Seafood imports under the Border Target Operating Model (BTOM) | Seafish

Seafood imports under the Border Target Operating Model (BTOM)

UK Government has released the final Border Target Operating Model (BTOM). We’ve summarised how it will impact seafood imports into Great Britain.

The BTOM is the UK Government’s approach to importing goods into Great Britain. It will be progressively introduced from January 2024.

It lays out the approach for sanitary and phytosanitary (SPS) controls at the border. Compared to the rolled-over EU model, the new control regime will use a risk-based approach, streamlined and digitised health certification, and trusted trader schemes.

The control of illegal, unreported and unregulated (IUU) fishing remains outside the scope of the BTOM. IUU documentation (catch certificates, processing statements and storage documents) requirements will remain separate from, and in addition to, SPS requirements.

a forklift loading a pallet in a van
The BTOM will impact seafood imports into the UK

SPS (sanitary and phytosanitary) checks

All goods, including seafood, will be categorised based on the inherent risk (high, medium or low) that the commodity poses to animal health and welfare, food safety and biosecurity, alongside any risk specific to the country of origin. The higher the risk, the higher the level of controls.

The level of controls will be:

  • All seafood consignments, regardless of risk category, will require pre-notification at least 24 hours before arrival, unless a derogation 4-hour period is arranged with Port Health for logistical purposes. The consignment will need to enter GB through a port that has a Border Control Post (BCP) designated for that type of commodity.
  • High risk consignments will require pre-notification and streamlined health certificates. They will be subject to 100% documentary, identity and physical checks. Exceptions from 100% checks are planned for some live aquatic animals.
  • Medium risk consignments will require pre-notification and streamlined health certificates. They will all undergo a documentary check. Identity and physical checks will be carried out on at least 1% of medium risk consignments, but some medium risk consignments will be checked at a higher rate (up to 30%) depending on their specific risks.
  • low risk consignments will only require pre-notification and entry via a Border Control Post. While low risk products won’t get routine checks, they may be subject to intelligence-led intervention.

The levels of checks are only indicative and can be adjusted to reflect the risk. If risks increase or decrease, and commodities need to move between risk categories, traders will normally be given 3 months’ notice. If urgent protective action is required, there may be no notice period.

Risk categories

There are 2 risk categorisation lists, which cover goods entering Great Britain from either:

Seafood entering GB from the EU, Iceland, Liechtenstein Switzerland,  Greenland and Faroes

Medium risk

  • Fishery products that have been processed. For example, by heating, curing, smoking, maturing, drying, marinating, extraction, extrusion or a combination of these
  • Fish associated with histamine such as mackerel, herring, sardine, anchovy .
  • Aquaculture product
  • Live crustaceans
  • Bivalve molluscs

Low risk

  • All remaining wild-caught fishery products, including fishery products that have been gutted, headed, sliced, filleted or chopped
  • Ambient-stable fishery products (subject to a list of conditions)
  • Composite products (pending the results of further risk assessments)

Seafood entering GB from the rest of the world

Medium risk

  • All fishery products except low risk fishery products
  • All composite products, other than low risk and exempt composite products

Low risk

  • Fishery products from New Zealand, except fish associated with histamine such as tunas and mahi mahi
  • Ambient-stable fishery products and composite products (subject to a list of conditions)

Rest of the world categories only apply to goods from countries that have been subject to a risk assessment. Full details on the risk categories are available on the UK Government website.

Timeline for implementation

  • 31 January 2024: Medium risk seafood products from the EU will need to have health certification.
  • 30 April 2024: Medium risk seafood products arriving from the EU will undergo documentary checks and risk-based identity and physical checks. Low risk seafood imports from the rest of the world will not require health certification or require routine checks. Low and medium risk seafood from any country will have to enter Great Britain through an appropriate Border Control Post.
  • 31 October 2024: Safety and Security declarations for EU imports will come into force.

The timeline applies to all seafood arriving in Great Britain, including from the Republic of Ireland. A separate timetable applies to goods arriving via west coast ports.

Simplified and digitised health certificates

Streamlined health certificates for seafood imports are now available in the Government’s model health certificate collection on the website.

These certificates apply to seafood imports from the EU that require a certificate from 31 January 2024. Non-EU countries can start using the new certificates on 31 October 2023.

PDF versions of digitally signed export health certificates will be acceptable for seafood from EU and EFTA countries from January 2024. The digital certificate must be created in the EU’s Trade Control and Expert System (TRACES) or a similar online national export system and attached to the IPAFFS pre-notification.

Border Control Posts (BCPs)

There is already a network of BCPs at ports dealing with imports from non-EU countries. Port operators are considering the necessary changes (BCP infrastructure, staffing etc.) to facilitate the introduction of controls on EU goods. Government-run inland border control facilities will provide facilities for goods entering GB through the Short Straits (Port of Dover and Eurotunnel).

Trusted trader approach

The Government is proposing a voluntary trusted trader scheme, the Accredited Trusted Trader Scheme (ATTS), which provides SPS facilitations. The scheme allows the trader to take responsibility for assurances that are equivalent to those provided by standard official controls. The ATTS is a modular framework, and traders will be able to accede to one or more modules.

The proposed modules are:

  • Certification Logistics, allowing an export health certificate to be used from the point of origin of the goods (e.g. a manufacturing site) without the need for re-certification at a consolidation hub in the EU prior to dispatch to Great Britain
  • Checks Away from the Border, where checks are carried out by the Trusted Trader at their own site
  • Journey Assurance, which draws upon supply chain data and technology already available to businesses


Groupage loads containing medium-risk seafood will need health certification and undergo checks according to the new regime. The streamlined health certificate does not require a vehicle registration number, removing this current administrative burden.

With consolidation hubs, goods are brought together at a hub in the EU before export to Great Britain. The certifying officer at the hub completes certifications for individual consignments being loaded onto a lorry headed for the UK and seals the lorry. The Government is hoping to work with businesses to explore how the certificates can be aggregated.

With multiple pick-up, consignments are added to a lorry at different premises and certified at each pick up point. The seal is removed and reapplied at each pick-up point. The Government intends to work with importers and logistics firms who intend to use this model of groupage to reduce complexity and cost.

Northern Ireland imports

The Windsor Framework has established a new way to move goods intended for retail from GB to Northern Ireland. Eligible goods will be able to take advantage of facilitations in the Northern Ireland Retail Movement Scheme (NIRMS). Ineligible goods will still be able to enter NI, but without any of the BTOM facilitations. Imports into NI from the EU will continue as now, with none of the checks or controls set out in the BTOM.

Improving border processes for exporters

While the BTOM is intended to facilitate import processes, it also provides benefits to exporters. When fully operational, the UK Single Trade Window will make it faster and easier to complete border requirements for exports. Safety and Security declarations will no longer be required from the end of 2023 for fish caught in UK territorial seas and landed outside of the UK.

Find out more

You can read the BTOM document and information on risk categorisation by following the link below to the UK Government website. This can be accessed from the link below: