The UK–EU SPS Agreement and Food Exports: What Has Been Announced and What It Changes for Polish Companies

In May 2025, the United Kingdom and the European Union announced their intention to conclude a sanitary and phytosanitary (SPS) agreement designed to simplify trade in food, plants and products of animal origin. For Polish exporters sending goods to the UK, this could mean a substantial change to procedures, costs and logistics. This article explains what has been announced, the current legal position, and the road to implementation.

What is the UK–EU SPS agreement, and what has been announced?

An SPS agreement is an arrangement for mutual recognition of food safety standards and veterinary and phytosanitary checks. In practice, it means reducing or removing duplicate border checks for goods that meet agreed standards.

On 19 May 2025, at the UK–EU summit, the parties announced a "Common Understanding" — a statement of intent setting the direction for negotiations. This is not yet a ratified agreement or law in force — it is an announcement and a negotiating framework.

• The UK commits to dynamically aligning its SPS regulations with EU rules within the agreed scope
• Scope: animal products, plants, food, feed, pesticides and veterinary regulations
• Target entry into force in mid-2027 (a date not yet confirmed in legislation — a goal announced by the UK government)

The current position: BTOM and the SPS checks in force today

Regardless of the future agreement, food exports from Poland to the UK are currently subject to the full BTOM regime. The SPS agreement does not change this until it is implemented.

The EHC is issued by an official veterinarian/inspector; the cost can run to several hundred zloty per shipment — one of the main burdens the SPS agreement is ultimately intended to remove.

Common User Charge — current rates (Dover/Eurotunnel BCP)

The maximum charge on a single CHED is capped at 5 commodity lines (i.e. up to £145 for medium/high risk).

What is the SPS agreement planning to change?

• Removing Export Health Certificates for products covered by the agreement
• Ending routine border checks for dairy, fish, eggs and red meat moving from the EU to GB
• Free movement between GB and Northern Ireland (linked to the Windsor Framework)
• Dynamic alignment of UK regulations with the EU on SPS matters

Important caveat: the details are still being negotiated. The "mid-2027" date is a government target, not confirmed in legislation.

Temporary easements — what has already changed?

• Removal of import checks on medium-risk fruit and vegetables (including tomatoes, grapes, plums, cherries, peaches, peppers) — no CUC charges for these products
• Extension of import easements to 31 January 2027 as a transitional measure

What this means in practice for exporters from Poland

Until the agreement takes effect (mid-2027 at the earliest), when exporting food to the UK you need to:

1. Obtain a GB EORI number (free, via gov.uk)
2. Issue an EHC for animal/high-risk products
3. Pre-notify via IPAFFS before the consignment arrives in GB
4. Submit an ENS S&S GB declaration (mandatory since 31 January 2025)
5. Factor in the Common User Charge (£29/line for most medium/high-risk products)
6. Handle declarations through CDS (CHIEF was closed on 4 June 2024)

Frequently asked questions (FAQ)

Is the SPS agreement already in force? No. In May 2025 the intention and the "Common Understanding" were announced. Implementation is provisionally targeted for mid-2027 — not yet confirmed in legislation.

Do I still need to issue an EHC? Yes, until the agreement is implemented. The EHC for medium-risk animal products has been required since 31 January 2024.

What is the Common User Charge? A UK fee for SPS checks at government BCPs (mainly Dover/Eurotunnel). £29 per line for medium/high-risk products.

Where can I follow the negotiations? On gov.uk — the "UK-EU SPS Agreement — information for businesses" page.

How we can help

Agencja Celna at agencjacelna.uk handles PL–UK export and import clearance: EHC documentation, IPAFFS pre-notifications, ENS S&S GB declarations, and full CDS handling. Exporting food to the UK? Get in touch before problems arise at the border.

Sources

• UK-EU SPS Agreement — Information for Businesses, GOV.UK
• Common User Charge — rates, eligibility and invoices, GOV.UK
• Border Target Operating Model — leaflets, GOV.UK