The UK government has released its final plans for the new Border Target Operating Model (“the Model”). The Model was initially set for implementation from October this year and has now been delayed to January 2024. The UK Government has agreed to this delay of three months following input from public consultation from the private sector and stakeholders.
The Model which introduces the remaining sanitary and phytosanitary controls, as well as full customs controls for non-qualifying Northern Ireland goods, will be rolled out from January 2024. The newly introduced controls have a revised timetable, which includes the following milestones:
- 31 January 2024: Imports of medium-risk animal products, plants, plant products, and high-risk non-animal origin food (and feed) from the EU require health certification.
- 30 April 2024: The items mentioned above will undergo documentary, identity, and physical checks, while imports of sanitary and phytosanitary goods from other parts of the world will adopt a new risk-based approach.
- 31 October 2024: Safety and security declarations for EU imports will become mandatory, alongside a more streamlined dataset for imports.
Importers should begin now to ready their supply chains in advance of the implementation of these changes. Please reach out to a member of the team if you would like to discuss how these changes might impact your business.
Author
Jennifer F. Revis
Jennifer Revis is a partner in Baker McKenzie's London office and co-leads our EMEA Customs Team.
Jennifer focuses her practice on the public regulation of international trade, particularly in a wide range of customs compliance issues. She regularly advises clients on import matters, including customs valuation, rules of origin, and classification. She has worked with clients designing and implementing their compliance programs, policies, procedures and risk assessments, and assisting them in customs audits. She has significant experience in managing global customs projects and disputes, particularly in the area of customs valuation (transfer pricing; assists; royalties). Jennifer also advises on FTAs and trade remedies matters.
Jennifer has been consistently recognised as a "Leading Individual" for Customs & Excise and “Next Generation Partner” for Trade, WTO Anti-Dumping And Customs. Clients describe her as "an outstanding customs lawyer and litigator with fantastic experience. She is also easy to work with and leads her team with aplomb", "without a doubt, one of the best customs lawyers in the business (…) with an exceptionally deep knowledge of customs valuation concepts, as well as considerable experience applying those concepts in a variety of jurisdictions."
Jennifer has been on secondment to the UK customs authorities (Her Majesty's Revenue and Customs) in their tax and excise litigation department and to the Firm's European Law Centre in Brussels.
