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Reason for the changes听听听

The UK government is negotiating an agreement with the EU on the trade and movement of plants, plant products, animals, animal products,听feed听and food. This is called a sanitary and phytosanitary (SPS) agreement.听

The agreement means Great Britain (England,听Scotland听and Wales) and Northern Ireland will apply certain rules in line with the EU. These arrangements will apply听whether or not听you trade directly with the EU. It is our intention that the agreement will take effect in mid-2027.听

As EU rules change in the future, rules in Great Britain will update too. The UK will contribute to the decision-shaping process on future EU rules that will also apply in Great Britain.听

Read more about the benefits in听the UK-EU SPS agreement 鈥� information for businesses news story.听听

As negotiations are ongoing, not all details are confirmed at this stage.听This includes detailed requirements and the exact timing of when arrangements will change. We recognise that some businesses will take longer to comply and we are committed to working with them to ensure a smooth transition.听Further information will be provided following the completion of negotiations.听

Why听this matters听

This guidance is relevant to food businesses. It covers:听

• 蹿辞辞诲听产耻蝉颈苍别蝉蝉听辞辫别谤补迟辞谤听补诲诲谤别蝉蝉听谤别辩耻颈谤别尘别苍迟蝉听
• products requiring authorisations听
• food hygiene rules听
• food听products听subject to rules on compositional standards听
• fresh produce subject to rules on marketing standards听
• changes to听food labels听
• food contact materials

There are some differences between听Great Britain听and EU rules on food standards. Specifically, the changes might:

• affect what you produce and how you do this, including the standards that you听have to听meet听听
• open up听new opportunities for trade and change the way you do this听
• impact costs and processes听
• affect听you听through supply chains听

What this听means听for听food manufacturing,听processing听and standards听

These changes mean you will need to follow relevant EU rules for food standards, safety,听labelling听and regulated products. This applies听whether or not听you trade directly with the EU.听

You may need to review your products,听processes听and operations to ensure they meet updated EU requirements. This includes checking whether existing products, ingredients and production methods听remain听compliant.听

You may be affected in several areas, including:听

• the authorisation of regulated food and feed products, including additives,听flavourings听and novel foods听
• food hygiene and safety requirements, including contaminants and microbiological criteria听
• compositional standards for certain food products听
• food labelling requirements, including mandatory information and product descriptions听
• food contact materials and packaging requirements听

If your products rely on authorisations that currently apply in Great Britain, you may need to check whether these continue under EU rules and whether any changes to products or processes are听required.听听

You should also consider how changes may affect your supply chains, including sourcing of ingredients, manufacturing processes and how products are placed on the market.听

What businesses should know at this stage听

Organisations听and businesses, including food manufacturers and processors, are encouraged to听continue听engaging with the process听to be ready by mid-2027. You can do this听by keeping informed and opening conversations with听your听relevant trade body or industry association.听

At this stage, you are not expected to make detailed changes. You should consider the changes to requirements and how they could affect your business. The government will provide more detail in听summer 2026, including next steps.听听听听

What we know now听(and听what will be confirmed later)听

As negotiations with the EU are ongoing, not听all of听the details are confirmed at this stage. This information outlines what is known now to help you start planning, with further detail to follow later this year.听听听

Business addresses听

Under the听agreement,听it is expected that you will be听able to use a UK or EU food business operator address when marketing food for the Great Britain, Northern Ireland or EU markets. This simplifies the current rules, where food marketed in听Great Britain听requires听a UK听food听business听operator听address, and food destined for听the EU听or Northern Ireland听requires听an EU or Northern Ireland address.听

Regulated听food and feed听products听subject to pre-market authorisation听

If you produce or use regulated products听

鲍苍诲别谤听迟丑别听SPS agreement,听Great British听food and feed听authorisations听will cease to apply, and EU authorisations will听apply听in听Great Britain听in their place.听This includes the following听regulated听products and processes:听

• extraction solvents
• feed additives
• feed for听particular nutritional听purposes
• feed detoxification processes
• feed materials
• flavourings
• food contact materials
• food additives
• food enzymes
• genetically modified organisms听as听food and feed
• novel foods
• smoke flavourings

