This report, from the cross-party, cross-industry UK Trade and Business Commission (UKTBC) delivers 5 substantive recommendations for the UK Government, and our EU partners on how we can make an SPS deal a reality.
The Common Understanding, published in May 2025, states that the UK and EU “should work towards establishing a Common Sanitary and Phytosanitary Area by way of [an SPS] Agreement”. 11 of the 61 paragraphs which make up the Common Understanding are dedicated to the SPS agreement. Despite this relatively detailed framing (by contrast, just one paragraph is dedicated to the Youth Experience Scheme), negotiations on this topic have not been entirely straightforward.
At the time of writing, the 2026 UK-EU Summit is expected to take place in the summer, slightly later than its 2025 forerunner. In March 2026 the Department for Environment, Food & Rural Affairs (DEFRA) published guidance urging “every business in the agri-food sector [to] start to prepare now” for the new arrangements. DEFRA stated its intention for an agreement to be in place by mid-2027, suggesting that negotiations were nearing completion. Press reports ahead of the March 2026 UK-EU Parliamentary Partnership Assembly underscored this view.
Since 2021, the introduction of Export Health Certificates, plant health certificates and increased border checks have harmed GB-EU agrifood trade. In February 2026, the National Farmers’ Union (NFU) calculated that British farm product sales to the EU had declined by 37% between 2019 and 2024.
The introduction of the Trade and Cooperation Agreement (TCA) has contributed to food price inflation. A 2023 London School of Economics study put the per household cost of Britain diverging from EU agrifood standards after leaving the EU at £250. The study notes that while UK food prices rose by 25% between December 2019 and March 2023, this would have been limited to 17% had the UK remained in the EU..
Great Britain leaving the EU's common food area created particular problems for Northern Ireland that were illustrated by the introduction of ‘Not for EU’ labels displayed on food products. This significantly reduced consumer choice in Northern Ireland supermarkets, contributing to complexity and consumer costs. These impacts have been lessened only following significant time and effort including via the Windsor Framework, but any regulatory divergence would bring the issue back to the forefront.
If the damage of divergence is widely understood, a common UK-EU food and drink area should be the basis on which to repair this damage. At the same time, several thorny issues related to the SPS Agreement need to be addressed. These are summarised below, and covered in more detail in sections 2-6 of this report.
Dynamic alignment
The Common Understanding determines that the UK will align with EU SPS rules on an ongoing basis. The Common Understanding also provides for “a short list of limited exceptions to dynamic alignment”. Three areas where exceptions have been suggested are: animal welfare, plant protection products (pesticides), and precision breeding. Weighing the costs and benefits of securing ‘carve-outs’ on these issues has been a key issue for UK Ministers and civil servants since talks on an SPS Agreement began. A continued England-only exception on precision breeding would pose challenges for the UK Internal Market.
Implementation
Some stakeholders will embrace the SPS Agreement as a liberation from red tape and costly, time-consuming checks. Others will experience it as a complicated, burdensome process to ensure compliance where approaches have diverged. The UK Government should ensure proper engagement with this latter group, and prepare the necessary measures to ensure a smooth implementation in practice.
Legislation
Senior MPs want a greater role for Parliament in scrutinising UK trade deals, challenging the post-2021 emergence of “executive-led” treaty-making and implementation. Ministers will need to decide whether to grant this wish, or to prioritise speed of adoption, and then pursue further areas of UK-EU alignment. In any event, updating all relevant SPS standards so they align with the 76 EU regulations and directives in scope for the agreement will be a major legislative project, involving the UK, Scottish and Welsh Parliaments.
Broader aims for the UK-EU relationship
Senior MPs have urged the UK Government to provide more clarity on its strategic objectives for the UK-EU relationship. The way the UK Government approaches the SPS Agreement, and the trade-offs it will impose, could go some way to clarifying its longer-term intentions for UK-EU relations.
Maximising the benefits
Ultimately, the SPS Agreement can help the UK Government to get closer to delivering against two of its primary aims: improving economic growth, and mitigating cost of living pressures. Crucial to this is seeking a commitment from the EU to remove checks quickly, on which the UK should seek clear timescales.