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  • Writer's pictureAlinea Customs

Importing EU and EFTA goods covered by sanitary and phytosanitary controls from 31 January 2024

The UK Government’s Border Target Operating Model (BTOM) establishes a timetable for medium and high risk sanitary and phytosanitary goods – concerning products of animal origin (POAO) from the European Union and European Free Trade Association (EFTA) states to be accompanied by an Export Health Certificate authorised by the local authorities of the exporter from 31 January 2024.


From 31 January 2024, traders will be required to:

  • locate the Border Target Operating Model (TOM) risk category for the commodity imported

  • follow the sanitary and phytosanitary (SPS) rules for that category


Sectors impacted by SPS compliance controls


The enforcement of the regulations apply to importers of:


  • live animals

  • germinal products

  • products of animal origin

  • animal by-products

  • high risk food and feed of non-animal origin


Sanitary and phytosanitary goods are categorised based on their inherent risk (high, medium or low) that the commodity poses to animal health and welfare, food safety and biosecurity, alongside any risk that is specific to the country of origin.


Composite products


From January 2024, composite products from the EU and EFTA states will either be:


  • in the low TOM risk category (some products will have further risk assessment and may become medium risk, but not prior to April 2024)

  • not placed in a TOM risk category because it is exempt from official import controls

Having been rolled back on 5 occasions due to the impact on traders, the United Kingdom is also due to implement a requirement for physical inspections to start on 30 April 2024.


Risk categories


The government has published information tables concerning the risk categories of how different types of animals and animal products are categorised.


The table is available to access using the following link:


Traders can also search for specific risk categories via the product’s commodity code, using the following link: TOM risk categories for animal and animal product imports from the EU to Great Britain: searchable list with commodity codes


Rules for each TOM risk category


There are 3 TOM risk categories:

  • low

  • medium

  • high

If your consignment is in the low TOM risk category


  • Use the import of products, animals, food and feed system (IPAFFS) to notify authorities before the goods arrive in Great Britain.

  • You do not need a health certificate.

  • Low TOM risk category consignments must come with a commercial document from the supplier.

  • Some ABPs currently need a facilitation letter to import from the EU. From 31 January 2024 you’ll no longer need a facilitation letter for these products if they are in the low TOM risk category.

  • Low risk consignments will not be subject to routine documentary, identity and physical checks. However, from 30 April 2024 checks may still be undertaken where intelligence indicates a specific risk.

  • From 30 April 2024 your goods must enter Great Britain through a point of entry with a border control post (BCP) that is designated to check your commodity.

  • For EU goods entering Great Britain through west coast ports, there will be a different implementation date for intelligence-led checks and for the requirement to enter through a port with a BCP. There is more detail in the Border Target Operating Model.


If your consignment is in the medium TOM risk category


  • Use IPAFFS to notify authorities before the goods arrive in Great Britain.

  • From 31 January 2024 your consignment must have a health certificate issued by the competent authority in the country where the goods originate.

  • From 30 April 2024 products in the medium TOM risk category:

  • · will need to enter Great Britain through a point of entry with a BCP that is designated to check them

  • · may be subject to documentary, identity and physical import checks

  • For EU goods entering Great Britain through west coast ports, there will be a different implementation date for identity and physical checks and for the requirement to enter through a port with a BCP. There is more detail in the Border Target Operating Model.


If your consignment is in the high TOM risk category


  • Use IPAFFS to notify authorities before the goods arrive in Great Britain.

  • Your consignment must have a health certificate issued by the competent authority in the country where the goods originate.

  • Most consignments in the high TOM risk category are already subject to physical import checks. These checks will continue in the same way after 31 January 2024.


If your consignment is in the medium or high TOM risk categories, but there is no health certificate for your goods


- there’s no licence for your animal or germinal product

- you’re not sure if you need a licence

  • If you are importing a medium-risk ABP, but there’s currently no health certificate for your goods, you will require a commercial document.


TOM risk categories for products from non-EU countries

TOM risk categories for plants and plant products


To find TOM risk categories for plants and plant products, visit the UK Plant Health Information Portal.


Model Export Health Certificates


The government has provided the ability for a digital signature to be recognised, through the adoption of The Electronic Trade Documents Bill, as opposed to a wet signature to facilitate the process.


Trusted Traders


Businesses that regularly transport SPS goods from the EU to the UK can apply for “trusted trader” status and become liable to fewer checks. Trusted traders will be presented with different options for providing the authorities with assurance.


Further resources


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