CFA is keeping its members abreast of the latest developments in activity following up on the 19 May 2025 UK-EU High Level Summit’s announcement on forthcoming negotiation of an SPS Agreement between the UK and EU.
Karin Goodburn chairs the SPS Certification WG, which meets weekly including with senior officials from various departments and agencies engaged in preparation for such negotiations and of further potential changes to infrastructure and systems. A summary of divergences in legislation requiring attention in the streamlining of trade has been shared with Government officials, the Lords EU Affairs and Commons EFRA Committees.
The cost of EHC completion for certain exports to the EU post-Brexit is still around £5m pcm, or about £260m since the end of the Transition Period when their completion to certify compliance with EU law came into effect. This is equivalent to the profit from over £13 billion food sales.
The Groupage Exportation Facilitation Scheme (GEFS), which is vital for the distribution of mixed loads of foods containing products of animal origin (POAO), is continuing, with strengthened requirements. The Scheme streamlines export bureaucracy on adherence to best traceability and other specified practice for entire groups of products sent as mixed loads to the island of Ireland in particular. Changes made enabling GEFS’ continuation include increased audit frequency for Scheme members, standardised Support Attestations and stronger compliance rules. Revised GEFS guidance has been issued by Government.
Meanwhile the potential for GB-wide “Not for EU” labelling for POAO remains although no legislation has yet been enacted to make it enforceable in GB. It appears to be being kept “in reserve” for potential inclusion in EU SPS agreement negotiations.
Karin Goodburn comments: “It’s worth noting that great majority of UK law relevant to EHCs is the same as that in the EU as the UK played a leading role in securing appropriate finalised EU legislation when it was an EU Member. Resolution of such incongruities would help facilitate trade, but where there is divergence and it is in favour of UK businesses this needs to be accommodated. In addition, for chilled foods to be sold on the Continent requires re-establishment of sales infrastructure, which has to be underpinned by commercial confidence in systems, and requirements becoming stable.”
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4 September 2025

