UK-EU SPS agreement: what food manufacturers must do now

By Adrian Sidaway, Director (RI) Head of Corporate Audit & Accounts

There is a tendency in the food and beverage sector to file anything with the words “sanitary and phytosanitary” under “trade and logistics” and move on. The UK-EU SPS agreement, agreed in principle at the UK-EU summit in May 2025 and targeted for implementation by mid-2027, has been treated by too many manufacturers as a border-checks story. Something for importers and exporters to worry about. Something the logistics team will handle.

That reading is wrong, and it could prove expensive.

The SPS agreement is not a trade deal with a regulatory side effect. It is a regulatory reset with a trade benefit attached. Under the terms published by the UK Government on GOV.UK, Great Britain will adopt dynamic alignment with EU food law across eighteen distinct policy areas. That covers food safety, additives, contaminants, labelling, novel foods, food contact materials, hygiene standards, health and nutrition claims, pesticide residue levels, and marketing standards. The EU rules will replace, not supplement, the rules currently applicable in Great Britain. And they will apply to every food and drink business operating in the UK market, whether or not that business has ever sent a single pallet across the Channel.

That last point deserves repeating. A manufacturer in the Midlands producing sauces sold exclusively through UK wholesalers will be subject to the same regulatory realignment as a seafood processor shipping to France. The FDF has made this explicit: the agreement applies to all UK food and drink businesses, even if they do not export to the EU. This is not a selective measure. It is a wholesale rewriting of the domestic rulebook.

Where has UK food law actually diverged?

The practical implications of the agreement depend on how far UK and EU food law has drifted apart since Brexit. In some areas, very little has changed. Coffee and sugar compositional standards, for instance, have remained broadly aligned. But in others, the divergence has been meaningful, and reversing it will require real work on the factory floor.

Take titanium dioxide, classified as E171. The EU banned it as a food additive in August 2022 following an EFSA safety assessment. The UK’s Food Standards Agency did not follow suit, and the additive remains permitted in Great Britain. Any manufacturer currently using titanium dioxide in products sold on the UK market should assess whether reformulation will be required if EU rules are adopted through the SPS agreement.

Nitrites in processed meat tell a similar story. In October 2025, the EU introduced new rules cutting the maximum permissible levels of nitrites added during meat product manufacturing by nearly half. Great Britain has not yet adopted equivalent limits. Meat processors and charcuterie producers relying on current UK-permitted levels will need to review their formulations and, in some cases, their production processes.

"The businesses caught out here will not be the ones that got the science wrong. They will be the ones that assumed a domestic approval meant a settled position."

Then there is the novel foods regime. Since Brexit, the UK has operated its own market authorisation pathway for novel food products, separate from the EU’s. Current government guidance indicates that EU authorisations are expected to replace the existing GB authorisation framework for products within scope of the agreement. For manufacturers holding a GB-only novel food authorisation, or with an application in progress through the UK system, this is not a theoretical risk. Products may need to be reformulated or withdrawn from the Great Britain market unless and until a corresponding EU authorisation is obtained, a process that can take several years.

The edible insects market offers a pointed example. Certain insect-based products are managed differently in Great Britain and the EU. GOV.UK guidance now states directly that some products will need to be reformulated or withdrawn from the GB market when GB authorisations are withdrawn under the agreement from mid-2027.

How much of this is on the sector’s radar?

Not nearly enough. The FDF’s Q1 2026 Trade Snapshot found that 41% of its members are either unaware of the SPS agreement or do not understand how it will affect their business. That figure is striking given the scale of what is coming. Over 400 areas of legislation are expected to come into line with EU requirements. This is not a single regulation to absorb. It is a programme of alignment that touches almost every part of how a food product is made, labelled, and sold.

The Government’s own timeline sets out three phases: further details on upcoming changes, including exceptions and transition periods, expected in summer 2026; detailed guidance, checklists, and practical tools in autumn 2026; and the agreement itself taking effect, subject to negotiations, in mid-2027. That timeline is ambitious even for businesses that are already paying attention. For the 41% that are not, it is a cliff edge.