Food and feed authorisations in听Great Britain听and the EU听have diverged听since EU Exit,听in terms of听modification听of existing authorisations, revocations and听new听authorisations made.鈥疐or example, titanium dioxide is no longer authorised听as a food additive听in the EU and there has been a reduction in the permitted levels of nitrites and nitrates in EU听authorisations.听听

You need听to check听the following resources to determine听whether you need to reformulate your products or change products you use听to comply with EU rules under听the SPS agreement, noting that there may be further changes between now and when the agreement is in place:听

• feed additives, food additives, food contact materials, food flavourings,听genetically modified organisms听as food and feed, novel foods and smoke flavourings听鈥撎齝heck听the ,听which includes links to most of the EU lists of authorised regulated products, such as the听community register of GM food and feed听
• extraction solvents听鈥撎齝heck听the听听
• feed materials and feed for听particular nutritional听purposes听鈥撎齝heck听the听,听the听听and听听

Making marketing authorisation applications听

The EU鈥檚 requirements have听remained听consistent with the UK鈥檚 standards and will continue to ensure food and feed is safe before it reaches consumers. Pre-market authorisation will continue to ensure safety for consumers, consistency and quality across the market and trust in the food system.听

Businesses making market authorisation applications to the EU听from mid-2027听will need to follow the EU process and guidance for the relevant regulated product type.听For example, to make an application for the market authorisation of a food additive, or to听modify听an existing听EU听food additive authorisation, businesses will need to familiarise themselves with the听.听听听

All businesses will need to follow the updated transparency rules in the听.听This means听you听will听be required听to proactively听disclose听and notify European听Food听Safety听Authority听(EFSA)听of commissioned studies.鈥�鈥痶o clarify some鈥痮f the updated rules, which businesses will need to听review.听

If听you sell or produce听novel foods听

Great British听novel food authorisations听will cease to apply, and any data protection periods and associated market exclusivity听connected with that authorisation听will no longer apply.听You听will need to check the EU听novel food听authorisation status and any associated exclusivity provisions in the听 for the products听you听have an interest in so that听you听can ensure compliance.听

Some novel foods such as edible insects听are managed differently in听Great Britain听and the EU. As a result,听some products will need to be听reformulated or听withdrawn from the听Great British听market听when听Great British听authorisations are withdrawn under听the SPS agreement听from mid-2027.听Businesses with an interest in these products will need to check:听

• the 听
• the 听

If you use, produce or process food contact materials听听

Food manufacturers, processors and packaging manufacturers will need to check the听recent听technical changes made to听听to听see if the updates to good manufacturing practice requirements will require changes to their business operations听under听the SPS agreement. The EU is changing things听currently;听we will let you know more information when we have it.听

Since EU Exit, the EU has introduced changes to authorisation rules for some food contact materials. Businesses will need to familiarise themselves with any EU authorisations and changes relevant to their products or processes. For example (non-exhaustive list):听听

• plastic materials and articles in contact with food 鈥� there have been updates to the听,听new rules for natural substances, labelling changes and updates to testing conditions that businesses will need to align with听
• recycled plastics 鈥撎齊egulation 282/2008 has been replaced with听,听which sets rules for recycled plastic materials and articles intended for food contact, introduces authorisation of recycling processes and introduces monitoring requirements, so businesses wishing to place on the market, or process, recycled plastics will need to align with these rules
• bisphenol A听(BPA)听鈥撎�听prohibits the use of听BPA听(and its salts) in food contact materials, so businesses need to start reformulating their products or changing their processes to remove BPA听to ensure compliance with EU rules under the SPS agreement
• active听and intelligent materials and articles intended to听come into contact with听food 鈥� the use of the 鈥榙o not eat鈥� logo will become mandatory under EU rules. If businesses听do not currently use this logo on听their products, changes will be听required听to ensure compliance听with EU rules听under the SPS agreement

