The announcement that the UK and the EU are moving towards a new Sanitary and Phytosanitary (SPS) agreement represents, in Professor Chris Elliott’s opinion, one of the most significant developments in UK food policy since Brexit.

The Great SPS Reset – what it means for farmers, food businesses and consumers

While negotiations between the two sides remain ongoing, the direction of travel has now become clear: the UK intends to move towards dynamic alignment with EU rules governing food safety, plant health and animal health, with businesses expected to be fully ready for the new framework by around mid-2027. In practical terms, this signals a major shift back towards regulatory harmonisation between the UK and the EU. The National Famers’ Union has outlined examples of this and some of the pros and cons they see from this initiative.

Regulatory harmonisation with the EU on gene editing may well reduce the ability within the UK to drive innovation to develop precision-bred crops that could improve productivity, resilience and indeed sustainability in UK farming. To me, this is the one major disadvantage of the regulatory reset.”

Another example of significant changes can be seen in gene editing. The UK diverged from EU SPS regulation through the Genetic Technology (Precision Breeding) Act 2023. This legislation was introduced to benefit UK agriculture by enabling the faster development and adoption of gene-edited crops and livestock with traits such as improved disease resistance, higher yields and greater climate resilience, thereby supporting more productive and sustainable farming systems in the UK. Regulatory harmonisation with the EU on gene editing may well reduce the ability within the UK to drive innovation to develop precision-bred crops that could improve productivity, resilience and indeed sustainability in UK farming. To me, this is the one major disadvantage of the regulatory reset.

The SPS framework covers the rules that regulate the production, sale and trade of food, feed, plants and animal products. These rules underpin how food is inspected, how animals and plants move across borders and how food safety risks are managed throughout supply chains. Since the UK left the EU single market, trade in agrifood products between the UK and Europe has been subject to a range – some would say inadequate – of additional checks, export health certificates and inspection regimes that have added both cost and complexity to food trade. The proposed SPS agreement seeks to reduce this friction by ensuring that the UK follows broadly the same regulatory framework as the EU in most areas of food safety and animal and plant health. Clearly, the UK Government and sectors of the UK agrifood industry welcome this as it will certainly reduce costs in the long term; however, it means that businesses who had to spend significant money due to Brexit rules must now spend more to essentially return to the original system.

The reduction in border checks between the UK and the EU may well be seen as a money-saving prospect and some companies, mainly SMEs, who found exporting to the EU too challenging, may well reexamine the market opportunities going forwards. Reduced paperwork, fewer inspections and faster border crossings should help restore smoother supply chains and improve competitiveness for UK exporters. Conversely, however, the agreement will likely introduce significant regulatory implications for businesses operating in the UK market. One of the most notable changes concerns regulated food and feed products such as food additives, feed additives and novel foods. Under the proposed framework, products in these categories will require EU market authorisation in order to be sold in Great Britain once the agreement enters into force. Existing UK authorisations could cease to apply, meaning businesses may need to seek EU approval even if their products are only sold domestically in the UK.

For some companies, particularly those developing innovative ingredients or new food technologies, this could introduce additional regulatory hurdles. EU approval processes can be lengthy and complex, and the requirement to obtain authorisation from Brussels may be seen as an unwanted outworking from the agreement.

For most farmers, the implications of the SPS agreement are likely to be mixed but overall positive. Many UK farming sectors remain heavily dependent on exports to the EU, particularly lamb, beef and dairy. Reduced border friction could therefore support farm incomes by making exports easier and more predictable. Livestock movements, breeding stock trade and exports of animal products may become less burdensome once SPS alignment is in place.

I think it’s important to state that, in reality, farming practices across the UK are already very similar to those required under EU rules, meaning that the practical changes for most farmers may be relatively limited.”

The issue of pesticides is another area where alignment with EU rules could have practical consequences. Since Brexit, the UK has largely mirrored EU pesticide approvals, but there have been occasional differences in regulatory decisions. One of the most widely discussed examples has been the temporary emergency authorisations granted in the UK for the neonicotinoid pesticide thiamethoxam for use on sugar beet crops to control disease. Neonicotinoids are effectively banned for outdoor agricultural use across the EU due to concerns about impacts on pollinators, particularly bees. If the SPS agreement leads to full dynamic alignment in plant health and pesticide regulation, the scope for such divergences by the UK could narrow significantly. Farmers may therefore face tighter restrictions on certain crop protection tools if EU rules evolve further in this direction. On the other hand, many food retailers and export markets already expect compliance with EU pesticide standards, meaning that alignment could simplify market access and reduce the risk of export barriers arising from differing residue limits or approval decisions.

I think it’s important to state that, in reality, farming practices across the UK are already very similar to those required under EU rules, meaning that the practical changes for most farmers may be relatively limited. Indeed, many producers may welcome the return to a more predictable regulatory environment after several years of uncertainty.

For UK consumers, I believe the SPS agreement could bring several benefits. Reduced friction at borders may help stabilise food supply chains and improve the availability of certain products that have occasionally faced disruption since Brexit. Lower administrative costs for importers and exporters could also help limit price pressures; although in reality, food prices are influenced to a greater extent by numerous broader economic factors, including energy costs, labour availability and global commodity markets.

Maintaining alignment with EU SPS standards will also ensure that the UK continues to operate within one of the world’s most robust food safety systems. EU food safety legislation is widely regarded as among the most comprehensive globally, particularly in areas such as traceability, chemical safety and animal health surveillance. Thus, from a food standards perspective, I very much welcome the alignment.

One notable concern of mine relates to border control and enforcement. While reduced checks between the UK and EU will undoubtedly facilitate legitimate trade, they may also create opportunities for those seeking to exploit regulatory gaps. One issue that has been highlighted repeatedly in recent years is the problem of illegal meat entering the UK. These carry serious animal diseases such as African swine fever and bring greater food safety risks. If SPS alignment results in fewer routine border inspections on goods moving between the UK and EU, there is a possibility that illegal products could slip through with still greater ease unless enforcement systems are strengthened.

Thankfully, border checks will not disappear entirely. Risk-based surveillance, intelligence-led inspections and veterinary monitoring will remain essential components of biosecurity protection. However, policymakers must ensure that the reduction in formal SPS checks does not inadvertently weaken the UK’s ability to seize illegal meat.

Despite these concerns, the overall direction of the SPS agreement reflects a pragmatic recognition of the realities of modern food supply chains. The UK and EU remain deeply interconnected in their food systems and regulatory divergence has created trade friction that has proven costly for businesses on both sides of the Channel.

For food businesses, the key message is clear: the regulatory landscape is shifting again and preparation for alignment with EU rules will be essential over the next two years.”

I am of the view that returning to a harmonised SPS framework will restore smoother trade while maintaining high food safety standards. For food businesses, the key message is clear: the regulatory landscape is shifting again and preparation for alignment with EU rules will be essential over the next two years. For farmers, the agreement should bring greater stability in export markets, even if it limits regulatory flexibility in some areas. For consumers, it should help maintain strong food safety protections and support more stable food supply chains. As negotiations continue and the final details emerge, the challenge will be to ensure that the new framework delivers the economic and operational benefits that businesses need, while maintaining robust protections against emerging risks such as illegal food imports and biosecurity threats.

One of the forgotten, or at least seldom mentioned, aspects of this move is that the UK, without a seat at the table where decisions are made, will have to abide by many decisions taken in Brussels. Not exactly the Brexit bonus we were all promised…