UK-EU Sanitary and Phytosanitary (SPS) Agreement Negotiations | Seafish

UK-EU Sanitary and Phytosanitary (SPS) Agreement Negotiations

In May 2025, the UK and EU committed to negotiate an SPS Agreement.



The relevant section of the Common Understanding can be accessed here – under the sub-heading, ‘Working towards a Common Sanitary and Phytosanitary Area’: UK-EU Summit - Common Understanding (HTML) - GOV.UK. This Agreement should, once implemented, allow movements of fish and fishery products between the UK and EU without the current requirements for export health certificates (EHCs) and routine border checks. It’s expected that the UK will, as part of the Agreement, need to align its SPS regulation to the EU’s.

Negotiations between the UK and EU are ongoing – with the UK Government expressing an ambition to conclude by early 2027, although this is not a fixed deadline. All current arrangements remain in place until further notice, but information on what businesses can do now is available here: UK-EU SPS Agreement - Information for Businesses - GOV.UK. We at Seafish will maintain close contact with Defra throughout the negotiation process to highlight the seafood industry’s priorities and concerns. We will update industry on developments through our newsletters, the Seafish Trade Facilitation Forum, and this page.

Defra publishes information on UK alignment with EU SPS legislation

In March 2026 – Defra published additional information on UK alignment with EU SPS legislation, including the legislation that’s confirmed to be in scope of alignment. Further information is available here: UK-EU SPS Agreement - Legislation in scope - GOV.UK.

In addition to publishing information about the legislation in scope of SPS alignment, Defra have published a page dedicated to advice for businesses – including a Call for Information that allows industry to share views on what support they need to help them prepare. Seafish will be responding to the Call for Information and consulting widely with industry before doing so. However, Defra have emphasised that they’re also keen to hear from individual businesses; so, we’d encourage industry stakeholders to respond to the Call for Information individually, too.

Environment, Food and Rural Affairs Committee report on the negotiations

In February 2026 – the Environment, Food and Rural Affairs Commons Select Committee published a report on the negotiations, which called for an implementation period in relation to regulatory alignment between the UK and EU. Further information is available here: Govt must seek carve outs and implementation period in EU trade deal – EFRA Committee report - Committees - UK Parliament.

Defra Stakeholder Information Forum

In November 2025, Defra convened a Stakeholder Information Forum regarding the changes. Here are the key points from that Forum:

  • The timescale for the implementation of the agreement is mid-2027.
  • As per the understanding we had already – the Agreement should remove current SPS barriers like EHCs.
  • There’ll be some limited exceptions to the principle of SPS alignment – there’s no confirmation currently of what these exceptions will be, but it’s hoped that more information will be available soon.
  • SPS negotiations will proceed on their own track – their conclusion will not depend on other aspects of the Common Understanding being successfully taken forward.
  • Where divergences have arisen since the UK’s exit from the EU (e.g., in relation to contaminant limits), Defra welcome feedback on a realistic way of addressing these – divergences will need to be examined as part of the negotiation process and there will ultimately need to be alignment. However, Defra are keen to know what stakeholders need regarding transitional arrangements. We at Seafish are in close contact with government in this respect, explaining what the seafood industry may need (e.g., additional testing to demonstrate compliance with EU contaminant limits that do not currently exist in the UK).
  • In respect of potential alignment with the EU Packaging and Packaging Waste Regulation – while this will not be covered by the SPS Agreement negotiations, it would be incorrect to assume that there are no separate discussions ongoing about this and other policy areas outside of scope (e.g., IUU regulations).
  • Defra are working on a new legislative framework in the UK that’ll underpin the SPS Agreement and emphasise the need for strong parliamentary oversight in this regard.
  • In relation to imports into the UK, the BTOM will be updated – we’ll largely need to follow the EU’s imports regime.

Presentation to Seafish Trade Facilitation Forum

In July 2025, Seafish provided our Trade Facilitation Forum members with an overview of the commitment to an SPS Agreement and what this means for them. The slide deck is available here:

Back to top