Food hygiene听and contaminants听

You听will need to check , as some rules have changed in the EU since EU Exit. Businesses will need to ensure compliance with these rules under听the SPS agreement.听Amendments include听extending the 鈥榮ell-by鈥櫶齞ate for eggs, and some new requirements, such as in the areas of temperature control and dry ageing of meat.听

Ready-to-eat (RTE) food producers will need to听comply with听.听This criteria only applies to RTE foods if:

• they support growth of Listeria monocytogenes
• you do not have enough evidence that they are under the limit of 100 cfu/g (colony forming units per gram)

You should review the 听and the听听to see if you need to make any changes. The change to the legislation does not affect use-by dates on your products or how you establish shelf life if your business already complies with existing legislation.

There will be new,听additional听and revised maximum levels for contaminants such as per- and polyfluoroalkyl substances (PFAS), heavy metals (for example, lead and cadmium), mycotoxins and听plant toxins in various foods. All food and feed businesses will need to ensure compliance with the levels set out in听.听

The UK听government has听made听clear that some听accommodations听to EU law will be听required听to account for听Great British听specific conditions, for example mycotoxin levels in oats. These are subject to听ongoing discussions with the EU.听听听

Official controls on products of animal origin听intended for animal consumption apply to game handling establishments in the EU. Game handling establishments听in听Great Britain听will need to check these rules to听determine听whether operational changes will be听required.听听

Foods subject to rules on compositional standards听

It鈥檚听expected that businesses will be able to choose to make changes听under some of the new rules. For example:听

• jams听and听jellies:听permitting听concentrated fruit juice as an ingredient in jam听
• fruit juices:听market new reduced-sugar fruit juices categories听and听use sunflower seed protein to clarify fruit juices
• preserved听milks:听apply treatments that reduce lactose content in dehydrated preserved milks and rebrand as evaporated听or听condensed milk,听adjusting minimum level for fat in evaporated听milk听as necessary

New听rules听will听mean some businesses need to change the composition of their products if they wish to continue marketing these products under听specific (reserved)听terms. These include:听

• jams, jellies and听marmalades:听increases to the听minimum听amount of fruit听required听per 1,000g of finished product in jam, extra jam and jelly and extra jelly (minimums vary according to fruit species and are category dependent)听as per听听
• reduced听sugar jams,听jellies听and听marmalades: the 鈥榬educed sugar鈥櫶齪rovision in domestic rules (requiring a soluble dry matter content of not less than 25% and not more than 50%)听will听be removed, and reduced sugar, jellies听and听marmalades will need to meet the reduced sugar definition of a minimum of 30% less sugar than a full sugar product as set out in听听听
• coconut听juice and coconut water: minimum Brix level of 4.5听(sugar content)听
• fruit听nectars:听new听upper limits for honey听or听sugar included in fruit nectars 鈥� depending on fruit source, this听corresponds to:听
  • 20% of finished product for听fruit nectars听when听made from听fruits with acidic听juices听unpalatable in the natural state听(Part I Annex IV of听)听听
  • 15%听when made from low-acid, pulpy or highly flavoured fruits with juice unpalatable in the natural state听(Part听II Annex IV of )听听
  • 10% for听fruits with juice palatable in the natural state听(Part III Annex IV of )听听
• olive听oil blends:听only听extra virgin olive oil, virgin olive oil, olive oil composed of refined olive oils and virgin olive oils, or olive-pomace oil may be part of blends of olive oil

When听businesses change the composition of their products, or adjust their practices, they may need also to change their labels to ensure they听remain听accurate听and compliant with food labelling rules.听In addition to this, there will be some changes to the rules on how these types of food products should be labelled, even听if听no changes are made to the product itself,听and these are set out in the food labelling section.听

Bottled waters听鈥� alignment with Directive 2009/54/EC听

Domestically produced natural mineral waters that have been granted domestic recognition would be able to be marketed on the EU single market without having to seek听additional听recognition from an EU member state.鈥�鈥�听听

This will also be the case for third country waters recognised in Great听Britain听鈥� they too can be sold in the EU without听additional听recognition from the EU.听听听

