Submission to EFRA Committee's inquiry on animal and plant health

Summary

The proposed SPS Agreement offers significant opportunities for the UK. It promises to make life easier and reduce costs for UK agrifood businesses, and to bring about an end to the damaging labelling requirements introduced in Northern Ireland following the Windsor framework. It is likely to increase UK-EU trade, and boost UK GDP, albeit modestly. 

Best for Britain polling suggests that the British electorate are supportive of dynamic regulatory alignment with the EU in exchange for the improvement in trade that an SPS deal will bring. 

That said, the SPS deal forms just one part of wide-ranging UK-EU negotiations. The UK Government will have to weigh the importance it attaches to aspects of the SPS agreement, such as its current plans for faster deregulation on precision breeding, against other policy priorities. Those will include the number of visas issued as part of the UK-EU Youth Experience Scheme, the nature of a closer UK-EU defence partnership, and payments for access to the EU’s internal energy market, among many others. To assist the UK Government in its assessment on how much weight it should attach to precision breeding, the Committee should recommend that an independent cost-benefit analysis of this issue be conducted.

Given the small size of the UK’s agrifood sector, and the far greater economic benefits that would stem from a closer trading relationship with the EU in goods and services, the UK may want to make concessions now in order to achieve bigger gains in the future.

Dynamic regulatory alignment

In advance of the May 2025 UK-EU summit, Best for Britain commissioned YouGov to survey 4,703 British adults about their views of UK-EU relations, what they considered to be the main issues facing the country and what the priorities for the summit should be.

The survey also asked respondents their views on some possible trade-offs which could result from a closer UK-EU trading relationship. Two of these questions relate specifically to an SPS agreement, and whether people would support the UK Government securing an improved trading relationship with the EU if required to agree to the same rules as the EU. 

In response to the question, “Thinking about the UK’s relationship with the EU, would you support or oppose the government securing a better trading relationship with the EU if it meant… the UK agreeing to the same animal and plant health rules as the EU?”, more than half (53%) of respondents would be in favour, with just one in five (21%) opposed. 

In response to the question, “Thinking about the UK’s relationship with the EU, would you support or oppose the government securing a better trading relationship with the EU if it meant… the UK agreeing to the same veterinary rules as the EU?”, half (49%) would be in favour, while less than one in five (18%) would be opposed. 

These results suggest strong public backing for the UK Government introducing dynamic regulatory alignment with the EU as part of an SPS deal. For British voters, alignment with EU regulations is seen as a small price to pay in order to improve the terms of trade for UK agrifood exporters.

Best for Britain’s YouGov polling also asked respondents to state, from a list of 19 options, what they considered to be the most important issues for the UK Government to focus on improving. The ability to sign new trade deals with non-EU countries came in joint-fifth from bottom, cited by only 7% of respondents, while the ability to sign new trade deals with the US came joint bottom, selected by just 4%. The same question revealed significant support for bolstering trade with the EU: trade was the sixth most-cited issue, ahead of the quality of public services and the availability of jobs in the UK.

Best for Britain’s polling has uncovered very few risks to pursuing dynamic regulatory alignment. Voters are strongly in favour of following EU animal and plant health rules, and EU veterinary regulations in exchange for an improved trading relationship; and they consider the theoretical downsides of EU alignment more generally to be unimportant. These factors, combined with the fact that the Labour Party committed to securing an SPS deal within its 2024 election manifesto, suggest the UK Government should be confident in pursuing dynamic alignment as part of the SPS deal it negotiates. The technical details of the SPS agreement may of course present significant challenges for the teams of negotiators on both sides, and in an August 2025 speech Cabinet Office Minister Nick Thomas-Symonds stated his expectation that a deal may take until 2027 to be implemented. But the specific issue of dynamic alignment should now be seen as politically straightforward in the UK.

Preparing for potential regulatory divergence: precision breeding

The UK-EU Common Understanding states that an SPS agreement “should include a short list of limited exceptions to dynamic alignment”. It is widely understood that precision breeding could be one of the areas where an exception may be considered. The Genetic Technology (Precision Breeding) Act 2023 brought in a new regulatory framework for the treatment of precision-bred organisms in England. Following secondary legislation introduced in May 2025 applying to crops, businesses would be able to apply to bring gene-edited crops to market from November 2025. By contrast, the EU still considers gene-edited organisms under more stringent regulations governing genetically-modified organisms. Therefore, for the broader SPS negotiations, of which the UK’s agreement to dynamic regulatory alignment is a core part, to conclude successfully, one of two things appears very likely to happen: either the EU will agree for precision breeding to be a formal exception to dynamic alignment, or the UK will need to drop its request.

