UK and EU Finalize Deal to Scrap Brexit Food Checks — But Not Until 2028

British food exports to the EU have collapsed by a third since 2019 — and the deal just finalized between London and Brussels is designed to fix exactly that. The EU and UK have completed a sanitary and phytosanitary (SPS) agreement removing Brexit checks on imports and exports of food and animal products, covering everything from sausages and cheese to leather goods and flowers.

Sources close to the negotiations said the 200-page text on post-Brexit food exports has "been settled and there will no further negotiation." EU ambassadors will see it at a meeting on Wednesday, which will also cover the first draft of a joint statement to be issued by Andy Burnham and EU leaders at the rescheduled EU-UK summit on 20 November.

Don't mark your calendar for relief just yet. Implementation isn't expected until the first quarter of 2028, after the change in UK prime minister pushed the second EU-UK summit back six months. Defra, which had originally told industry the deal would take effect in May next year, has now briefed industry leaders on the longer timeline. A further six-month transition will apply to a handful of key products — grains grown this year with fungicides not yet approved in the EU, for example.

What does the deal change for business?

The immediate winners are British food exporters. The National Farmers' Union said last month that EU-bound food exports have fallen by a third since Brexit, with eggs, chicken and potato products worst hit. Removing checks claws back a trade channel that's been leaking for years.

Smaller UK retailers benefit too. Delicatessens can return to buying smaller batches of cheese and wines — a practice that became impossible after 2022, when the cost of Brexit checks priced out anyone who wasn't shipping in volume. For specialty importers, that's the difference between stocking a single pallet of Bordeaux or skipping it entirely.

Northern Ireland retailers get a specific win. Under the proposed framework, they will no longer have to label products "not for the EU" — a process that big supermarket chains such as Marks & Spencer have publicly criticised.

Transport operators will lose some of the paperwork one industry leader described to the parliamentary trade select committee as "pure hell." In one case, a truck was held up for 27 days in Calais purely because it lacked the right certificates for a frozen beef cargo. That's nearly a month of a vehicle sitting idle — a cost that ultimately lands on the shipper's margin.

Why the 2028 delay?

The holdup is the UK's need to "dynamically align" British food standards legislation with the EU's. The UK has largely followed EU rules since Brexit, but it has diverged in some areas — notably fungicides used to help crops grow in British wet weather. Aligning those regimes takes legislative time, hence the stretched timeline.

That alignment clause will renew an old fight. Expect fresh controversy over whether the UK is a "rule taker" rather than a "rule maker" — a central argument of the original Brexit debate that this deal puts squarely back on the table.

What's still unresolved?

The so-called "zero text" also includes chapters on a widely expected youth experience scheme, but that piece is still being negotiated. Ambassadors will discuss an 11th-hour UK proposal on tuition fees for young Europeans, aimed at breaking a deadlock in the talks.

The sticking point is familiar: the UK has insisted EU students pay full international fees. Two weeks ago, the European Commission was concerned enough that ambassadors discussed "decoupling" the issue entirely — agreeing to negotiate it separately for another six months rather than let it sink the wider package.

The SPS deal itself was largely agreed back in May and published by the government to give food producers time to prepare. Talks between British and EU officials began in London earlier this year with the aim of stripping out much of the Brexit paperwork on both sides.

For food producers, the practical takeaway is a two-year runway: the commercial logic of exporting to the EU just improved, but the operational savings don't arrive until 2028.