The UK–EU SPS agreement is not in force yet: in May 2025 only the intention to conclude one was announced, and the UK government cites mid-2027 as its target for entry into force. Until then, Polish food exporters follow the current BTOM requirements: EHC, IPAFFS pre-notification, ENS and the Common User Charge.
Contents
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 — the UK government's stated intention on gov.uk)
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.
| Element | In force since | Requirement |
|---|---|---|
| Export Health Certificate (EHC) | 31 January 2024 | For medium-risk animal products from the EU to GB |
| Documentary/identity/physical checks | 30 April 2024 | For medium/high-risk animal products, plants and HRFNAO |
| Common User Charge (CUC) | 30 April 2024 | A fee for SPS checks at government BCPs |
| IPAFFS | Ongoing | Pre-notification for importing high-risk animal products and food into GB |
| ENS / Safety & Security GB | 31 January 2025 | Mandatory declaration for imports from the EU into GB |
The EHC is issued by an official veterinarian/inspector; according to the UK government, an EHC can cost up to £200 per consignment — one of the main burdens the SPS agreement is ultimately intended to remove.
Common User Charge — import rates (Sevington BCP for Dover/Eurotunnel, per gov.uk; Defra may adjust them after its annual review)
| Goods category | Rate per commodity line |
|---|---|
| Animal products — low risk | £10 |
| Animal products — medium/high risk | £29 |
| Plants — medium risk A / high risk | £29 |
| HRFNAO | £29 |
| Plants — medium risk B / low risk | no charge |
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
- The easement is temporary and has been extended pending implementation of the SPS agreement — check the current end date on gov.uk / the Plant Health Portal before shipping
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:
- Obtain a GB EORI number (free, via gov.uk)
- Issue an EHC for animal/high-risk products
- Make sure the IPAFFS pre-notification is made before the consignment arrives in GB (usually lodged by the importer on the UK side, based on data and the certificate from the exporter)
- Submit an ENS S&S GB declaration (mandatory since 31 January 2025)
- Factor in the Common User Charge (£29/line for most medium/high-risk products)
- Handle declarations through CDS (Customs Declaration Service)
How we can help
Agencja Celna at agencjacelna.uk handles PL–UK export and import clearance: ENS S&S GB declarations and full CDS handling, and for food we help you organise the EHC and IPAFFS requirements. Practical detail is in exporting food to the UK – EHC, IPAFFS and SPS checks, BTOM after Brexit – what to check before moving goods and when goods need IPAFFS. 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
Frequently asked questions
Is the SPS agreement already in force?
No. In May 2025 the intention to conclude an agreement and the "Common Understanding" were announced. The UK government says on gov.uk that it intends the agreement to take effect in mid-2027, but that date is not confirmed in legislation.
Do I still need to issue an EHC?
Yes, until the agreement is implemented. The EHC for medium-risk animal products from the EU has been required since 31 January 2024, and according to the UK government it can cost up to £200 per consignment.
What is the Common User Charge?
A UK fee for SPS checks at the government border control post (BCP) at Sevington, charged on imports through Dover and Eurotunnel. It is £29 per commodity line for medium- and high-risk animal products, HRFNAO and medium risk A and high-risk plants, capped at 5 lines per CHED (£145).
Will the SPS agreement remove all border checks?
The announced plan is to remove Export Health Certificates and routine border checks for products covered by the agreement, including dairy, fish, eggs and red meat moving from the EU to GB. The details are still being negotiated, and the current BTOM requirements apply until implementation.
Where can I follow the negotiations and guidance?
On gov.uk – the page "UK-EU SPS Agreement – Information for Businesses" run by Defra. Also check the current requirements for your category of goods before every shipment.
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