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Target Border Operating Model (TOM): How New Rules in 2023 Will Impact Exporters & Non-UK Importers

The Publication Of The New UK Border Target Operating Model Products Spells A New Era In UK Imports and Exports That Non-UK Business Need To Prepare For.

Welcome TOM!

The UK government first released the Border Target Operating Model, or "TOM," on April 5, 2023.

This Border Operating Module (BOM) will replace previous ones that were made available to aid in the comprehensive revamp of the UK's import and export customs and border processing systems due to the country's exit from the Single Market and Customs Union of the European Union.

Why is a TOM necessary?

One of the key issues with Great Britain's exit from the EU was the necessity for border checks. However, most border checkpoints between the UK and EU countries have been closed since free circulation rules and uniform border safety checks were adopted in the 1990s. After Brexit, it was necessary to create a new system since the UK and significant EU ports lacked fundamental infrastructure.

Born out of practicality, Russia's unlawful invasion of Ukraine. the subsequent spike in global energy prices and pandemic-affected supply networks. the UK decided not to impose TOM administrative requirements on businesses, in 2022.

But this left the UK exposed to animal diseases, like African Swine Fever, spreading through Europe. A new regulatory regime, based on the use of data and technology to better analyse risk, was promised.

TOM Objective 1: Biosecurity and Veterinary Control

Overall, however, the UK aims to improve the system of sanitary and phytosanitary controls - SPS - on imports with a new risk-based approach. These precautions will improve the defences against foreign diseases and pests while also preserving the UK's security and biosecurity.

Biosecurity is a top concern for the imports of

  • Products of Animal Origin (POAO)

  • High-risk Foods of Non-Animal Origin (HRFNAO)

  • Live Animals

  • Animal By-Products (ABP)

  • Plants

  • Plant products

  • Fish and fishery products.

  • Composite products and others.

TOM Objective 2: Safety and Security Controls on Imports

The TOM intends to integrate the EU fully into these S&S measures for the first time since the EU breakup by implementing basic pre-departure messaging safety and security checks on all products entering the UK.

TOM Objective 3: Turn the UK Single Trade Window into a Reality

The UK Single Trade Window is a new digital platform that will assist merchants transport products worldwide. With that, the UK wants to establish a seamless "digital" border, where technology and real-time data reduce delays and streamline commerce. The TOM draws heavily on the ability to use a UK Single Trade Window.

TOM Objective 4: Modernize and Digitalize the Border

The TOM's goal is to develop in the UK a cutting-edge border management system that can be used by all other countries, including EU Member States. The newly presented TOM builds on the 2025 Border Strategy, including the UK Single Trade Window (a new digital platform that will assist merchants transport products worldwide). The UK wants to establish a seamless "digital" border, where technology and real-time data reduce delays and streamline commerce.

Answer These Questions

The UK Government welcomes feedback and questions on the material in the TOM, focuses on four main concerns, and requests your thoughts on the following:

  • The impact of the new safety and security control paradigm on businesses and how it will be implemented

  • The application of the new sanitary and phytosanitary control paradigm and how it affects biosecurity, animal welfare, food safety, and businesses

  • How many specific importing business models be further encouraged to be prepared? What challenges does the private sector face in adopting the new model by the specified deadline?

  • What more information is needed for businesses to prepare for and implement the new Border Target Operating Model?


The infrastructure and changes outlined in the TOM are closely related to the development of the UK Single Trade Window (STW), which aims to automate border checks as much as possible and eliminate the duplication of information that must be submitted to different agents, the entirety of the 2025 UK Border Strategy, and the target for UK exports to reach $1 trillion annually by the end of the decade, despite claims made by some that it will only really affect UK importing companies. UK businesses and, in particular, non-UK companies involved in food, plant, and feed trade with the UK, must pay careful attention and prepare.

Please get in touch if you would like touch if you have questions or wish to speak to an SPS specialist, book a free call here.

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