New import controls were implemented on 30th April 2024. This article gives you operational information updates on BTOM. 


  • Frozen fish fingers risk categorisation  
  • How to avoid ‘no match’    
  • Resources to help you comply with new BTOM rules   
  • Contact points for urgent border target operating model (BTOM) queries 

Frozen fish fingers risk categorisation  

We have received questions about the risk categorisation of frozen fish fingers. They are considered low risk if made with wild caught fish. Please note this is not a change to any risk categorisations. 

The BTOM risk category list by commodity code states, CN1604199190 is fillets of other fish species – raw, merely coated with batter or breadcrumbs, whether or not pre-fried in oil, frozen. Wild caught fish is defined by the following risk categorisation. A wild caught fishery product will be in the low BTOM risk category if it meets all the following criteria: 

  • it is not live or would be unable to survive if returned to the environment (‘not viable’) 
  • it comes from an approved establishment and is identified accordingly 
  • it has not been subject to processing, as defined in Article 2 of Retained EU Regulation 852/2004 – for example, by heating, curing, smoking, maturing, drying, marinating, extraction, extrusion or a combination of these 
  • it is accompanied by the required illegal, unreported and unregulated (IUU) documents, for example, a valid catch certificate and proof of storage and processing, where applicable 
  • it is not fish that is associated with histamine (that is, species of the families Scombridae, Clupeidae, Engraulidae, Coryfenidae, Pomatomidae or Scombresosidae) 

How to avoid ‘no match’  

To help you avoid delays to your consignments Defra and HMRC have produced a step-by-step video and technical information sheets and on how to prevent and resolve a ‘no ‘match’ in the Customs Declaration Service (CDS). Defra and HMRC cross-check information provided by importers in their Part I CHED and customs declaration to ensure the CHED reference and commodity code are consistent. Any mismatches between this data will result in consignments being directed to a BCP for further checks.

Resources to help you comply   

Our detailed guidance has been updated with information on how to comply with your new legal responsibilities for:     

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