Update on EU-UK Trade


Update on EU-UK Trade

UK further delays full border controls on EU goods

The United Kingdom (“UK”) Government announced that no further import controls on EU goods will be introduced in 2022. Businesses can therefore stop their preparations ahead of Border Operating Model (“BOM”) Phase 3, initially planned for July 2022. The UK intends to publish a new Target Operating Model in autumn 2022, delaying the introduction of the remaining import controls until the end of 2023.


Following the withdrawal of the UK from the European Union (“EU”), the UK has been gradually introducing its own border controls, including on goods coming from the EU. This is based on a three-phased approach, as set out in the BOM policy document drawn up by the UK government. The BOM affects all exports from EU into the UK.

The introduction of the full scope of the BOM has been delayed several times. On 28 April 2022, the UK Government announced further delay in the introduction of full border controls on EU goods, as envisaged by Phase 3 of the BOM. The announcement cites administrative burdens and risk of disruption at ports and to supply chains as reasons for the postponement.

Main changes following the latest delay

BOM Phase 3 was envisaged to introduce the following border controls as from July 2022:

  • A requirement for further Sanitary and Phytosanitary (SPS) checks on EU imports currently at destination to be moved to Border Control Post (BCP).
  • A requirement for safety and security declarations on EU imports.
  • A requirement for further health certification and SPS checks for EU imports.
  • Prohibitions and restrictions on the import of chilled meats from the EU.

The UK government has indicated that it intends to publish a new Target Operating Model in autumn 2022 that would set out the new regime of border import controls, and which would be introduced at the end of 2023. The new Target Operating Model is envisaged to deviate from the controls regime that the EU applies to their own imports, with focus on decreased border checks and increased efficiency.

Impact on business

The postponement of the introduction of border controls by the UK on EU goods is expected to have an overall positive impact on both the affected industries and consumers. By preventing the increase of the compliance cost and border delays, it will ensure that EU goods remain accessible and competitive on the UK market.

Businesses should however remain informed of the status of publication of the new UK Target Operating Model and be prepared for the future compliance requirements, expected as of the end of 2023.

How we can help

Deloitte’s Global Trade Advisory specialists are part of a global network of professionals who provide specialised assistance in global trade and customs matters. If you have questions about the UK import requirements and their impact on your business, do not hesitate to contact us.

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