A practical, experience-based playbook for getting Indonesian seafood plants, cold stores, and freezer vessels onto Great Britain’s approved establishments list in 2025 so shipments clear BTOM checks. What to prepare, who applies, timelines, verification, scope changes, and the common pitfalls we see.
If you want your Indonesian seafood to clear Great Britain’s Border Target Operating Model checks in 2025, start with one non-negotiable. Your establishment must appear on the UK’s approved third-country establishments list with the correct scope. Everything else, including IPAFFS and health certificates, hangs on that listing.
This is the action-first playbook we use for our own operations and for buyers who ask us to help their partners in Indonesia get GB-ready.
The 3 pillars of GB approval that actually matter in 2025
-
Your GB listing is live and accurate. Your processing plant, any third-party cold store, and relevant freezer vessels are on the “GB approved list” for the right category. Fishery products, crustaceans, bivalve molluscs are separate scopes.
-
Your scope matches your paperwork. The establishment number, legal name, address, and category on the GB list must match the Great Britain health certificate your competent authority issues. If they do not match, BTOM identity checks will stall your load.
-
Your audit and cold-chain story is watertight. The UK has retained the EU hygiene model. Think retained Regulation 852 and 853 logic. HACCP, sanitation, water tests, histamine where applicable, and validated freezing regimes for parasites if you supply raw-ready products.
Here is how to execute, week by week.
Week 1–2: Validate scope and build a clean dossier
Start by mapping your export chain for GB. Which establishment actually produces, which stores, and which vessels catch and freeze? If any of those touch product before export and they are separate legal sites, they usually need their own GB listing under the right scope.
Confirm your category needs. If you export tuna saku or grouper fillet, that is “fishery products.” If you export prawns, that is “crustaceans.” Live or processed bivalves are under “bivalve molluscs.” Many Indonesian exporters sit only on “fishery products” and then try to ship shrimp. That is a fast way to get flagged at the BCP.
Build your dossier for BKIPM. In our experience, a complete, indexed pack shortens review time by 1 to 2 weeks:
- Legal entity documents, address, and geo-location coordinates that match signage and invoices.
- Plant layout and flow diagram. From raw receiving to dispatch.
- HACCP plan with hazard analysis, CCP validation, and monitoring records. Include histamine program for scombrids and parasite control if supplying raw-ready items such as Yellowfin Saku (Sushi Grade).
- Sanitation SOPs, pest control contract, maintenance and calibration logs.
- Potable water certificate. Micro test results from an accredited lab, recent 3 to 6 months.
- Finished product micro or chemical test results aligned to product risk. Example. Histamine for tuna. Listeria for RTE.
- Cold store and freezer vessel details if you use them. Ownership, address, layout, photos, and existing approvals.
- Traceability records. One mock lot traced from intake to dispatch with labels and production records.
- Prior approvals help. EU list code, Canada, China, or other major markets if available. They are not a replacement for GB listing but they strengthen equivalence.
Actionable tip. Do a “mock EHC” now. List your GB product descriptions exactly as they will appear on the health certificate, then confirm your intended category is listed for your establishment. If you plan to export both Grouper Fillet (IQF) and Frozen Shrimp (Black Tiger, Vannamei & Wild Caught), you will likely need both fishery products and crustaceans scopes associated with your relevant sites.
Need a quick sanity check on scope or dossier completeness? You can Contact us on whatsapp. We are happy to review against current UK expectations.
Week 3–6: Who applies, how long it takes, and how to confirm listing
Only the Indonesian competent authority can nominate you. For seafood, that is BKIPM under KKP. Exporters cannot apply directly to UK authorities. BKIPM verifies your compliance, may do or reference an audit, and submits your details to the UK list manager.
Timelines we see in 2024–2025. Internal BKIPM review and any corrective action typically run 2 to 4 weeks. UK processing and publication often add 2 to 4 weeks. The list itself is updated in batches. We advise planning for 4 to 10 weeks total, with longer lead times around Ramadan and year end.
How to check the UK list. On GOV.UK, search for “Approved third country establishments fishery products Great Britain.” Open the fishery products or crustaceans list and filter by country Indonesia. Confirm that your establishment name, address, and category appear exactly as they do on your certificates. Keep a PDF copy for your importer’s files. We also ask our UK buyers to screenshot the entry and attach it to their IPAFFS consignment record.
