The UK-EU SPS Agreement

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. 

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.. 

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.