UK-EU trade negotiations – how aligning with the EU will affect your business

Image of container ship and EU Flag and the Union Flag flying together

Photograph: Getty and StockStudio/Alamy

Negotiations are ongoing between the UK and EU on a Common SPS (Sanitary and Phytosanitary) Area to reduce agri-food trade barriers by aligning with the EU on certain areas of regulation. Keep track of the negotiations on this page and see how the NFU is working to influence them on your behalf.

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What are Sanitary and Phytosanitary standards?

SPS (Sanitary and Phytosanitary) standards are the rules that countries maintain to ensure that the food produced in, and imported into, that country is safe for consumers, and to prevent the spread of pests or diseases among animals and plants.

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Why is the UK negotiating an SPS agreement with the EU?

Since its withdrawal from the European Union, the UK Government, in conjunction with the devolved administrations, has operated an independent SPS regime in Great Britain, with Northern Ireland governed by the terms of the Windsor Framework. This has resulted in routine border checks being applied to a range of agri-food products moving between the UK and the EU. These checks create friction in the trade of these products and have increased costs and risks for exporters.

The government wishes to remove these routine border checks on food and agricultural products, and the associated costs for businesses, through a Sanitary and Phytosanitary Agreement, which dynamically aligns Great Britain with EU regulations for the legislative areas in scope of the agreement.

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What is dynamic alignment?

On 19 May 2025, a Common Understanding document was agreed by the EU and UK in London. It set out the parties’ intentions to agree a Common Sanitary and Phytosanitary Area to reduce agri-food trade barriers through the principle of dynamic alignment with EU rules.

Dynamic alignment means having a single rule book, in this agreement, the EU rulebook, for the agreed areas of law in scope of the agreement.

In practice, this means the UK has agreed, in principle, to dynamically align with the EU (ie, apply EU rules domestically in Great Britain) on SPS legislation; food and feed safety; and broader nutrition-related areas such as food supplements, fortified foods, food for specific groups, nutrition and health claims, and nutrition labelling; wider agri-food rules related to food labelling, organics, key agri-food marketing standards and compositional standards; as well as the regulation of pesticides and biocides.

On 9 March 2026, the UK Government published the list of EU legislation which is currently viewed as being in scope of the agreement.

In return for dynamic alignment to EU rules, both parties will remove the need for export health certificates, phytosanitary certificates, certificates of inspection for organics, specific marketing standards certification requirements, border checks and the resumption of trade in banned British products (eg, seed potatoes, sausages, burgers) and live animal trade (for breeding).

Prior to the Common Understanding, the NFU lobbied the UK Government to pursue an SPS agreement with the EU, premised upon mutual equivalence of regulations. This would have recognised the UK’s unique starting point of largely continued alignment with EU regulations and minimised trade frictions whilst retaining domestic legislative autonomy.

The Common Understanding,, and subsequent guidance to businesses, also states that the SPS agreement should include a short list of limited exceptions to dynamic alignment. Whilst the list of exceptions is subject to negotiation between the UK and the EU, the Common Understanding sets out a series of requirements that any exception must meet to be agreed. The government has stated it views the ability to set high animal welfare standards, support public health, and support the use of new and innovative technologies as areas of importance.

The NFU is urging the government to pursue a number of exceptions, such as for precision breeding and technical adaptations to EU regulations, relevant to agricultural production in Great Britain, and to work with industry stakeholders to demonstrate that the required assurances can be met.

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How will this affect me and what is the NFU doing?

The SPS agreement will have wide-ranging and potentially significant impacts upon British farmers and growers. Alignment with EU regulations will apply to all domestically produced products regardless of whether or not your business trades with the EU.

For more than a year, the NFU has been supplying the government with extensive information about the potential risks and benefits of this agreement alongside our public lobbying work. Throughout this period, we have been clear that agriculture will need a variable pace transitional arrangement to account for the fact that different sectors have experienced different amounts of legislative divergence since the UK left the EU. Read more about our lobbying work via our timeline

Some of the main changes we anticipate as a result of dynamic alignment include:  

  • Removal of routine border checks for imports and exports of food and agricultural products between GB and the EU. This includes the removal of Export Health Certificates, Phytosanitary Certificates, Organic Certificates of Inspection, identity check fees, and sampling costs. This will benefit British exporters as well as British farmers and growers who import inputs such as plants for planting from the EU.
  • Alignment with the EU animal health frameworks. This will require regular animal health visits by a vet for all animal keepers as well as changes to the way that exotic diseases are managed. Read our explainer (opens in a new tab).
  • Alignment with EU rules for plant protection products. This will require compliance with EU residue limits in food and adherence to EU rules governing the marketing and use of PPPs. We anticipate this will result in changes to GB MRLs as well as the Active Substances available to growers in GB and their conditions of use. Read our explainer (opens in a new tab).
  • Alignment with EU biocidal product regulation. This will require adherence to EU rules governing the use of biocidal products. Agricultural uses of Creosote (posts, poles, and fencing) are no longer permitted in the EU.
  • Alignment with EU organic regulations. This will require organic producers to comply with new EU organic rules which came into effect in 2022. We anticipate this could pose significant challenges for organic poultry producers. Read our explainer (opens in new tab).

On 9 March, Defra launched a call for information which seeks to understand how prepared businesses are for an SPS agreement, as well as the potential impacts in terms of the benefits and costs associated with alignment.

The NFU will be responding and has launched a survey to hear concerns directly from members. This will enable us to continue to provide a clear picture to the government and ensure this agreement secures the outcomes needed for British farmers and growers.

More widely, the NFU and BAB continue to engage with the government, the Commission and relevant UK and EU stakeholders to advocate for a deal that works for farmers and growers and supports UK food production.

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Read more on our sector-specific work


When will this take effect?

Until negotiations with the EU have concluded and the necessary legislative changes are introduced into UK law, the current arrangements remain in place. Government ministers are targeting mid-2027 for the implementation of the agreement.

The NFU has been clear with the government that the best way to manage dynamic alignment with EU rules would be to agree on transitional arrangements that give businesses and regulators sufficient time to translate what’s been agreed in the negotiations into domestic legislation. These could vary depending on the policy area and its degree of divergence.

For example, when the UK left the EU, a transition period began on the date the UK formally left (31 January 2020) and lasted until 31 December 2020.

The agricultural sectors have been impacted by Brexit differently and since leaving the EU, they have registered various degrees of regulatory divergence from EU rules. This context influences the sectors’ views on the length of any such transition period.

The government has stated that it is also considering what targeted transitional arrangements may be required for those sectors that will find it more challenging to implement the necessary changes ahead of the agreement coming into force.

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What is the NFU asking for?

Alongside targeted technical adaptations and exceptions to dynamic alignment, the NFU is seeking a phased and sufficient transitional arrangement to minimise potential disruption to the British agricultural sector whilst also not unduly delaying unlocking the potential benefits that certain aspects of the agreement could bring.

Read more about transitional arrangements and implementation of the agreement.

Select the relevant section below to find out how the negotiations will affect your business and the lobbying work that the NFU is doing in this area:

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More on the UK-EU SPS negotiations

This page was first published on 30 July 2025. It was updated on 11 March 2026.


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