EU/UK Regulatory Divergence Monitoring

Since the UK left the EU, Great Britain’s regulations of seafood have diverged from those of the EU and Northern Ireland. This is now a key concern for the seafood sector and affects both exports to the EU and imports from the EU. 

For more on Northern Ireland's trading position and the Windsor Framework, visit Gov.uk:

How regulatory divergence affects UK Seafood Businesses

Impact on Exports to the EU 

Export Health Certification: To export to the EU, UK businesses need export health certification, signed by a certifying officer, confirming compliance with EU food regulations.  

Additional testing requirements:  If UK regulations for the domestic market are less strict than EU standards, exporters may need to do extra due diligence testing. For example, if the EU introduces a maximum residue limit for a contaminant that’s less stringently regulated in the UK, the exporter may be unable to place their product on the EU market without extra testing.  

EU member state specific rules: Individual EU countries may introduce rules that differ from UK legislation. This is especially true when they implement EU directives, like the Single Use Plastics Directive. UK seafood exporters must ensure compliance with each destination’s regulations.  

Impact on imports from the EU 

Divergence can also impact UK imports from the EU. If the EU introduces more permissive food safety laws than the UK's, it can mean that EU products imported into the UK are technically illegal. 

Seafish role in monitoring divergence

At Seafish, we monitor emerging UK-EU regulatory divergences and their impact on seafood trade. We then liaise with government to plan coordinated responses, discussing – for example – whether any new contaminant testing facilities are needed for exporters. Where the level of divergence is small, we consider the extent to which compliance with the UK's regulations will support compliance with the EU's. We also consider ways that the UK can liaise with the EU about the impact of divergences. Finally, we alert industry to divergences that they need to know about (e.g., through our Regulation e-alerts). 

How industry can get involved 

Contact us: If you're concerned about how a regulatory divergence might affect your business, please reach out by using the contact details below.

Subscribe to our monthly regulation e-alert: Stay informed on evolving UK-EU trade regulations.  

Join the Seafish Trade Facilitation Forum

The Forum meets four times a year to provide regular updates on our divergence monitoring findings.

To find out more about the Forum visit:

Further information 

For further information and guidance, please contact: