Brexit change
Leaving the friction-free Customs Union and the Single Market created the need for new border controls. The UK introduced some new customs formalities in January 2022, but has been slow to implement its own controls for imports from the EU.
The government published its Border Target Operating Model (BTOM) initially in July 2020. Five revisions followed: in October 2020, January 2021, July 2022, May 2023 and August 2023. It was not until 2024 that the phasing in of the BTOM began.
By contrast, from 1 January 2021, the EU applied its third-country customs and regulatory regime to goods imported from Great Britain to the EU. Since then, the EU’s full border controls have applied to British goods exports to the EU. These controls include documentary and physical checks to ensure that goods comply with EU safety, security, health and environmental standards.
As a result, GB exporters have been at a competitive disadvantage from red tape and costs which EU exporters to the UK avoided.
Different arrangements apply to the movement of goods between Northern Ireland and the EU under the Windsor Framework (see separate section).
BTOM and phasing in
The BTOM has a risk-based approach for sanitary and phytosanitary (SPS) checks of imports of live animals, animal products, plants and plant products. The three main elements are pre-notification, health certification and physical inspections.
The plans included delivery of the UK’s new Single Trade Window (STW) to streamline the collection of data on goods moving between borders for Defra, HMRC and the Home Office. Although the STW was due for delivery in 2025/26, in November 2024, the government announced delivery would be paused. Later, in February 2026, the FT reported that FOI requests had revealed that the government had cancelled the project. Despite this, the government said ‘we remain committed to delivering a single trade window’.
The BTOM was phased in as follows.
1 January 2022 – pre-notification of imports from the EU of animal and plant products.
31 January 2024 – health certificates and phytosanitary certificates for imports of medium-risk animal products, plants, plant products and high-risk food and feed of non-animal origin from the EU. Also, pre-notification requirements for EU SPS goods entering Great Britain via west coast ports.
30 April 2024 – risk-based SPS checks on goods imported to GB from the EU including:
- physical, documentary and identity checks are required for:
- medium-risk animal products, plants and plant products;
- high-risk food and feed of non-animal origin.
- GB customs officers carry out “risk-based” physical and identity checks at the border.
- a ‘Common User Charge’ to recover the operating costs of border checks:
- applies to imports from all countries of animal products, plants and plant products that enter through the Port of Dover or Eurotunnel;
- importers pay the charges, which vary from nothing up to £145 per consignment, depending on the risk category and the number of commodity lines;
- a separate charge of nil or £10 applies to each transit in either direction.
31 January 2025 – safety and security declarations for imports into GB from the EU (primarily used by HMRC and Home Office).
25 February 2025 – non-qualifying Northern Ireland goods from NI apply the BTOM.
18 August 2025 – the government announced that it was suspending the introduction of extra border checks on live animal imports from the EU, and on specific animal and plant goods from Ireland. It said this was to support British businesses and ease trade ahead of its new SPS deal with the EU.
Consequences
Trade bodies and businesses from the food, agriculture, logistics and port industries were concerned about increased costs, reduced EU exports to Great Britain, and processing delays that damage perishable items. There would also be an associated increase in food prices.
Repeated delays in implementing controls have meant ongoing uncertainty, an increase in risk and unnecessary costs. The phased implementation has also increased biosecurity risk (NAO).
Inevitably, UK-EU goods trade has suffered (see section on ’Scale of the trade impacts’) but it is hard to say how much is due to new border controls.
From January 2020, in Kent, Operation Brock has aimed to manage traffic flows and mitigate disruption. With its origins in the Johnson government’s no-deal preparations of 2019, it includes:
- large lorry parks in Kent that can hold up to 2,000 trucks;
- digital ‘Smart Freight Service’, to check if hauliers have the right paperwork before they can proceed.
In December 2025, the government said it is considering plans to modify and scale back Operation Brock.
Photo by David John Abrams/Shutterstock