On 29 August 2023 the UK government announced the publication of its new Border Target Operating Model.
What is the Border Target Operating Model?
The Border Target Operating Model is a key part of the UK government's 2025 border strategy and sets out the processes and requirements for importing into Great Britain. A downloadable copy of the full Border Target Operating Model can be found on GOV.UK.
My business is based in Northern Ireland and trades with GB. What does this mean for my business?
If your business is based in Northern Ireland and moves qualifying Northern Ireland goods to GB, they will continue to benefit from Unfettered Market Access. This means that these goods will continue to face no customs or Sanitary / Phytosanitary requirements upon entry into GB. This remains the case even if the qualifying Northern Ireland goods enter GB via a port in Ireland.
What is meant by Sanitary and Phytosanitary Requirements?
Sanitary and Phytosanitary controls are measures which are designed to protect plant, animal, and public health. For more information see out article on SPS requirements for moving products of plant and animal origin.
What is meant by a Qualifying Northern Ireland Good?
A Qualifying Northern Ireland Good (QNIG) is any goods that have been commercially processed in Northern Ireland or are physically located and in Free Circulation in Northern Ireland at the 'point of sale'. This means that it is not under any special customs procedure nor is it in a bonded or customs warehouse in Northern Ireland.
A Qualifying Northern Ireland Good enjoys 'unfettered' access to the market in the rest of the U.K., meaning that, if you move qualifying Northern Ireland goods directly from NI to GB, there will be no customs processes for traders, with some very limited exceptions. For example, goods falling within the very limited number of procedures relating to specific international obligations binding on the U.K. and EU - such as the obligations on the movement of endangered species. You will also not need any new regulatory approvals to place your qualifying goods on the market in Great Britain.
Since 31 January 2024, Northern Ireland Qualifying Goods moving to GB via Irish ports, only require a Goods Movement Reference (GMR) from the Goods Vehicle Movement System (GVMS). When creating this GMR, the haulier / agent should indicate they are moving such goods by selecting the 'oral or by conduct declaration or no declaration required' option.
Traders, and in particular, non-U.K. traders, should be aware that you cannot move goods through Northern Ireland to avoid the UK tariff or import processes. Traders found to be doing so may receive penalties and their goods may be seized and destroyed if they move goods through Northern Ireland for an avoidance purpose.
More information about Northern Ireland qualifying goods can be found in the GOV.UK guidance about Moving qualifying goods from Northern Ireland to the rest of the UK.
What Is meant by unfettered market access?
Unfettered Market Access refers to the ability of businesses in Northern Ireland to move Northern Ireland qualifying goods to GB without facing any customs requirements, such as an export/import declaration and the payment of customs duty.
There are some limited exceptions to this. If a good is not able to benefit from unfettered market access, then an export declaration will be required prior to departure from Northern Ireland. More information about which goods do not qualify for unfettered market access can be found in the GOV.UK guidance document.
It is important to remember that unfettered market access does not apply to goods which travel from Ireland via Northern Ireland to Great Britain. It is therefore important that businesses understand their trade routes to ensure that they can avail of the benefits of unfettered market access.
What changes have been made to Sanitary and Phytosanitary rules in the Border Target Operating Model?
For more information on SPS rules please see our article about SPS requirements.
The Border Target Operating Model has set out the new requirements for importing goods subject to Sanitary and Phytosanitary requirements into Great Britain. These changes will be phased in throughout 2024. The timetable below sets out the requirements for importing goods from the island of Ireland:
31 January 2024
The introduction of health certification on imports of medium risk animal products, plants, plant products and high-risk food and feed of non-animal origin from the EU. Low risk plant products and products of plant origin will no longer require pre-notification.
31 January 2025
The introduction of documentary and risk-based identity and physical checks on medium risk animal products, plants, plant products and high-risk food and feed of non-animal origin from the EU.
In addition to SPS requirements imports into Great Britain from Ireland will also become subject to full customs controls.
On 31 January 2025 the UK government will also introduce the Single Trade Window which aims to reduce the level of duplication involved in import processes. The introduction of a Single Trade Window is a key aspect of the UK Government’s 2025 Border Strategy. For more information on the Single Trade Window and how to prepare for its introduction please visit our article about Trade digitalisation and the Single Trade Window.
How do I get an Export Health Certificate?
Businesses in Ireland must apply for an Export Health Certificate through the Trade Control and Expert System (TRACES). Once registered, businesses should ensure that they choose the correct chapter to obtain the level of access relevant to their business. Gov.ie has comprehensive guidance about registering for TRACES NT.
The Department of Agriculture, Food and the Marine has developed a step-by-step video guide on how to complete an Export Health Certificate through TRACES NT:
My business is based in Ireland but trades with GB. What steps should I take now?
Unlike businesses based in Northern Ireland, businesses located in Ireland who are exporting to GB will be required to comply with the new biosecurity border requirements.
There are several key actions which businesses that are based in Ireland who export goods of plant and animal origin should take now as the Border Target Operating Model takes effect. These include:
- Identifying the level of risk (low, medium, or high) associated with each of their products which are either plant or animal based.
- Register on GOV.UK for the Import of products, animals, food and feed system (IPAFFS). This will enable you to pre-notify the UK authorities of any upcoming shipments.
- Register for TRACES NT. This is the system used for developing export health certificates. More information, including a step by step guide on this process, can be found in this downloadable manual from the Department of Agriculture, Food and the Marine.
In addition to sanitary and phytosanitary requirements, the Border Target Operating Model will see the introduction of full customs controls on goods imported into GB. To help ensure compliance with this new requirement businesses in Ireland may wish to consider some of the following key tips:
- Ensure that an appropriate incoterm has been agreed with the buyer of the goods. Incoterms specify the terms and conditions of trade between the buyer and seller, setting out responsibility for areas such as arranging transport and import/export customs clearance. More information about the requirements for each individual incoterm can be found in our Article: A guide to Incoterms.
- If arranging transport make sure the transport provider has access to the UK’s Goods Vehicle Movement System (GVMS). More information is available in our article, The Goods Vehicle Movement System.
- If responsible for the import customs clearance into GB, businesses in Ireland should ensure that they, or a third party working on their behalf, have access to the UK’s Customs Declaration Service (CDS). This is the system used by HMRC to facilitate the completion of import declarations into the UK.
Further help preparing for the implementation of the UK Border Target Operating Model
If you need help understanding how the implementation of the UK Border Target Operating Model will impact upon your business you may be able to receive specialist advice from an approved InterTradeIreland consultant. Simply select below to apply for fully funded Trade Hub support.
Prepared by the InterTradeIreland Trade Hub Team.
Reviewed: December 2024