UK Post-Brexit Customs Controls 2025: What's Now Fully Implemented Under BTOM

What BTOM Is and Why It Took So Long#

The Border Target Operating Model (BTOM) is the UK government's framework for implementing import controls on goods arriving from the EU and the rest of the world after Brexit. The UK left the EU Single Market and Customs Union on January 1 2021, but the government repeatedly delayed full implementation of import controls — initially to avoid disruption during the pandemic and supply chain crisis, later due to industry lobbying over readiness. Full implementation has now proceeded in phases. The BTOM represents the end state of that phased approach: a system where EU goods face the same categories of border checks as goods from non-EU countries, with some risk-based adjustments. For businesses that built their sourcing model on the frictionless pre-2020 relationship with EU suppliers, this is a structural change to their supply chain cost.

Safety and Security Declarations: The New Requirement#

From January 2024, UK importers have been required to submit a Safety and Security (S&S) declaration for all goods arriving from the EU — a requirement that applies to goods from the rest of the world but that EU goods were previously exempt from. The S&S declaration (known as an Entry Summary Declaration or ENS) must be lodged before the goods arrive at the UK border. For businesses importing by road from the EU, this means your freight forwarder or customs broker needs additional lead time to prepare and submit the declaration. The practical impact is additional documentation cost, typically £15-30 per shipment from a customs broker, plus the risk of delay if declarations are incomplete or submitted late.

Sanitary and Phytosanitary Checks on EU Food#

The UK has introduced checks on imports of animals, animal products, plants, and plant products from the EU — categories that were previously exempt from UK border checks. Under the risk-based approach in BTOM, the frequency and intensity of physical checks is calibrated to the risk level of the product category: high-risk animal products face more frequent physical inspection than lower-risk processed foods. The practical consequence is that UK importers of fresh produce, dairy, meat, fish, and plants from EU suppliers now need to use Border Control Posts (BCPs) with the appropriate facilities, pre-notify arrivals through the Import of Products, Animals, Food and Feed System (IPAFFS), and budget for the cost of health certificates from EU exporters — typically €200-400 per consignment for an official veterinarian's signature.

Documentary Checks: What Has Changed#

In addition to physical and identity checks, BTOM has introduced documentary controls on a range of product categories from the EU. These require importers or their agents to present the appropriate certificates of origin, health certificates, phytosanitary certificates, or conformity documentation at the point of import. For many product categories this is a new cost — EU suppliers who previously shipped to the UK without export documentation now need to obtain and pay for the relevant certificates. Some EU exporters have absorbed this cost; others have passed it to their UK buyers. Either way, it has increased the effective cost of sourcing from the EU relative to the pre-2021 baseline and adds administrative complexity to procurement.

How Much Are These Controls Adding to Import Costs?#

Estimates of the cost of Brexit trade controls vary depending on the product category and trade volume. The UK Trade Policy Observatory has estimated that the full suite of controls adds 2-8% to the landed cost of affected goods, when customs broker fees, health certificates, additional transit time, and inventory buffer costs are included. For food businesses, the sanitary checks and health certificate requirements are the largest single cost. For general merchandise importers, the S&S declaration requirement and customs documentation represent a smaller but real additional overhead. The impact is proportionally larger for SMEs, who cannot spread fixed compliance costs across high volumes the way larger importers can.

What Importers Need to Do Now#

UK importers from the EU should audit their current supply chain for BTOM compliance. Key questions: Are your freight forwarders and customs brokers submitting S&S declarations on all EU shipments? If you import food, plants, or animals from the EU, are you pre-notifying via IPAFFS and using appropriate BCPs? Are your EU suppliers providing the correct export documentation, and who is bearing the cost of health or phytosanitary certificates? Have you updated your landed cost calculations to include the new documentation costs and any additional dwell time at the border? AskBiz's dashboard tracks regulatory changes and flags new requirements for your specific product categories and trade routes, so compliance gaps don't become expensive surprises.

• The UK's Border Target Operating Model (BTOM) has now fully implemented post-Brexit import controls.
• Safety and security declarations on EU goods, sanitary and phytosanitary checks on food and plant products from the EU, and documentary controls are all in force.
• UK importers from the EU face new costs, documentation requirements, and potential delays that were not part of the pre-2020 trading relationship.