Since the end of the Brexit transition period on the December 31st 2020, businesses in the UK have been dealing with phased-in implementation of procedures for moving goods between the European Union and Great Britain.
This implementation has been broadly following the ‘Border Target Operating Model’, although admittedly, it has been subject to 7 delays since 2020. There remain two further deadlines in 2025, after which time the full process for importing any goods from the EU should be in place.
This article will explain the changes to be implemented in trade with the EU in 2025. More crucially, it will advise how businesses need to prepare for a fully post-Brexit trading environment.
Timeline of implementation for procedures (2020-today).
- 1st January 2020
- New health certification requirements for goods exported from the UK to the EU.
- Checks on goods imported into the UK from the EU to be phased in.
- March 2021, September 2021, December 2021, April 2022, August 2023.
- Implementation of health checks on imports is repeatedly delayed.
- 31st January 2024.
- The introduction of health certification on imports of medium-risk animal products, plants, and plant products and high-risk food and feed of non-animal origin from the EU.
- 30th April 2024.
- The introduction of documentary and risk-based identity and physical checks on medium-risk animal products, plants, plant products, and high-risk food and feed of non-animal origin from the EU.
- September 2024 and October 2024
- The implementation of some health checks and the introduction of a reduced data set as part of the UK Single Trade Window has been delayed.
- 31st January 2025
- Safety and Security declarations are required for imports into Great Britain from the EU or from other territories where the waiver applies.
- 1st July 2025
- The introduction of border checks on EU imports applies to fruit and vegetables.
- No date confirmed
- The introduction of the UK’s Single Trade Window, which aims to remove duplication and simplify import procedures, has been delayed until April 2026 at the earliest. No finalised date for implementation has been announced.
True to form, then, the final deadline on the UK’s BTOM, initially scheduled for 31 October 2024, is now due to be implemented on 1 July 2025. However, from that moment, the procedure for UK imports of products from the EU should be fully in place.
31st January 2025 deadline explained
From Friday 31st January 2025, Safety and Security declarations are to be introduced for any EU imports into the UK.
This means that all individuals and businesses importing goods from the EU using a commercial carrier will be required to submit an Entry Summary Declaration (ENS), except in very specific circumstances. This brings importing from the EU broadly in-line with importing from the rest of the world. It must be done at least 2 hours before the goods arrive at an EU ferry port, or if using the Eurotunnel, 1 hour before arrival.
Furthermore, the amount of data required as part of an Entry Summary Declaration will be reduced to 20 mandatory fields, with 8 conditional fields and 9 optional fields.
Ensure the responsible party within your supply chain is aware of their requirements ahead of the deadline. If your business is in a position to begin submitting these declarations already, you are encouraged to do so.
For UK government guidance on the legislation changes, including a full list of the dataset required, see their official website here.
Advice for businesses after final Brexit deadlines in 2025
1. Don’t view the end of the phase-in period as the end of changes in regulation
At WTA, we advise businesses to avoid seeing the end of the Border Target Operating Model (BTOM) as the end of regulation changes between the UK and EU.
Unfortunately, as the UK and EU are now totally independent markets, regulatory divergence will only continue.
Businesses need to prepare for more differences in regulations, such as ingredient usage, packaging types, and labelling in the years ahead. Producing one product to fit both markets is becoming increasingly unviable.
So, our guidance is to remain informed. Follow news updates and adapt to any regulatory changes ahead of time. Newsletters such as WTA’s weekly Market Update keep readers informed on changes in logistics and customs every week.
The fact is, the EU needs to be treated as the same as any other export market now. Where businesses need to be prepared for making fundamental changes to products to get access.
2. Continually adapt your businesses supply chain for resilience
Focus on ways to add resilience to your international supply chain involving the EU. This means thinking carefully about your suppliers and their stability.
Assess all other stakeholders, such as your logistics provider, and the service received. Stronger partnerships with EU suppliers minimise delays and miscommunications. Your customs broker needs to be experienced and informed about regulatory changes.
"I would say it's vital for any customs broker to have the right technology in place for maximising speed. Too many customs brokers still rely on a manual process, when technology exists to semi-automate the process. This reduces the opportunity for mistakes and speeds things up. Vital for our many food and drink clients."
Jamie Craig, Customs Consultant, WTA
Furthermore, using an AEO-accredited logistics or customs provider can hugely simplify processes at the border. Reduced checks, faster clearances, and priority at borders all help reduce disruption in trade after the BTOM.
3. Focus on digitalisation
Keep an eye out for announcements about new systems like the UK Single Trade Window, which will reduce administrative burdens. This new system aims to reduce duplication in data entry and simplify processes for importers and exporters.
Take advantage of these systems as early as possible.
Meanwhile, greater leverage of supply chain visibility software, such as the WTA Platform, can provide unmatched insight into your goods in transit.
Offering a single storage location for shipment documentation transforms your ability to manage customs effectively. Coupled with financial data, location, temperature and humidity tracking, your logistics and customs management becomes spectacularly easier.
Sadly, the end of the transition period does not mark the end of regulatory changes between the UK and EU. Businesses must be prepared for continual tweaks and alterations to rules between the markets. Divergence will only continue from here, and businesses must be continually aware of it.
Subscribe to WTA's Market Update to stay ahead of regulation changes as they arrive and ensure your supply chain is never disrupted.