Guidance

Food manufacturing, processing and standards: preparing your business

Updated 28 May 2026

Reason for the changes   

The UK government is negotiating an agreement with the EU on the trade and movement of plants, plant products, animals, animal products, feed and food. This is called a sanitary and phytosanitary (SPS) agreement. 

The agreement means Great Britain (England, Scotland and Wales) and Northern Ireland will apply certain rules in line with the EU. These arrangements will apply whether or not you trade directly with the EU. It is our intention that the agreement will take effect in mid-2027. 

As EU rules change in the future, rules in Great Britain will update too. The UK will contribute to the decision-shaping process on future EU rules that will also apply in Great Britain. 

Read more about the benefits in the UK-EU SPS agreement – information for businesses news story.  

As negotiations are ongoing, not all details are confirmed at this stage. This includes detailed requirements and the exact timing of when arrangements will change. We recognise that some businesses will take longer to comply and we are committed to working with them to ensure a smooth transition. Further information will be provided following the completion of negotiations. 

Why this matters 

This guidance is relevant to food businesses. It covers: 

• food business operator address requirements 
• products requiring authorisations 
• food hygiene rules 
• food products subject to rules on compositional standards 
• fresh produce subject to rules on marketing standards 
• changes to food labels 
• food contact materials

There are some differences between Great Britain and EU rules on food standards. Specifically, the changes might:

• affect what you produce and how you do this, including the standards that you have to meet  
• open up new opportunities for trade and change the way you do this 
• impact costs and processes 
• affect you through supply chains 

What this means for food manufacturing, processing and standards 

These changes mean you will need to follow relevant EU rules for food standards, safety, labelling and regulated products. This applies whether or not you trade directly with the EU. 

You may need to review your products, processes and operations to ensure they meet updated EU requirements. This includes checking whether existing products, ingredients and production methods remain compliant. 

You may be affected in several areas, including: 

• the authorisation of regulated food and feed products, including additives, flavourings and novel foods 
• food hygiene and safety requirements, including contaminants and microbiological criteria 
• compositional standards for certain food products 
• food labelling requirements, including mandatory information and product descriptions 
• food contact materials and packaging requirements 

If your products rely on authorisations that currently apply in Great Britain, you may need to check whether these continue under EU rules and whether any changes to products or processes are required.  

You should also consider how changes may affect your supply chains, including sourcing of ingredients, manufacturing processes and how products are placed on the market. 

What businesses should know at this stage 

Organisations and businesses, including food manufacturers and processors, are encouraged to continue engaging with the process to be ready by mid-2027. You can do this by keeping informed and opening conversations with your relevant trade body or industry association. 

At this stage, you are not expected to make detailed changes. You should consider the changes to requirements and how they could affect your business. The government will provide more detail in summer 2026, including next steps.    

What we know now (and what will be confirmed later) 

As negotiations with the EU are ongoing, not all of the details are confirmed at this stage. This information outlines what is known now to help you start planning, with further detail to follow later this year.   

Business addresses 

Under the agreement, it is expected that you will be able to use a UK or EU food business operator address when marketing food for the Great Britain, Northern Ireland or EU markets. This simplifies the current rules, where food marketed in Great Britain requires a UK food business operator address, and food destined for the EU or Northern Ireland requires an EU or Northern Ireland address. 

Regulated food and feed products subject to pre-market authorisation 

If you produce or use regulated products 

Under the SPS agreement, Great British food and feed authorisations will cease to apply, and EU authorisations will apply in Great Britain in their place. This includes the following regulated products and processes: 

• extraction solvents
• feed additives
• feed for particular nutritional purposes
• feed detoxification processes
• feed materials
• flavourings
• food contact materials
• food additives
• food enzymes
• genetically modified organisms as food and feed
• novel foods
• smoke flavourings

Food and feed authorisations in Great Britain and the EU have diverged since EU Exit, in terms of modification of existing authorisations, revocations and new authorisations made. For example, titanium dioxide is no longer authorised as a food additive in the EU and there has been a reduction in the permitted levels of nitrites and nitrates in EU authorisations.  

You need to check the following resources to determine whether you need to reformulate your products or change products you use to comply with EU rules under the SPS agreement, noting that there may be further changes between now and when the agreement is in place: 

• feed additives, food additives, food contact materials, food flavourings, genetically modified organisms as food and feed, novel foods and smoke flavourings – check the European Commission’s food and feed information portal, which includes links to most of the EU lists of authorised regulated products, such as the community register of GM food and feed 
• extraction solvents – check the EU list of authorised extraction solvents 
• feed materials and feed for particular nutritional purposes – check the catalogue of feed materials, the register of feed materials and list of intended uses of feed for particular nutritional purposes 

Making marketing authorisation applications 

The EU’s requirements have remained consistent with the UK’s standards and will continue to ensure food and feed is safe before it reaches consumers. Pre-market authorisation will continue to ensure safety for consumers, consistency and quality across the market and trust in the food system. 

Businesses making market authorisation applications to the EU from mid-2027 will need to follow the EU process and guidance for the relevant regulated product type. For example, to make an application for the market authorisation of a food additive, or to modify an existing EU food additive authorisation, businesses will need to familiarise themselves with the EU’s food additive guidance.   