Do I need to be on the UK approved establishments list to export seafood from Indonesia?
Yes. GB only accepts products of animal origin from listed establishments. Under BTOM, BCPs use the GB list to validate your health certificate and to decide inspection intensity. If you are not listed, consignments will be refused.
I’m already EU-listed. Does the UK accept that or do I need separate GB listing?
You need a separate GB listing. GB retained the EU hygiene framework but maintains its own list. Being EU-listed is useful evidence for BKIPM and UK reviewers. It is not sufficient to ship to Great Britain.
How long does UK listing take and who applies?
Plan for 4 to 10 weeks end to end. BKIPM applies on your behalf. You cannot apply directly to UK authorities.
What documents are required by BKIPM to request UK listing?
Expect legal identity documents, HACCP and prerequisite programs, calibration and sanitation records, water and product test results, traceability evidence, plant layout, and details for any freezer vessels and third-party cold stores. If you seek multiple scopes, make that explicit in your dossier and show capability for each.
Do cold stores and freezer vessels also need to be UK-listed?
Yes, if they handle product that will be exported to GB and they are separate legal locations. An unlisted third-party cold store is one of the most common reasons we see for rejections. Freezer vessels that harvest and freeze at sea must also be listed under the fishery products scope if the product will enter GB supply chains.
How can I check if my Indonesian establishment appears on the GB approved list?
Go to the GB approved establishments page on GOV.UK, open the relevant category list, filter by Indonesia, then search your name or address. Verify the establishment number matches the one on your health certificate.
Can I ship to Great Britain while my UK listing application is pending?
No. Do not load for GB until the listing is published. Your importer’s IPAFFS pre-notification will not resolve the gap, and you risk inspection fees plus delay.
Week 7–12: Maintain, expand scope, and scale shipments
Once you are listed, keep the listing accurate. For legal name or address changes, new lines like RTE sushi-grade products, or adding a new site, request a scope change via BKIPM. Include evidence your HACCP covers the new risk. In our experience, scope tweaks are faster than first-time listings, but they still ride the same publication cycle.
Operationally, keep your compliance calendar tight. Quarterly potable water tests for most plants. Monthly histamine verification for tuna when you are in heavy season. Thermometer calibration monthly. Annual pest trend analysis. A simple one-page compliance calendar pinned in the QC office avoids last-minute scrambles when BKIPM requests a refresh to support your scope.
As you plan UK tenders, align product development with your listing. If you intend to offer more raw-ready SKUs such as Mahi Mahi Fillet or premium sashimi items, make sure your parasite control or deep-freeze regime is documented. If you are scaling shrimp volumes, confirm the specific cold stores in your chain appear on the GB crustaceans list. To browse standard specs we export today, you can View our products.
The 5 mistakes that delay or kill GB listings
- Scope mismatch. Shipping crustaceans under a plant listed only for fishery products. Fix by matching the EHC product description to your GB category and adding scope before booking.
- Unlisted third-party cold store. If a separate company stores your sealed cartons pre-export, it generally must be on the GB list for the relevant scope. Add them or move the product to a listed facility.
- Wrong or old legal name and address. The UK list must mirror your certificates. Align signage, invoices, and registration documents. Update BKIPM if anything changes.
- Using EU plant codes on GB health certificates. GB requires the GB-listed identity. Train your certifying officers and standardize your certificate templates.
- No proof of equivalence for raw-ready products. For sashimi, poke, or ceviche items, keep your freezing regime for parasites and histamine controls handy. The quickest way to satisfy a query is label-proof tied to batch records.
Resources and next steps
BTOM continues to tighten data validation and risk-based checks through 2025. We have found that plants that map their chain, align scope early, and keep a living HACCP file rarely have GB issues. Start with your scope map. Build a clean dossier. Confirm publication before shipping. If you are unsure how your product list translates into GB categories, or you need a second set of eyes on your application pack, Call us. We are happy to share what has worked for Indonesian exporters shipping every week.
One last reminder. IPAFFS pre-notifications and health certificates are critical, but they only work if your establishment is on the GB approved list for the exact product you are sending. Nail the listing first. Everything else flows more smoothly.