BTOM: Why the UK cannabis and hemp industry must pay attention

As of 2024, the UK’s border operations are undergoing one of the most significant overhauls since Brexit. The introduction of the Border Target Operating Model (BTOM) affects how goods are imported into Great Britain from the EU and the rest of the world. While this is a cross-sector transformation, it carries specific and potentially costly consequences for the UK cannabis and hemp industry - especially for those importing seeds, biomass, oils, CBD products, and medical cannabis.

This article outlines what the BTOM is, how it works, and what businesses in our sector need to know

What Is the BTOM?

The Border Target Operating Model (BTOM) is the UK Government’s post-Brexit framework for managing imports of goods, particularly focusing on those that may pose biosecurity, health, or safety risks. It introduces a risk-based, digitised model for controlling imports of:

• Sanitary and phytosanitary (SPS) goods (food, feed, plants, animals)
• Non-SPS goods (manufactured or industrial items)

Developed jointly by the Cabinet Office, Defra, and HMRC, the BTOM replaces the temporary light-touch arrangements that followed Brexit and introduced phased checks and documentation requirements, including physical inspections, health certifications, and safety and security declarations.

Phased Implementation in 2024

The BTOM introduced new border controls in stages:

• 31 January 2024 – Health certification required for medium-risk animal and plant products
• 30 April 2024 – Physical and identity checks begin at Border Control Posts (BCPs)
• 31 October 2024 – Safety and security declarations required for EU imports

These requirements already affect some imports and fully in force by the end of 2024.

How This Affects the Cannabis and Hemp Industry

Importing Hemp Seeds and Biomass

Hemp seeds for cultivation or biomass for processing are often classified as plant products, falling under phytosanitary controls. This means:

• Phytosanitary certificates from the country of origin may be required
• Pre-notification on IPAFFS (the Import of Products, Animals, Food and Feed System) is mandatory
• Inspections at BCPs could lead to delays or rejections if documentation is incomplete

Any deviation—such as seeds lacking clear provenance or products without THC declarations—can result in border seizures.

CBD Products and Novel Foods

CBD oils, capsules, or edibles imported from the EU or other third countries now face increased scrutiny, especially if they are classified as novel foods or contain animal-derived ingredients (e.g. gelatine capsules).

• Under BTOM, these products may require:
• Health certificates from exporting authorities
• Labelling compliance in line with UK regulations
• Safety and security declarations by October 2024
• Inspection on arrival, particularly if medium- or high-risk

For businesses relying on just-in-time delivery or third-party manufacturers abroad, this can be a logistical headache unless properly prepared.

Medical Cannabis Imports

Medical cannabis, already regulated under the Misuse of Drugs Regulations 2001, must be imported under a valid Home Office licence. BTOM adds another layer to this process:

• From October 2024, safety and security declarations will apply to EU-sourced products
• There is potential for inspection delays, even if products are already controlled substances
• Ports and BCPs must be prepared to handle controlled goods, adding complexity to importation schedules

The Risk of Non-Compliance

The penalties for failing to comply with BTOM procedures include:

• Refusal of entry at the border
• Financial loss from delayed or rejected goods
• Regulatory investigation if products breach labelling or safety laws
• Damage to reputation with clients and regulators

Given the sensitive nature of cannabis and hemp-related products, even minor errors can attract disproportionate scrutiny.

What Should Businesses Do Now?

Register and Prepare for New Systems

Sign up to IPAFFS for SPS product imports, and familiarise yourself with the UK Single Trade Window, which will streamline import/export documentation digitally.

Review Your Supply Chains

Speak to overseas partners about documentation readiness. Map your port of entry to ensure it’s equipped for your type of goods (e.g. Controlled Drugs or phytosanitary products).

Ensure Labelling and Testing Compliance

Make sure all products meet UK regulatory standards before shipping. Have clear SOPs in place for checks, record-keeping, and responding to inspections.

Stay Informed

Join trade bodies like the Cannabis Trades Association (CTA) to receive updates, guidance, and access to toolkits designed for our industry. Consider applying for trusted trader schemes to reduce friction and increase predictability at the border.

Final Thoughts

The BTOM represents a shift from temporary post-Brexit flexibility to a rigorous, risk-based import control regime. While it aims to improve biosecurity and streamline processes through digitisation, it also introduces new challenges for sectors like ours - where the legal, botanical, and commercial nuances are already complex.

For the UK cannabis and hemp industry, awareness and preparation are key. Those who act now by adapting systems, reviewing supply chains, and aligning with guidance, will not only stay compliant but also build resilience in an increasingly scrutinised trading environment.

Need help preparing for BTOM?

The CTA is here to support members with checklists, compliance toolkits, and import/export guidance tailored to your product category. Get in touch to ensure your business is ready.

Published 30th March 2025