Likewise, EU-recognised natural mineral waters will be recognised here in Great Britain without听additional听process.听听听

For spring waters,听only the听below听treatments听will be听permitted, with specific rules听attached to each treatment:听听听

• filtration听or decanting听
• removal听of free carbon dioxide听
• adding听carbon dioxide听to produce carbonated or sparkling water听
• ozone-enriched听air oxidation technique听听
• activated听alumina听

This means that UV treatment will no longer be听permitted.听

Fresh produce听and hops听subject to rules on marketing standards听

It鈥檚听expected that businesses will be able to choose to make changes under some of the new rules. For example:听

• mixes听of fruit and vegetables: will be able to be marketed听up听to a weight of 10kg (previously听it was听5kg)
• bananas: relaxation around how they can be presented听鈥� minimum number of fingers in a cluster of bananas will be removed听
• hops:听the maximum weight limit听will increase听for small packages of hops and hops products听for sale to private individuals for their own use听which are exempt from certification requirements听
• poultry meat:听water content testing can now only be done via the chemical method rather than by drip听testing听听
• new听poultry cuts are now defined in marketing standards: bone-in thigh with a听portion听of the back, inner fillet, feet, paws, neck, head, supreme, wishbone, scapula
• the requirement to display whether the听poultry meat听is class A or class B as well as the recommended storage temperature on听accompanying听commercial documents has been removed,听however,听the definitions for class A and class B听are expected to听remain 鈥� this does not remove or change existing temperature requirements on handling fresh or frozen听poultry meat

New rules will mean some businesses may need to make changes听to marketing:听

• certain citrus fruits听(limes, grapefruits, pomelo and shaddock)听and new apple varieties听are expected to听be brought into scope of specific marketing standards for the first time听
• shell eggs:
  • quality characteristic requirements for class A eggs in听change from no foreign smells to no 鈥渦nintended鈥� foreign smells, to accommodate aromatised eggs听
  • new听on-farm marking听rules听in听Article 8(1) of 2023/2465 mean听eggs will be marked with the producer code before leaving the production site听
  • Article 8(2) of 2023/2465 sets out a requirement that, where a destination member state exempts a supplier from marking rules, consignments must be accompanied by a copy of the delivery contract

Changes to food labels听

The main food labelling rules (under the EU鈥檚听Food Information to Consumers听Regulation听1169/2011)听have听changed听very little听since the UK鈥檚 exit from the EU. The fundamental rule will remain that food听information听must not be misleading. However, changes to sector specific rules such as food compositional and marketing standards rules may require information on food labels to be changed.

Changes听are not expected to the compulsory labelling indications for fresh and frozen beef. This means that in respect of Great听Britain, we expect that the country indications for birth, raising,听slaughter听and cutting will continue to be 鈥楿nited Kingdom鈥�.

It鈥檚听expected that businesses will be able to choose to make changes under some of the new rules听to their labels. For example:听

• allergen labelling:听high purity听behenic acid derived from mustard seeds听is听exempt from mandatory mustard allergen labelling in the EU, emulsifiers听such as听E 470a, E 471 and E 477听made from behenic acid听will听no longer require the word mustard to be highlighted or listed in the allergen declaration
• food听business听operator听address: a UK or an EU听food business operator address should be acceptable for food sold in either the UK or the EU and so you may choose to change the food business operator address on your label 鈥� Northern Ireland businesses will be able to continue to use an address in Northern Ireland, the EU and Great Britain
• fruit听juice: you can choose to make the statement 鈥榝ruit juices听contain听only naturally occurring sugars鈥櫶�
• coconut听water听or听juice: you will be able to use the term 鈥榗oconut听water鈥� interchangeably with 鈥榗oconut听juice鈥櫶�
• jams,听jellies and marmalade:听you will no longer need to听label听the sugar content as听鈥榯otal sugar content听[number]听g per 100 g鈥櫶齛nd instead听provide sugar information听as part of the nutritional information听panel听

New rules will mean some businesses may听need to make changes听to labels even if the food product itself does not need to change. These include听the following:听

