IN Brief:
- A reported 200-page draft sanitary and phytosanitary agreement is being considered ahead of a UK–EU summit on 20 November.
- Routine health certification and border checks could be removed for most qualifying agrifood trade, while customs declarations remain.
- The UK would align relevant food rules with the EU; the start date remains unconfirmed despite reports pointing to early 2028.
A reported draft agreement between the UK government and the European Union could remove many sanitary certificates and routine border checks on food and agricultural trade. A 200-page sanitary and phytosanitary (SPS) text has been circulated to EU member states ahead of discussions in Brussels and a UK–EU summit scheduled for 20 November. The reported agreement is not yet in force, and its final legal text, exceptions and implementation timetable remain subject to confirmation.
The draft would simplify procedures used to verify compliance with animal health, plant health and food safety rules. Reporting on the circulated text points to the removal of export health certificates, phytosanitary certificates and several associated inspection charges for qualifying trade. Existing Defra guidance also anticipates the removal of routine SPS documentation and checks on most agrifood movements between Great Britain and the EU. Equivalent changes are proposed for many movements from Great Britain to Northern Ireland, subject to the final arrangements.
Customs declarations would remain even if routine SPS certificates were removed. Consignments would still need the commercial information, identification and customs formalities required for their movement, while trade with countries outside the EU would continue under its applicable arrangements. Food exporters will therefore need to distinguish sanitary paperwork from the customs documentation that accompanies a shipment. Removal of one set of controls would not abolish the other.
Meat, dairy, fish, eggs and plant products are among the categories currently subject to additional sanitary or phytosanitary procedures. The government’s negotiating objectives include restoring trade in products such as fresh sausages, certain burgers, shellfish and seed potatoes that have faced post-Brexit restrictions. The treatment of individual products will depend on the final agreement and any retained exceptions. Until implementation, the existing certification and control requirements continue to govern consignments.
Preparing export consignments can require processors to coordinate certification with packing schedules, veterinary availability and planned vehicle departures. Physical inspections or sampling may further affect when chilled goods can leave a site and how long they remain in controlled storage. Removing routine SPS steps could reduce administrative work and make despatch more predictable, particularly where plants send frequent small consignments. Temperature control, traceability and hygiene requirements would continue to apply throughout production and transport.
The same proposal would bring Great Britain’s relevant food rules into alignment with EU requirements, including future amendments within the agreed scope. Defra has identified hygiene, food labelling, contaminant limits, regulated ingredients and food contact materials as areas affected by the proposed framework. Its guidance says the changes would apply to domestic manufacturers as well as exporters. Regulatory work could therefore extend to factories whose products never cross the EU border.
Authorisations for additives, enzymes, flavourings, novel foods and other regulated products are among the matters that food businesses would need to review. Defra has identified differences between some Great Britain and EU approvals since Brexit, including changes to permitted substances and conditions of use. Products made to an existing GB specification may need a revised ingredient or process once the new legal framework applies. Those decisions will depend on the agreed rules and transition provisions rather than the circulated draft alone.
Packaging specifications could require similar attention where food contact materials are affected. Defra identifies revisions to EU rules on recycled plastics, bisphenol A, authorised substances and good manufacturing practice, alongside changes that may affect labels. Some of the potential adjustments were examined in earlier IN Food coverage of food-contact requirements. Manufacturers and packaging suppliers would need to compare their current declarations, material specifications and label artwork with the requirements eventually brought into force.
Goods moving from Great Britain to Northern Ireland could also face fewer routine sanitary checks under the proposed arrangements. Defra says some limited movements, including certain live animals, may still require simplified certification, and separate digital procedures are being reviewed. Distribution networks supplying Northern Ireland will have to follow the rules applying to each product and route. The final agreement will determine which exceptions remain and how any revised systems operate.
The start date remains unresolved. Government guidance updated in July describes an intention to implement the SPS agreement in mid-2027, whereas media reporting on 3 November indicates that commencement may slip to the first quarter of 2028. In a parliamentary answer on 28 October, ministers said negotiations were at an advanced stage and that implementation dates would be announced in due course. The 2028 date is therefore a reported expectation, not an agreed statutory deadline.
The next decision point is the UK–EU summit on 20 November, following consideration of the circulated text by EU representatives. Food manufacturers can identify which export certificates, regulated ingredients, labels and food contact specifications might be affected, while continuing to meet today’s requirements. Binding changes to production specifications and border procedures will depend on the final agreement, implementing law and published transition arrangements.
