The UK's draft Border Target Operating Model

Published by SIPA

The UK Government has laid out its new model for importing goods in its draft Border Target Operating Model (BTOM). It will apply to all goods, including seafood, imported into the UK from inside and outside the EU.

Sanitary and phytosanitary (SPS) checks

Seafood will be assigned a high, medium or low risk category. The assigned category reflects the risk that the commodity poses to animal health and welfare, food safety and biosecurity, plus any risk specific to the country of origin. The higher the risk, the higher the level of controls.

The indications in the BTOM are that most live fish and shellfish will be high risk, and fishery products will be either medium or low risk.

The level of controls will be as follows:

  • All seafood consignments, regardless of risk category, will require pre-notification and entry through a Border Control Post (BCP). In addition:
  • High risk consignments will require health certificates. They will be subject to 100% documentary, identity and physical checks.
  • Medium risk consignments will require health certificates and will undergo a documentary check. Identity and physical checks will be carried out on at least 1% of consignments.
  • Low risk consignments will have no requirement for health certification or routine physical border checks

Proposed timeline for implementation

  • 31 October 2023: Medium risk seafood products from the EU will need health certification.
  • 31 January 2024: Medium risk seafood products arriving from the EU will undergo documentary checks and risk-based identity and physical checks. Low risk seafood imports from outside the EU will not require health certification or routine checks.

Other facilitations

  • Health certificates for seafood imports will be simplified, requiring fewer data inputs.
  • New BCPs will come on stream to supplement the current network of BCPs
  • The Government is piloting 2 trusted trader models with industry, to be piloted in 2023. Trusted traders will benefit from reduced requirements at the UK border.
  • The Government will work with traders to reduce the complexities and cost of groupage loads arriving from the EU.

 There is more information on the Seafish website here.

 I will be giving a presentation on the Border Target Operating Model at SEG at the Seafish Pavilion (Hall 2, Stand 2I601) on Wednesday 26 April at 14:00.
Places are limited, so please reserve a place early by contacting me on


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