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.  


Jennifer is a Partner and head of Baker McKenzie's Customs & Excise Practice in London, and co-head of Baker McKenzie EMEA Customs group.


Alexandra is an associate in the London Competition, Trade and Foreign Investment practice. Her focus is on international trade, particularly in customs compliance issues. Alexandra advises clients on import matters, including customs valuation and rules of origin. She has worked with clients on customs investigations and valuation disputes.


Yassine El Bojaddaini is a senior associate within the EMEA Customs Practice. He has ample experience on advising and representing multinationals in customs and tax related matters including restructurings, litigation and supply chain optimization.