The UK Government is preparing to implement the final stage of the Border Target Operating Model (BTOM) as part of its post-Brexit plans. This new model, which focuses on safety and security entry summary declarations, will take effect on 31 January 2025 and apply to all EU imports into Great Britain.

During the event Tulldagen in Malmö we met up with Melanie Southan and Daniela D’Urso from His Majesty’s Revenue and Customs (HMRC), who explained the new processes further.
– The first two stages of the BTOM were SPS (Sanitary and Phytosanitary) controls: certification and border controls of animal and plant goods. The third stage, which is our area, is the safety and security ENS (Entry Summary Declaration) requirements.

The implementation of ENS will mean that for the first time, all EU imports into Great Britain will require an entry summary declaration. The government has revised the data requirements to ensure a balance between security and minimizing the burden on businesses. Melanie continues:
– We have reduced the data set down to 20 mandatory fields, with conditional and optional fields for importers to use if they wish to submit a full data set.

Facilitate smooth trade for importers and exporters

For EU exporters, the emphasis will be on providing accurate and timely information to facilitate smooth trade. Melanie and Daniela highlighted that exporters hold the necessary details about their goods, which are crucial for risk assessments.
– It’s really important for our risking that the information provided is accurate, submitted at the right time, and that the data quality is as good as it can be. We are making recommendations in our guidance to help exporters understand the kind of information required for each field. This ensures our border controls focus on stopping illegal imports, like drugs or weapons, while legitimate goods pass through efficiently.

To prepare, EU exporters and businesses must secure a GB EORI (Economic Operator Registration and Identification) number and register for the IT platform S&S GB. Non-UK registered businesses can also apply for one. Additionally, exporters must register for the safety and security GB system.
– Both of these processes are promoted on our website, and all of our guidance is being put online, says Daniela.

Industries affected by the new requirements

Unlike the earlier SPS stages of the BTOM, which applied specifically to animal and plant goods, the safety and security declarations are broader.
– The safety and security requirements are for all imports. There are a few exceptions, like personal goods and post, but otherwise, all sectors will need to complete an ENS declaration for moving goods from the EU to GB.

What the process looks like for businesses

For businesses importing goods, the process will require careful preparation. The UK’s new risking engine, known as S&S GB, mirrors Europe’s ICS system. Importers will need to ensure they have the correct information and submit it within the required timeframe.
– Depending on the transport, declarations need to be made two hours before some movements and four hours before others. Once it’s submitted, businesses will receive a Goods Movement Reference (GMR) number, allowing the goods to move into Great Britain.

Submitting ENS declarations, however, requires specific systems.
– You’ll need to either build your own software or use an intermediary or software provider. There is no user interface to S&S GB for private individuals. Accuracy and timing are critical, and our teams will reach out if there are issues that need improvement.

Challenges and opportunities

Balancing trade efficiency with national security has been the primary challenge during the BTOM implementation.
– The biggest challenge for us has been getting the balance right between making sure we have all the information needed to keep the country safe, while not overburdening traders. We think we’ve achieved that balance with this model.

In the future, the government hopes for a period of stability once the BTOM is fully in place.
– After Brexit, there’s been a huge amount of change in our border controls. I think everyone would be happy to have a period of calm after this final stage is implemented, Melanie concludes.

For businesses and exporters, preparation is key. Ensuring compliance with the new safety and security requirements will be essential as the BTOM’s final phase starts in January 2025.

Watch the YouTube video below.