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Guides / BTOM risk categories · Updated 30 September 2026

Border Target Operating Model: risk categories for EU food and plant imports

Under the Border Target Operating Model, the risk category of your food, animal or plant product decides what certificates you need, whether you pre-notify, and how likely a check is. Here is how to read it for EU imports into Great Britain.

What the Border Target Operating Model does

The Border Target Operating Model (BTOM) is the UK Government's framework for import controls into Great Britain. It covers two things: security and safety controls, which apply to all imports, and sanitary and phytosanitary (SPS) controls, which apply to live animals, animal products, plants and plant products. The central idea is that controls should match risk, so a sealed tin of shelf-stable food is not treated like a chilled consignment of fresh meat.

For a trader buying from the EU, the practical question is always the same: which risk category does my commodity fall into? The answer decides whether you need an export health certificate or phytosanitary certificate, whether you must pre-notify the import, and how likely it is that the load will be pulled for inspection. This guide explains how that works. If you already know your category and just need help with the notification itself, see our IPAFFS pre-notification guide.

The three risk categories for animal products

Defra publishes risk categories for EU imports of products of animal origin (POAO), animal by-products, live animals and germinal products, and hay and straw. Each commodity sits in low, medium or high risk, and categories can be moved up or down as the risk picture changes.

CategoryHealth certificateDocumentary checksIdentity and physical checks
LowNot requiredNot routineNo routine checks, intelligence-led only
MediumRequired100% as standardA set inspection rate for the commodity
HighRequired100% as standardPhysical and identity checks

The inspection rate for a medium-risk commodity is listed against it in the Defra tables, so two medium-risk products can have quite different chances of being inspected. Always look up the specific commodity grouping rather than assuming.

When shelf-stable food counts as low risk

For POAO intended for human consumption, shelf-stable products are low risk only if they meet every criterion on Defra's list. In summary, the product must:

Miss one criterion and the product drops out of the low-risk shelf-stable group, so you then need to find its own commodity grouping in the other tables. Defra's guidance also places EU composite products (goods combining animal and plant ingredients) in the low category, unless exempt from official import controls, while further risk assessments are carried out. Low risk does not mean no rules: the goods still have to meet GB SPS import requirements.

Plants and plant products from the EU

Plants use a slightly different split, with medium risk divided into A and B:

The plant categories are published on Defra's Plant Health Portal, which also links to the frequency of checks for each group. For a wider look at plant material, see our guide to importing plants and seeds.

Health certificates in practice

For medium and high-risk animal products, the export health certificate is issued by the competent authority in the exporting EU country, usually after an official veterinarian has certified the consignment. The certificate has to be arranged before the lorry leaves, and its details are linked to the import notification. The most common real-world failure is timing: a certificate that does not match the load, or one that is still being processed when the vehicle is already at the port, leaves the goods stuck. Build certification into the supplier's dispatch plan, and agree in advance who is responsible for chasing it.

The SPS paperwork is separate from the customs declaration. A correct CDS import declaration does not clear SPS controls, and a valid health certificate does not pay duty or VAT. Both have to be in place.

Checks at border control posts

Where documentary, identity or physical checks apply, they happen at a border control post (BCP): a facility designated to inspect the relevant type of goods. Not every BCP is designated for every commodity, so the route has to be planned around a post that can handle what you are carrying. A documentary check confirms that the certificate and notification match; an identity check confirms the goods are what the documents say; a physical check can include sampling. If the goods are selected, the lorry is directed to the BCP and waits for the result, which can add hours to a delivery of chilled or perishable goods.

Low-risk animal products are not subject to routine checks, but intelligence-led checks can still happen at any time.

The Common User Charge at Dover and Eurotunnel

The Common User Charge was introduced on 30 April 2024. It applies only to commercial imports through the Port of Dover or Eurotunnel in Kent, and it covers the cost of the government BCP used for those routes. It is not linked to whether your goods are actually inspected.

Current rates are published on gov.uk and should be checked there, as we do not reproduce them here. Traders coming in via other ports pay whatever charges that port's BCP operator sets, which is worth including when comparing routes. Our cost guide covers the other costs of a typical clearance.

A practical checklist for EU food and plant imports

  1. Find the commodity code and the BTOM risk category in the Defra tables for animal products or plants.
  2. Confirm whether a health or phytosanitary certificate and IPAFFS pre-notification are needed.
  3. Agree with the supplier who arranges the certificate, and when.
  4. Choose a route with a BCP designated for your goods, and budget for the Common User Charge if you cross at Dover or Eurotunnel.
  5. Line up the customs declaration separately, including your EORI number.

For a UK-focused overview of how these controls fit together with IPAFFS and the wider BTOM timeline, read this plain-English BTOM overview for UK importers.

Related guides

Want the wider BTOM picture?

Plutos is a UK–Poland customs information site run by the same team as Easy Clearance. Its BTOM guide covers the model's background, the UK Single Trade Window and Northern Ireland.

Read the BTOM overview on Plutos

Sources

General information, not legal, tax or customs advice. Rules change; confirm current requirements on gov.uk or with a registered agent before you ship.