By Sam Thake, Customs Consultancy Manager, Denholm Good Logistics
The UK and EU are developing a new SPS agreement, which is expected to take effect from mid-2027.
For businesses trading in agri-food, the agreement is expected to reduce checks and paperwork on UK-EU movements, while also requiring alignment with EU SPS rules.
Timings remain subject to negotiation, and further detail will be published as the agreement develops.
Expected benefits
The agreement is expected to deliver several key benefits, including:
- removal of paperwork such as:
- Export health certificates
- Phytosanitary certificates
- ISPM15 marking (for wood packaging material)
- Northern Ireland plant health labels
- port health checks will be removed – for goods such as dairy, fish, eggs and red meat
- less delays due to removal of paperwork and checks
- making it easier to move SPS and non-SPS goods together
- easing pressure on consumer food price inflation
What businesses should prepare for
UK businesses will need to meet EU rules, including those that only operate in the UK market.
This will require changes to:
- processing methods
- certifications
- labelling
- IT systems
The government has published a list of legislation expected to be in scope so businesses trading in these goods can begin preparing: UK-EU SPS Agreement – Legislation in scope – GOV.UK.
Goods that are not exempt from prenotification controls will need to use EU digital systems such as TRACES NT.
In some cases, aquatic animals, live animals, germinal products and animal products will require intra-trade animal health certificates (ITAHCs).
Rest of World SPS Goods
This agreement does not apply to ‘Rest of World’ agri-food trade. Paperwork and border checks will remain, aligned with the same rules the EU applies to these imports. Increased checks are also expected for certain commodities imported from the rest of the world.
Composite products from these countries will require a private attestation signed by the importer or import agent in GB if they are shelf-stable and contain no meat. Products that are not shelf-stable, or that contain meat, will be subject to full SPS controls unless the meat is gelatine, collagen or highly refined. Both types of product will remain subject to border checks.
Certain shelf-stable composite products that do not contain meat may be exempt from official controls at border control posts, provided they meet specific requirements set out in EU legislation, including labelling, packaging and heat-treatment conditions. This exemption applies only to products listed in Regulation (EU) 2021/630 (as amended), such as certain confectionery, cereal-based products, pasta and breads. Food supplements may require particular attention under this exemption because of the way plant materials are used in these products.
Sector-specific impacts
The agreement will affect UK businesses differently depending on the sector they operate in and the goods they trade. Further preparation guidance is available here: SPS agreement: preparing your business – GOV.UK.
Animal Breeding Regulation
All zootech-registered breed societies and breeding bodies will need to align with Regulation (EU) 2016/1012 under the SPS agreement.
Border Control Posts and Control Points
Inspection requirements for SPS goods are expected to change, including alignment with EU rules on which goods are eligible for inspection and the rate of inspections. The agreement removes the need for inspections of SPS goods from the EU, but inspection rates are expected to increase for certain ‘Rest of World’ imports.
All border control posts will need to be approved by the European Commission before the agreement comes into effect. The designation process and detailed requirements are expected to be confirmed in due course.
Control points will continue to be approved by Defra, but they will also need to comply with the EU’s minimum standards for these facilities.
Food and Feed Safety Hygiene
Businesses will need to align with EU food and feed safety and hygiene rules. There are several areas where current EU and GB rules differ, including:
- Contaminant levels in food products
- Authorised smoke flavourings
- ID marks for products of animal origin
- Hygiene rules for foods of animal origin
Fish and Shellfish
Businesses in this sector are likely to be affected by:
- Food and feed safety and hygiene requirements
- Contaminants and additive product standards
- Transportation and handling requirements for live aquatic animals
- Identification marks or labelling requirements
- Expected re-opening of live bivalve molluscs (LBM)
- Aquatic animals requiring ITAHCs
Illegal, unreported and unregulated (IUU) fishing requirements will remain in place. Exports of wild-caught seafood to the EU will still require catch certificates, processing statements and non-manipulation documents where relevant.
Arrangements for GB to NI movements in relation to IUU checks are still under negotiation.
Animal Feed
British feed additive authorisations will be replaced by EU authorisations. Businesses should review the following resources to identify whether products will need reformulation or other changes to comply with EU rules:
- feed additives – check EU’s Register of Feed Additives
- feed materials and feed for particular nutritional purposes – check the catalogue of feed materials, register of feed materials and list of intended uses of feed for particular nutritional purposes
- transparency rules in the EU’s General Food Law.
Food Manufacturing, Processing and Standards
The agreement is expected to affect businesses that will need to comply with EU rules on food standards, safety, labelling and regulated products. Businesses should review their:
- products
- ingredients
- production methods
- authorisations for regulated products and ingredients
- hygiene and safety requirements
- compositional standards
- labelling, contact materials and packaging requirements
Business operator addresses may be able to be either a UK or EU address, regardless of whether the goods are destined for the UK, EU or NI. At present, food marketed in the UK requires a UK address, while food marketed in the EU or NI requires an EU or NI address.
Changes have so far been confirmed in the following areas:
- regulated products and their authorisations
- novel foods
- food contact materials
- food hygiene and contaminants
- ready-to-eat (RTE) food producers
- compositional standards
- bottled waters
- fresh produce and hops marketing standards
- food labels
- nutrition-related labelling, composition and standards
UK businesses should review each of these areas in relation to their products and processes and align with the relevant EU legislation and requirements.
Food Production, Plants, Animals and Associated Sectors
The agreement will affect farmers, growers, edible and ornamental horticulture businesses, producers of plants and plant products, garden centres and retailers, manufacturers and suppliers of garden products, landscapers and associated businesses.
This may affect not only what is produced and moved, but also the processes involved, particularly in relation to:
- feed, pesticides, biocides
- compliance with checks, marketing and records
- buyer and supplier requirements
- control measures for pest and disease outbreaks
- EU plant passports – increased growing season inspections in 2026
- pest categorisations
- movement of other objects – such as agricultural and forestry machinery and equipment
- participation in the EU’s reporting and inspection systems
- compositional levels of specific ingredients in certain products
- live animal keeping requirements
Genetic Technologies
Genetically modified organisms (GMOs) will need to comply with EU rules, and responsibility for marketing authorisations will return to EU processes.
Precision breeding remains subject to negotiation. It is understood that the UK will retain its own rules in some areas.
At this stage no further information is available.
Organics
The agreement will change the principles of organic farming and production. Negotiations are still underway, and more information will be released. At present, it is confirmed that there will be alignment with EU rules and standards across:
- breeding, rearing or producing organic livestock
- pet food composition and processing standards
- aquaculture
- labelling requirements
- plant reproductive material (PRM) definition expansion
- certificates of inspection for Rest of World imports via TRACES NT
What happens next
Detailed guidance is expected in autumn 2026, including checklists and practical tools. Businesses should review which parts of the agreement are likely to affect their products, processes and supply chains so they can prepare early.
If you need assistance with how this could affect your business, reach out to your DGL representative.
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