The FDF has warned that lessons from other alignment exercises should be heeded. When Switzerland aligned with equivalent EU food safety standards, businesses were granted 24 months to adapt. The UK’s current trajectory offers significantly less time between detailed guidance and implementation, and some industry figures have described the mid-2027 target as precisely that: a cliff edge with insufficient runway.

What should a food manufacturer be doing now?

The instinct to wait for the autumn guidance is understandable but risky. The areas of divergence are already published. The list of EU legislation in scope is on GOV.UK. A manufacturer does not need to wait for Defra to tell them whether titanium dioxide is in their products, or whether their novel food authorisation is GB-only.

The first step is a regulatory gap analysis. Every food manufacturer should be reviewing the GOV.UK list of legislation in scope against their own product range, ingredient specifications, and labelling. The question for each product is straightforward: where UK and EU rules have diverged since Brexit, does this product comply with the EU position? If it does not, what needs to change, and how long will that change take?

Formulations are the obvious focus, but labelling deserves equal attention. Origin marking, allergen declarations, nutritional information, and food contact material requirements have all seen divergence, some of it subtle but all of it enforceable. A label reprint is cheaper than a product recall, but only if it happens in time.

Supplier contracts are another area that businesses often overlook until the deadline is close. If a manufacturer’s current ingredient supplier is providing a product that meets GB standards but not EU standards, the SPS agreement will make that supplier non-compliant. The time to audit supply chains is before the transition, not during it, when every other manufacturer in the sector will be trying to do the same thing.

The digital and IT dimension is also worth noting. Businesses that trade with the EU will need to interact with EU digital systems such as TRACES NT. Even for businesses that do not trade cross-border, the shift in underlying regulatory references may require updates to quality management systems, product specification databases, and compliance documentation.

Is there an upside?

The agreement is not without commercial logic. Food and drink exports to the EU fell 6.9% in volume terms in Q1 2026 compared to Q1 2025, continuing a decline that has seen export volumes drop by nearly a quarter since the pre-Brexit era. The SPS deal is intended to reverse some of that damage by eliminating the need for export health certificates, reducing border checks, and removing the “Not for EU” labelling requirement that has been a persistent source of friction and cost.

For manufacturers that do export, or that have considered exporting but been deterred by the complexity, the agreement opens a door. A single regulatory framework across the UK and EU market simplifies product development, packaging, and compliance. The ability to use either a UK or EU food business operator address on labelling, regardless of destination market, removes a practical headache that has dogged dual-market businesses since Brexit.

But it is important to be clear-eyed about what “simplification” means in practice. For businesses that had built their product ranges, ingredient specifications, and quality systems around the post-Brexit UK framework, alignment means change. It means cost. And it means doing that work against a timeline that, as things stand, gives most businesses less than twelve months from the point at which detailed guidance appears to the point at which the rules apply.

The audit question that matters

The question every food manufacturer should be asking right now is not whether the SPS agreement will affect them. It will. The question is whether they know, product by product, ingredient by ingredient, where they stand. A regulatory gap analysis conducted now, while there is still time to source alternative ingredients, commission reformulation work, reprint labelling, and update quality systems, is worth considerably more than one conducted in a panic in the first quarter of 2027.

A clear pattern is emerging across industry commentary and readiness surveys. Businesses that already trade with the EU are generally more likely to be aware of the implications, even if they have not yet started the detail work. The businesses that sell exclusively in the UK market appear to be at an earlier stage of understanding the implications. That gap in awareness is the real risk. The regulatory change itself is manageable. Discovering it six months too late is not.

For businesses across the food and beverage sector, the practical next steps are to review the GOV.UK legislation-in-scope list, sign up for Defra’s SPS readiness email alerts, and engage with trade bodies such as the FDF for sector-specific updates. For those that want to talk through what the SPS agreement means for their product range and compliance position, Ballards’ food and beverage team can help.

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This article has been prepared for information purposes only. Formal professional advice is strongly recommended before making decisions on the topics discussed in this release. No responsibility for any loss to any person acting, or not acting, as a result of this release can be accepted by us, or any person affiliated with us.