UK: moving goods between Great Britain and the EU — GOV.UK / HMRC, 2026-03-04