Support for divergence

A number of organisations have expressed strong support for the UK Government seeking to ensure precision breeding be ‘carved out’ from dynamic regulatory alignment. One of the most vocal is multinational pharmaceutical and biotechnology firm, Bayer. In January 2025, Bayer argued that the introduction of precision breeding will “help deliver sustainable crops that meet the specific needs of both producers and consumers”. Previously, in September 2024, it called on the newly-elected Government to accelerate plans to introduce the necessary “implementing rules”, via secondary legislation, without which the Precision Breeding Act would “serve no functional purpose”. The passing of this secondary legislation in May 2025 has been welcomed by organisations including the Agricultural Industries Confederation and the National Farmers’ Union.

Weighing the benefits and costs of regulatory divergence

The inclusion of precision breeding as an exception to dynamic alignment under the SPS deal could impose political, economic and/or financial costs on the UK Government. The precise nature of these costs would only become clear during negotiations with the EU. However, Best for Britain has not been able to identify sufficient analysis to quantify the economic benefits of precision breeding. The absence of more detailed projections for the expected benefits therefore creates a significant issue: without having an idea of the level of magnitude by which, for example, crop yields and UK GDP may increase, costs to farmers may reduce or national food security may improve, it becomes difficult to see how the UK Government would justify wanting to insist that precision breeding becomes an exception to dynamic regulatory alignment. Without more detail, the UK Government risks accepting a cost in exchange for an unknown benefit. The Committee should ask advocates of precision breeding if they have carried out any estimations of the economic benefits that can be expected, to help the Committee and the UK Government to make a better-informed judgement on this issue. 

A further major consideration, which is perhaps more pertinent for businesses, is the likely timescale for progress on the EU side. The posited benefits of precision breeding are of course just as appealing to EU member states as they are to the UK (or any other country). The passing of the 2023 Precision Breeding Act was presented as a benefit in large part because it was said to demonstrate the UK’s ability to innovate at greater speed than the EU. In recent months, however, the EU has made significant progress towards introducing new regulation on precision breeding (“new genomic techniques” or NGTs, in the EU’s nomenclature). In April 2025 the European Parliament’s Committee on Environment, Food Safety and Public Health voted in favour of opening interinstitutional negotiations on NGTs. At the time of writing it is not known when these negotiations will conclude, but after months of stalled talks, it is clear that the EU is now moving forward. As law firm Osborne Clarke described in a summary note on the UK-EU SPS deal, businesses with operations in the UK and the EU may prefer to support a single, harmonised framework. The law firm concludes that it is “likely” that the UK will have to “slow down its plans” in the gene-editing space. 

An anticipated benefit of the SPS deal is that, through regulatory alignment, it would lead to the removal of onerous certification and controls, such as the “Not for EU” labels, displayed on food products exported from Great Britain to Northern Ireland. These labelling requirements have significantly reduced consumer choice in Northern Irish supermarkets, and contributed to complexity and consumer costs. The Committee should consider whether and how far a potential precision breeding exemption could lead to the introduction of new labelling requirements for these new products. And if new labelling requirements were introduced, would this negate the expected benefits associated with the removal of the “Not for EU” labels? The Committee should invite stakeholders, including the Food Standards Agency, to give oral evidence on the potential implications for labelling, red tape and other costs that would be anticipated if the UK does indeed pursue precision breeding as an exception to dynamic alignment. 

In considering whether it will recommend that the UK Government should press ahead with divergence on precision breeding, the Committee should also give consideration to the likely nature of the UK’s concessions to the EU in such a scenario. If the concessions were, for example, to take the form of an increased financial payment, at what level would the Committee consider this higher payment to offer value for money to UK taxpayers?  Perhaps the best way to guide future negotiations would be for the Committee to recommend an independent cost-benefit analysis be conducted, encompassing the economic benefits of precision-bred products coming to market, the likely ‘price’ the UK would have to pay in order to extract this concession from the EU, the implications of the EU itself now appearing to move at a quicker pace on NGTs, and the likely additional costs associated with any new labelling requirements. 

