UK/EU Trade Update
Background
The UK agreed with the EU in May to renegotiate the current trade deal to remove border restrictions on food imports and exports. The EU agreed to relax border controls if the UK aligned most food legislation with it. That means, before members benefit from a restriction on controls between the UK and the EU and between GB and Northern Ireland under the Windsor Framework, the UK needs to agree which legislation needs to be amended to align and ensure supply chains have implemented the changes.
These changes will only impact food movements across borders. Continuing changes to EU legislation in areas such as environment and product safety will continue to impact members trading in the EU and will apply in Northern Ireland. Alongside the renegotiated deal, the UK Government is also working on reducing the burden from these changes.
We met officials from Defra and DBT for an update on progress.
UK/EU Deal
Final negotiations on the deal will be in the Autumn. The intention is to finalise the deal by early 2026 to enable progress on aligning relevant legislation with the EU. The negotiations will cover which parts of food legislation the UK doesn’t want to align (possibly precision breeding and other biotech developments) and what the EU will require in return, including controls on imports.
Defra is continuing to map all legislation in scope and hopes to have it shortly. The BRC and others are working with them to try and prioritise the legislation changes which will be the most complex to implement to ensure it is done as quickly as possible, however we have signed an NDA which complicates discussion. Defra also said it would be holding stakeholder meetings in the Autumn to give more visibility of the changes and the process.
Defra recognises it will need a major campaign to ensure awareness across the supply chain, including SMEs and will prepare guidance as well as communications over the coming years. Defra wont confirm how long it will take to pass legislation (in all 4 UK parliaments) and ensure implementation to the EU’s satisfaction before they will relax border controls. It is likely to be 2-3 years.
Members welcomed the move to remove border controls but were concerned at the time it would take. Those with stores in Northern Ireland have been struggling to comply with the Windsor Framework and that will be compounded in the coming years as more EU environmental and product safety legislation is introduced.
EU Alignment Outside The Revised Deal
DBT is trying to support UK businesses identifying legislation which could impact supply chains, retailers operating in the EU and in Northern Ireland. It has identified legislation including CBAM, Forced Labour Regulations and EUDR amongst others. It is prioritising these based on their impact on businesses to decide what action to take.
In terms of action, the UK could choose to voluntarily align with the regulation; the new Product Regulation and Metrology Act enables the UK to do this easily through secondary legislation. It could choose not to align but provide more guidance on compliance, which it did with the General Product Safety Regulations in late 2024.
The BRC is part of an industry group working with DBT to identify priorities and distribute information. The latest report is available here
EUDR
Members were clear their biggest concern regarding EU legislation is EUDR, the deforestation regulations. These are due to come into force at the end of 2025 and will place a significant administrative burden on retailers moving products from UK to EU. However, their main concern is whether these regulations will apply in Northern Ireland.
Members were clear implementing EUDR for movements to Northern Ireland from January 2026 would significantly impact availability for consumers, as both retailers and, particularly suppliers are not ready for compliance. DBT said Ministers appreciated these concerns and the impact on Northern Ireland consumers, however, no decision has been taken yet on if and when EUDR will apply.
Low Value Imports
Members were reminded BRC was continuing to push for a quick decision from the Government to end LVI following the recent Treasury review. DBT confirmed we should get a response from the Chancellor this Autumn. The Chancellor raised it directly with CEOs at a recent BRC organised roundtable.
Next Steps
We will update members on developments with the UK/EU revised deal and alignment with EU legislation, particularly the position on EUDR. We will also give members visibility of future calls by Defra to explain the approach to alignment. We will also update as soon as we hear the response from the Chancellor on low value imports.