Restrictions on what can be included on the label:听

• fresh听fruit and vegetables: restrictions on听additional听terms听that听suggest superior quality, or any descriptor of quality not specified听in the marketing requirement set out in Annex I of Delegated Regulation 2023/2429
• olive听oils: the harvesting year will be permitted only on extra virgin olive oil and virgin olive oil; olive oil legal names will not be permitted where other food stuffs are added to extra virgin olive oil, virgin olive oil, olive oil composed of refined olive oils and virgin olive oils, or olive-pomace oil
• origin labelling: for mixed fruit and vegetables, minced meat, blended olive oils and any food providing information about the origin of the primary ingredient,听the use of 鈥渘on-UK鈥� to describe origin will not be permitted, this听will be replaced with the option to provide origin information using the terms 鈥淓U鈥� and 鈥渘on-EU鈥�

New mandatory information requirements:听

• ID marks applied to products of animal origin including meat, dairy,听fish听and egg products: you听may听need to change the form of the ID mark: under EU rules听(), establishments within the听EU听must use the EU suffix
• marmalades: citrus spreads marketed as marmalade will need to听be听labelled听as 鈥榗itrus marmalade鈥� or refer to the name of the citrus fruit听for example,听鈥檕range marmalade鈥櫶齩r the number of fruits used听
• prepacked fruit and vegetables: the听net听weight听will be听required听as per听听
• blended honeys: the countries of origin in descending order of contribution with percentages per country contribution听must be听provided
• nuts听(both in-shell and kernels, and their mixtures), dried fruits, mushrooms, capers, saffron and ripened bananas: country of origin labelling听required听
• potatoes听from Lebanon:听additional听origin and producer information听required

Changes to nutrition-related labelling composition and standards听rules听

Businesses will need to听comply with听EU rules on听nutrition-related labelling, composition and standards (NLCS),听which听cover:听

• nutrition labelling on all food (see also section on food labelling)听
• nutrition and health claims听
• food supplements听
• fortified food听
• food for specific groups (including infants and young children, food for special medical purposes, and total diet replacement for weight control)

Since EU Exit, the main changes the EU has introduced relate to regulations for total diet replacement for weight control products.听In 2022,听听came into force, which introduced new compositional, labelling and marketing requirements for food business operators.听These include:听听

• compositional changes including a听requirement for higher levels of protein in products听鈥� businesses may need to reformulate products听听
• prohibition of听nutrition and health claims听on these products听
• the听introduction听of听a requirement to notify competent authorities when placing TDR products on the market

The EU has also restricted and听prohibited听certain substances in food and food supplements.听This is set out in the annexes of听听on the addition of vitamins, minerals and of certain other substances to food.听听听

Additional听changes to NLCS legislation are optional for businesses. For听example,听changes听that allow:听

• different forms of vitamins and minerals to be included in specific foods听
• additional听protein hydrolysates (protein hydrolysed into its听component听products including amino acids and peptides) to be used in infant formula

Composites听

For information relating to composite products, please see the importing and exporting section below.听

Importing and exporting听

The new SPS agreement is relevant to all businesses and organisations involved in importing and exporting SPS goods between the UK,听EU听and the rest of the world.听

For trade between Great Britain and the EU, the SPS agreement will reduce the requirements for routine SPS documentation and controls. The requirements for export health certificates, phytosanitary听certificates听and routine border checks for most agrifood goods will be removed. Alignment with EU rules will mean there will be alignment with the EU鈥檚 approach to checks on rest听of world SPS trade. Requirements for trade with countries outside the EU will also continue to apply, in line with international rules.听

Import rules for composite products from non-EU countries will change. A听composite product is one that听contains听processed products of animal origin and a plant product used as a main ingredient,听not just for flavouring or to aid processing. For example, a lasagne or cream liqueur.听

Composite products imported into Great Britain will need an export health certificate if they听contain听meat, or听need to be transported in a chilled or frozen state (meaning not shelf-stable).听

Composite products will require a new 鈥榩rivate attestation鈥� document, signed by the importer or import agent in Great Britain, if they are shelf-stable or听contain听no meat.听听

When one is needed, the type of EHC听required听may vary. For example, there are specific rules for composites where the only POAO听component听is honey,听gelatine听or snails. You do not need an EHC at all if the only meat听component听in a composite is gelatine,听collagen听or certain highly refined products.听

Both groups will need to enter Great Britain via a suitably approved border control post and will be subject to border checks.听听

Certain shelf-stable composite products that do not听contain听meat may be exempt from official controls at border control posts, provided they meet specific requirements set out in EU legislation (including labelling, packaging and heat-treatment conditions). This exemption applies only to products listed in , such as certain confectionery, cereal-based products, pasta and breads.听

Special considerations are听required听for food supplements under this exemption, owing to the听particular uses听of plant materials in these products.听

Customs controls will remain.听

Great Britain to Northern Ireland movements听听

Under the SPS agreement, most agrifood goods will not need routine SPS certificates, checks and paperwork when moving from Great Britain to Northern Ireland.听

This will mean听export听health听certificates and听phytosanitary certificates, and the checks and controls associated with them, will no longer be听required.听

This will apply to all products that can be moved into the EU, which will include all food for processing, many retail products and, for example, plants for planting, seeds, and used agricultural and forestry machinery. The final restrictions on the movement of certain tree species will disappear.听

The Windsor Framework will continue to apply, addressing Northern Ireland鈥檚 unique circumstances and safeguarding the Good Friday Agreement. This听facilitates听Northern Ireland鈥檚 dual market access to both the UK internal market and the EU single market.听

In practice, the movement schemes set up under the Windsor Framework should no longer be needed, other than potentially for a limited number of goods not covered by the agreement. The Northern Ireland plant health label (NIPHL) scheme will not be needed at all.听

Early听considerations for your business听

To prepare for the UK-EU SPS agreement, you can now take the following steps:听

• and the 听to receive the latest updates听
• check whether the SPS agreement is likely to apply to your business, especially if you produce, handle, move or trade animals, animal products, plants, plant products,听food听or feed 鈥� check how to prepare your business听
• review your current supply chains and movements (including domestic movements and movements from Great Britain to Northern Ireland) to understand where SPS requirements may apply听
• consider where your business currently follows EU rules and where you may have diverged since EU Exit听
• speak to relevant partners (for example suppliers, customers, hauliers,听vets听or certification bodies) about potential future changes听
• check with trusted sector organisations or trade bodies for any sector specific advice and updates听

Exceptions听

The EU has accepted there will need to be鈥痑reas where the UK will鈥痳etain鈥痠ts own rules, as set out in the鈥�May 2025 Common Understanding.鈥疍etails of these are subject to the ongoing negotiation.鈥�听

The government has been clear about the importance of鈥痓eing able to:听

• set high animal welfare standards听
• support public health听
• support the use of鈥痭ew and innovative technologies听

Further information will be provided following the completion of the negotiations.听听

What happens next听

It is our intention that the agreement will take effect in mid-2027. Some detailed requirements and exact timings of when arrangements will change are still being finalised as part of ongoing negotiations.听听

Defra will continue to work with the sector to help shape future communications, guidance and support as further detail becomes available. We have set up an SPS Readiness Business Advisory Council, which is now meeting regularly. The council includes major trade associations and businesses.听听听

The following timeline sets out the expected stages for introducing the SPS agreement and when further information will be published:听

• summer 2026 鈥� further details on upcoming changes announced, including on any exceptions and transition periods
• autumn 2026 鈥� detailed guidance and support, including checklists and practical tools, made available听
• mid-2027 鈥� agreement takes effect (subject to negotiations)听

Further information will be provided following the completion of negotiations.听

Stay informed听

We will continue to publish updates as further detail is confirmed. To keep up to date, you can:听

• 听and the听
• engage with your trade body or industry association for sector-specific updates, where relevant听

You can also get鈥痑dditional鈥痵upport from other government agencies if you are a small or medium-sized enterprise (SME), contact:鈥�听

• Department for Business and Trade:听 a question
• Food Standards Agency:鈥