In this light, the need for more detailed projections of the expected economic benefits of divergence is plain. The Committee should also be mindful of the broader set of negotiations between the two sides on other topics. Even if, theoretically, teams of UK and EU negotiators will work to achieve balanced outcomes for each of the large areas to be agreed - SPS, Emissions Trading Systems, mobility, defence, energy cooperation - in isolation, in practice the discussions are likely to be more complicated. Whether the UK’s current trajectory of faster deregulation on precision breeding than the EU survives the forthcoming negotiations may hinge on how well discussions on other topics progress.

Implications of an SPS agreement for trade

The UK Trade and Business Commission (UKTBC), for which Best for Britain provides the Secretariat, has been a longstanding advocate of a new SPS area between the UK and EU. In May 2023, UKTBC argued that an SPS area would “facilitate seamless trade in livestock, plants, and related products” and “support wider Government efforts to level the trading playing field for UK food producers”. It is undoubtedly an achievement for the current UK Government to have secured a commitment on a new SPS area to come into force. Since Brexit, the end to UK-EU regulatory harmony has meant additional millions of pounds in costs to UK agrifood businesses as a result of red tape and delays. The removal of Export Health Certificates, plants health certificates and a reduction in border checks should be good news for UK agrifood businesses and consumers alike.

The SPS deal will mean Northern Ireland and Great Britain once again agreeing to the same set of rules on agrifood. It is expected that the “Not for EU” labels contained on food products exported from GB to NI, introduced via the Windsor Framework, will no longer be required once the deal is concluded. The removal of these labels would be a major benefit for Northern Irish consumers, who have faced fewer choices in supermarkets after the costs and red tape imposed by labelling requirements led many businesses to stop exporting to Northern Ireland (and the Republic of Ireland). 

The UK Government has estimated the combined impact of the SPS and energy cooperation deals will add around £9 billion to the UK economy by 2040, or roughly 0.3% of GDP. While this is a very welcome improvement, agriculture accounts for less than 1% of the UK economy, and so an SPS deal would never provide a very significant boost to GDP. 

Companies operating throughout the agrifood industry and supply chain stand to see significant benefits, but the UK Government’s 0.3% estimate for the impact on UK GDP is in line with independent research conducted by Frontier Economics and commissioned by Best for Britain, which found that UK-EU alignment on SPS regulations alone would have no meaningful impact on UK GDP. The research found that in order to drive significant growth to UK GDP, it would be necessary to go beyond an SPS deal to harmonise regulations and standards on goods. In a scenario with no US tariffs, Frontier found that UK-EU alignment on goods trade would add up to 1.5% to UK GDP, and that alignment on goods and services would add up to 2.2%. (The research also showed that UK-EU alignment would help both sides to lessen the impact of US tariffs). These growth estimates are far higher than those for other policy reforms and trade deals the Government has introduced and secured. If it wishes to drive economic growth, it is in the UK Government’s interests to expedite aspects of the outline deal with the EU, so that a future UK-EU Summit can mark the beginning of negotiations on alignment on goods and services trade. 

An April 2024 study for the Centre for Business Prosperity at Aston Business School by Prof Jun Du, Prof Gregory Messenger and Dr Oleksandr Shepotylo reached a similar conclusion. In addition to their core conclusions that an SPS agreement could lead to a 22.5% increase in agrifood exports, a 5.6% increase in imports, and an extra 0.2% to the agricultural sector’s value added, the authors emphasised the benefits of viewing such an agreement as an intermediate step on the road to broader improvements in the UK-EU trading relationship. They state that an SPS agreement “can be viewed not just as an economic instrument but also as a strategic step towards rebuilding a more constructive and trusting relationship between the two regions. This agreement could set the stage for future negotiations on more complex issues, such as the mutual recognition of professional qualifications”. 

In this and other deliberations that form part of the current inquiry, the Committee should bear in mind not just how any recommendations it makes are likely to be received by the EU (as the UK’s negotiating counterpart), but also their potential to either support or detract from the UK Government’s broader strategic objectives.