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Border Target Operating Model (BTOM): increase of plants and plant products that can move into GB freely

The Border Target Operating Model (BTOM): increase of plants and plant products that can move into GB freely, changes to risk categories and confirmation of end date for the EU medium-risk fruit and vegetables easement.

On 29 August 2023, the UK Government published the Border Target Operating Model (BTOM), which seeks to deliver one of the most advanced trade borders in the world by streamlining import controls and minimising burdens on traders.

The BTOM continues the phased approach of biosecurity controls to the import regime of plants and plant products and introduces a new risk-based approach to border controls.

Increased deregulation of plants and plant products imported into GB

After a scientific review of commodities across all plant and plant product risk categories, the UK government is pleased to announce that there has been an increase in plants and plant products that have become deregulated, therefore able to move into GB without being subject to any plant health controls. These changes are now in effect.

  • Commodities in the low-risk category for non-EU countries will no longer need a PC. This now harmonies the EU and non-EU controls.
  • All low-risk goods are now considered deregulated.

The deregulation of these products has a predicted reduction of around 800,000 PCs, estimating a £105m saving to industry. This figure is based on the average UK cost of a PC.

Medium-risk plants and plant products: new sub-categories

Initially, plants and plant products were categorised into ‘high, medium and low’ risk and controls have been appropriately weighted against the risk. After further review, there will be a change to how the medium-risk category will look for plants and plant products.

The medium-risk category will be split into two parts, A and B. Therefore, the new risk-categories will be: High, Medium A, Medium B and Low-risk.

  • High risk goods require a Phytosanitary Certificate (PC) and pre-notification before entering GB. Since 30 April 2024, in line with the phased import regime, these goods are subject to risk-based, physical and identity checks at a Border Control Post (BCP) or designated Control Point (CP).
  • Medium-risk A goods require a PC and pre-notification before entering GB. From 30 April 2024, in line with the phased import regime, these goods are subject to risk-based, physical and identity checks at a BCP or designated CP.
  • Medium-risk B goods only require a PC when entering GB.
  • Low risk goods do not require a PC or pre-notification.

Further to the risk category changes, three commodities, parts of plants (other than fruits and seeds) of Ipomoea and Solanaceae and leaves of Spinacia oleracea (spinach leaves) have moved from the low-risk category to medium-risk for imports from EU and non-EU countries.

There is currently an easement implemented for EU, Switzerland and Liechtenstein medium-risk fruit and vegetables meaning that they are not required to pre-notify or a have a PC. To give EU businesses more time to prepare for new controls, we can now confirm the end date for the easement has been extended and is planned to be 31 January 2025. From this date, EU medium-risk fruit and vegetables will be subject to either medium-risk A or medium-risk B controls, dependent on their categorisation.

What does this mean for your business?

If you import parts of plants (other than fruits and seeds) of Ipomoea and Solanaceae and leaves of Spinacia oleracea from the EU, Switzerland and Liechtenstein, these commodities will now be considered as ‘medium-risk goods’, but they will continue to be subject to the medium-risk fruit and vegetable easement, so will continue to be exempt from plant health import controls until 31 January 2025.

If you import parts of plants (other than fruits and seeds) of Ipomoea and Solanaceae and leaves of Spinacia oleracea from a non-EU country, you now need to adhere to medium risk import controls.

If you import one of the deregulated commodities from EU and non-EU countries, these products have now moved to the low-risk category, meaning there will no longer be plant health import controls for these products. This means these goods can move freely without any checks or certification.

Read the revised risk category page on the Plant Health Portal.

Q&A

How do I check the risk category of my plants or plant products?

Risk categorisations for plants and plant products from the EU can be found here.

Why has the medium-risk category been split into sub-categories?

The categorisation of goods is based on the risk they pose to GB biosecurity. Defra, along with the Welsh and Scottish Governments, have undertaken a review of the risk posed by certain goods and re-categorised them accordingly. This has resulted in the deregulation of many goods leading to a reduction of around 800,000 PCs and an estimated £105m saving to industry.

For some goods, the assessments demonstrated that certain commodities posed a lower level of risk, but not sufficiently low to justify the deregulation of these goods. Such goods are now listed within the Medium B risk category.

In other cases, risk assessments are ongoing. Trade will be given at least 3 months-notice of any changes to risk categorisation as result of these ongoing assessments.

Which commodities do not require plant health controls?

Any commodity that is in the low-risk category, have been deregulated and do not require plant health controls.

Furthermore, there is an easement of plant health controls on medium-risk fruits and vegetables from the EU, Switzerland and Liechtenstein. This easement will come to an end on 31 January 2025 and medium-risk fruit and vegetables will be subject to plant health controls.

Why is there an easement on fruit and vegetables from the EU but not non-EU countries?

We understand that businesses need time to prepare for changes to import controls and have taken this into account in the BTOM timeline, which strikes a balance between the need to implement critical phytosanitary controls and support businesses that import from the EU. Imports of fruit and vegetables from non-EU countries have been subject to plant health import controls for many years, and therefore businesses importing from non-EU countries need to simply continue what they have been doing up until now.