If you import food from the EU into Great Britain, the rules changed fundamentally on 31 January 2024. The Border Target Operating Model (BTOM) replaced the post-Brexit transition arrangements with a permanent system of sanitary and phytosanitary (SPS) controls.
For logistics managers and importers, this means understanding three risk categories, knowing when you need a health certificate, and mastering IPAFFS pre-notification. Get any of these wrong and your consignment gets held at the border — or rejected entirely.
This guide covers what you need to know in 2026: which products require health certificates, how inspection rates work, where to find model certificates, and what happens if your commodity doesn’t have a certificate available.
The Three BTOM Risk Categories
BTOM classifies all animal products and certain plant products into three risk categories: high risk, medium risk, and low risk. Your product’s category determines what documentation you need and what checks it faces at the border.
High Risk
High-risk products pose the greatest biosecurity or public health threat. This category includes:
- Live animals (certain species)
- Germinal products (semen, embryos, ova)
- Certain animal by-products (ABP)
- High-risk food and feed of non-animal origin (HRFNAO) — though note HRFNAO sits outside BTOM and is controlled under separate legislation
Requirements: Health certificate mandatory. IPAFFS pre-notification mandatory. 100% documentary, identity, and physical inspection at a designated Border Control Post (BCP).
Medium Risk
Medium-risk products could pose significant risk to public or animal health but are manageable with targeted controls. This includes most meat products, dairy products, fishery products, and certain composite products from the EU.
Medium risk is further subdivided into three tiers based on the consequence of non-compliance:
- M1 (baseline 1% inspection): Consequence of non-compliance is manageable
- M2 (baseline 10-15% inspection): Could pose significant risk to public or animal health
- M3 (baseline 30% inspection): Likely to pose significant risk to biosecurity or public health
Requirements: Health certificate mandatory. IPAFFS pre-notification mandatory. 100% documentary checks plus risk-based identity and physical checks at a designated BCP.
Low Risk
Low-risk products present minimal biosecurity threat. This includes many processed foods, shelf-stable products, and certain composite products.
Requirements: No health certificate needed. A commercial document from the supplier suffices. IPAFFS pre-notification still mandatory. No routine inspections, though intelligence-led checks remain possible.
The key point: all three categories require IPAFFS pre-notification, but only medium and high risk require health certificates.
Health Certificates: When You Need One and How to Get It
If your product is medium or high risk, you need a health certificate. This is non-negotiable.
Who Issues Health Certificates
Health certificates must be issued by the competent authority in the country where the goods originate. For EU imports, this is typically the national veterinary service or food safety authority in the exporting member state.
You cannot issue the certificate yourself. Your freight forwarder cannot issue it. The exporter must arrange it with their national authority before shipment.
Verifiable PDF Format
Great Britain accepts verifiable PDF health certificates from the EU, Iceland, Liechtenstein, and Norway for live animals, germinal products, products of animal origin (POAO), and animal by-products (ABP). This digital format reduces fraud risk and speeds up documentary checks.
The exporter sends you the PDF certificate, which you upload to IPAFFS during pre-notification.
Model Health Certificates
The UK government publishes model health certificates for different commodity types. These are the templates that exporting countries must use. You can find the full collection on gov.uk under “Health certificates for animal and animal product imports to Great Britain”.
Before placing an order with an EU supplier, check that a model certificate exists for your commodity. If it doesn’t, you may need an import licence or authorisation from the Animal and Plant Health Agency (APHA) instead.
What If No Certificate Exists?
For some medium-risk animal by-products, no health certificate template exists. In these cases, the exporter provides a commercial document instead — but you still need to check whether an import licence or authorisation is required from APHA.
Always verify this before shipment. Arriving at a BCP without the right documentation means your goods get held, and you face storage fees, potential re-export costs, or destruction.
IPAFFS Pre-Notification: The Step-by-Step
The Import of Products, Animals, Food and Feed System (IPAFFS) is the UK’s pre-notification platform. You must use it for all medium and high-risk consignments, and for low-risk consignments that contain animal products.
Registration
If you haven’t used IPAFFS before, register at gov.uk. You’ll need:
- Government Gateway credentials
- Your Economic Operator Registration and Identification (EORI) number
- Details of your business and the commodities you import
Timing
Pre-notify before the consignment arrives at the GB border. The exact timing depends on the commodity and mode of transport:
- Live animals and germinal products: at least 24 hours before arrival
- POAO and ABP: at least one working day before arrival
- HRFNAO: at least one working day before arrival
Check the specific requirements for your commodity. Late pre-notification risks delays.
Documents to Upload
During pre-notification, you’ll need:
- Health certificate (for medium/high risk) or commercial document (for low risk)
- Commercial invoice
- Transport documentation
- Any licences or authorisations if required
IPAFFS generates a Unique Consignment Reference (UCR) once you submit. Your haulier needs this UCR to move the goods through the border.
Responsibility
You remain responsible for the consignment until all checks are complete and the goods are released. If your freight forwarder handles IPAFFS on your behalf, ensure they have all the correct documents and that the notification is accurate. Errors in the notification can trigger unnecessary inspections.
