By Basant El-Faramawy
The European Union and the United Kingdom have finalized an agreement to eliminate Brexit-era checks on imports and exports of food and animal products, ranging from sausages and cheese to leather goods and flowers. The sanitary and phytosanitary (SPS) deal is expected to take effect in the first quarter of 2028, following a six-month delay caused by a change in the UK prime minister.
Deal Details and Timeline
The 200-page text, largely settled in May, will allow the vast majority of movements of animals, animal products, plants and plant products between Great Britain, the crown dependencies and the EU to occur without the certificates or controls currently required. UK goods will also be exempt from the EU's carbon border adjustment mechanism, as both sides are aligned on emissions standards.
Impact on Trade and Retailers
The agreement is seen as a boon for British food exporters, whose sales to the EU have fallen by a third since Brexit, with eggs, chicken and potato products worst affected. Smaller UK retailers such as delicatessens will be able to resume buying smaller batches of cheese and wines, a practice made impossible by the cost of checks introduced in 2022.
Northern Ireland Reaction
Unionist opinion in Northern Ireland is divided. Democratic Unionist Party leader Gavin Robinson said the deal does not go far enough and reflects a "lack of ambition" by the government. The DUP opposed the Windsor Framework because it cemented SPS checks on goods moving from Great Britain to Northern Ireland. Ulster Unionist Party spokesperson Steve Aiken offered a cautious welcome, noting that checks on most agricultural goods from the rest of the UK would be significantly but not completely reduced.
Electricity Market and Budget Contributions
A wider series of mini-deals expected to be sealed at a UK-EU summit on 20 November would also see Britain rejoin the EU's single electricity market, allowing UK energy companies to sell into continental grids. In return, the UK will make a financial contribution to the EU budget reflecting its level of participation in the internal market.
Implementation Delays and Regulatory Alignment
The SPS deal will not be implemented until early 2028 because the UK must "dynamically align" its food standards legislation with the EU's. While the UK has largely followed EU rules, it has diverged in areas such as fungicides used for crops in wet weather. The legislation is expected to renew debate over whether the UK is a "rule taker" rather than a "rule maker." A further six-month transition period will apply to a handful of key products, including grains grown with fungicides not yet approved in the EU.