Inspection Rates and Border Control Posts
How Inspections Work
When your consignment arrives at a Border Control Post, three types of check may apply:
-
Documentary checks: Verification that your health certificate, commercial documents, and IPAFFS notification are complete and accurate. 100% of medium and high-risk consignments undergo documentary checks.
-
Identity checks: Visual inspection to confirm the goods match the documentation (labels, seals, product type, quantities). Applied to a percentage of medium-risk consignments and all high-risk consignments.
-
Physical checks: Laboratory testing, microbiological analysis, or detailed physical examination. Applied to 100% of high-risk consignments and a risk-based percentage of medium-risk consignments.
Inspection Rates by Category
| Risk Category | Documentary | Identity | Physical |
|---|---|---|---|
| High | 100% | 100% | 100% |
| Medium M1 | 100% | 1% | 1% |
| Medium M2 | 100% | 10-15% | 10-15% |
| Medium M3 | 100% | 30% | 30% |
| Low | None | None | None |
Low-risk consignments face no routine inspections but remain subject to intelligence-led or targeted checks if concerns arise.
Border Control Posts (BCPs)
Medium and high-risk goods must enter Great Britain through a designated Border Control Post that is authorised to handle your commodity type. You cannot use just any port.
The UK government publishes a list of authorised BCPs, updated regularly. Each BCP specifies which commodity types it can inspect. For example, some BCPs handle only fishery products, while others are authorised for meat, dairy, and composite products.
Before shipping, verify that your chosen port has a BCP designated for your commodity. Arriving at an undesignated port means your goods cannot clear import controls.
West Coast Ports Variation
Goods entering through west coast ports (such as Heysham, Birkenhead, and Belfast) have different implementation timelines for certain identity and physical checks. If you use these routes, check the latest guidance on transitional arrangements.
Special Cases: Composite Products, HRFNAO, and Non-EU Imports
Composite Products from the EU
Composite products contain both plant materials and processed animal products (for example, a pizza with cheese and tomato sauce, or a sandwich with meat filling).
All composite products from the EU, Switzerland, Norway, Iceland, and Liechtenstein are classified as either low risk or exempt from official import controls. Some may be reclassified as medium risk after future assessments, so monitor any notifications about your product category.
If your composite product is low risk or exempt, you do not need a health certificate — only a commercial document and IPAFFS pre-notification.
High-Risk Food and Feed of Non-Animal Origin (HRFNAO)
HRFNAO products sit outside the BTOM risk categorisation. They are controlled under assimilated Regulation (EU) 2019/1793 and include products with known risks of:
- Contaminants (mycotoxins, aflatoxins)
- Pesticide residues
- Microorganisms (Salmonella, Listeria)
Examples include certain nuts, figs, spices, and rice from specific countries of origin.
HRFNAO products can only enter via designated BCPs and require specific documentation. Check the FSA’s HRFNAO guidance for the current list of controlled products and their countries of origin.
Non-EU Imports
Imports from non-EU countries have their own risk categorisation tables, separate from the EU BTOM categories. The principles are similar — health certificates for medium and high risk, IPAFFS pre-notification, BCP entry — but the specific commodity classifications may differ.
If you import from both EU and non-EU sources, verify the rules for each origin country. Do not assume the same product has the same risk category regardless of origin.
Key Takeaways
- BTOM has three risk categories: high, medium (with M1/M2/M3 sub-tiers), and low. Your product’s category determines documentation and inspection requirements.
- Health certificates are mandatory for medium and high risk only. Low-risk consignments need a commercial document instead. All categories require IPAFFS pre-notification.
- Inspection rates vary by category: high risk faces 100% checks; medium risk faces 100% documentary plus 1-30% identity/physical checks depending on sub-tier; low risk faces no routine inspections.
- BCP entry is mandatory for medium and high risk. Verify your chosen port has a BCP designated for your commodity before shipping.
- HRFNAO sits outside BTOM and is controlled under separate legislation. Composite products from the EU are generally low risk or exempt.
FAQ
Do I need a health certificate for cheese imported from France?
Yes. Cheese is a dairy product and falls under medium risk. You need a health certificate issued by the French competent authority, IPAFFS pre-notification, and entry through a designated BCP. Expect 100% documentary checks and risk-based identity/physical checks.
What happens if I arrive at a port without a designated BCP?
Your goods cannot clear import controls. The port authority will not allow the consignment to enter Great Britain. You face re-export costs, storage fees, or potential destruction of the goods. Always verify BCP designation before shipping.
How far in advance must I pre-notify via IPAFFS?
For most products of animal origin, at least one working day before arrival. Live animals and germinal products require at least 24 hours. Check the specific timing for your commodity — late pre-notification risks delays and may trigger additional scrutiny.
Can my freight forwarder handle IPAFFS pre-notification on my behalf?
Yes, many freight forwarders offer this service. However, you remain legally responsible for the accuracy of the notification and the completeness of the documentation. Ensure your forwarder has the correct health certificates and commercial documents before they submit.
My product doesn’t have a model health certificate on gov.uk. What do I do?
Contact the Animal and Plant Health Agency (APHA) to determine whether you need an import licence or authorisation instead. Do not ship without clarifying this — arriving without the correct documentation means your consignment will be held at the border.