All businesses will need to follow the updated transparency rules in the EU’s general food law. This means you will be required to proactively disclose and notify European Food Safety Authority (EFSA) of commissioned studies. EFSA provided a Q&A update in 2023 to clarify some of the updated rules, which businesses will need to review. 

If you sell or produce novel foods 

Great British novel food authorisations will cease to apply, and any data protection periods and associated market exclusivity connected with that authorisation will no longer apply. You will need to check the EU novel food authorisation status and any associated exclusivity provisions in the EU list of novel foods for the products you have an interest in so that you can ensure compliance. 

Some novel foods such as edible insects are managed differently in Great Britain and the EU. As a result, some products will need to be reformulated or withdrawn from the Great British market when Great British authorisations are withdrawn under the SPS agreement from mid-2027. Businesses with an interest in these products will need to check: 

• the European Commission’s information page on novel foods 
• the EU’s edible insect Q&A publication 

If you use, produce or process food contact materials  

Food manufacturers, processors and packaging manufacturers will need to check the recent technical changes made to Regulation 2023/2006 to see if the updates to good manufacturing practice requirements will require changes to their business operations under the SPS agreement. The EU is changing things currently; we will let you know more information when we have it. 

Since EU Exit, the EU has introduced changes to authorisation rules for some food contact materials. Businesses will need to familiarise themselves with any EU authorisations and changes relevant to their products or processes. For example (non-exhaustive list):  

• plastic materials and articles in contact with food – there have been updates to the EU list of authorised substances, new rules for natural substances, labelling changes and updates to testing conditions that businesses will need to align with 
• recycled plastics – Regulation 282/2008 has been replaced with Regulation 2022/1616, which sets rules for recycled plastic materials and articles intended for food contact, introduces authorisation of recycling processes and introduces monitoring requirements, so businesses wishing to place on the market, or process, recycled plastics will need to align with these rules
• bisphenol A (BPA) – Regulation 2024/3190 prohibits the use of BPA (and its salts) in food contact materials, so businesses need to start reformulating their products or changing their processes to remove BPA to ensure compliance with EU rules under the SPS agreement
• active and intelligent materials and articles intended to come into contact with food – the use of the ‘do not eat’ logo will become mandatory under EU rules. If businesses do not currently use this logo on their products, changes will be required to ensure compliance with EU rules under the SPS agreement

Food hygiene and contaminants 

You will need to check EU hygiene rules for foods of animal origin, as some rules have changed in the EU since EU Exit. Businesses will need to ensure compliance with these rules under the SPS agreement. Amendments include extending the ‘sell-by’ date for eggs, and some new requirements, such as in the areas of temperature control and dry ageing of meat. 

Ready-to-eat (RTE) food producers will need to comply with new EU food safety criteria for Listeria monocytogenes. Businesses will want to review both the FSA’s updated Listeria information and the EU’s updated Listeria guidance to see if they need to make any changes. Required changes may include re-labelling products or changing use-by dates.  

There will be new, additional and revised maximum levels for contaminants such as per- and polyfluoroalkyl substances (PFAS), heavy metals (for example, lead and cadmium), mycotoxins and plant toxins in various foods. All food and feed businesses will need to ensure compliance with the levels set out in Regulation 2023/915. 

The UK government has made clear that some accommodations to EU law will be required to account for Great British specific conditions, for example mycotoxin levels in oats. These are subject to ongoing discussions with the EU.   

Official controls on products of animal origin intended for animal consumption apply to game handling establishments in the EU. Game handling establishments in Great Britain will need to check these rules to determine whether operational changes will be required.  

Foods subject to rules on compositional standards 

It’s expected that businesses will be able to choose to make changes under some of the new rules. For example: 

• jams and jellies: permitting concentrated fruit juice as an ingredient in jam 
• fruit juices: market new reduced-sugar fruit juices categories and use sunflower seed protein to clarify fruit juices
• preserved milks: apply treatments that reduce lactose content in dehydrated preserved milks and rebrand as evaporated or condensed milk, adjusting minimum level for fat in evaporated milk as necessary

New rules will mean some businesses need to change the composition of their products if they wish to continue marketing these products under specific (reserved) terms. These include: 

• jams, jellies and marmalades: increases to the minimum amount of fruit required per 1,000g of finished product in jam, extra jam and jelly and extra jelly (minimums vary according to fruit species and are category dependent) as per Directive 2024/1438 
• reduced sugar jams, jellies and marmalades: the ‘reduced sugar’ provision in domestic rules (requiring a soluble dry matter content of not less than 25% and not more than 50%) will be removed, and reduced sugar, jellies and marmalades will need to meet the reduced sugar definition of a minimum of 30% less sugar than a full sugar product as set out in Regulation 1924/2006  
• coconut juice and coconut water: minimum Brix level of 4.5 (sugar content) 
• fruit nectars: new upper limits for honey or sugar included in fruit nectars – depending on fruit source, this corresponds to: 
  • 20% of finished product for fruit nectars when made from fruits with acidic juices unpalatable in the natural state (Part I Annex IV of Directive 2001/112)  
  • 15% when made from low-acid, pulpy or highly flavoured fruits with juice unpalatable in the natural state (Part II Annex IV of Directive 2001/112)  
  • 10% for fruits with juice palatable in the natural state (Part III Annex IV of Directive 2001/112)  
• olive oil blends: only extra virgin olive oil, virgin olive oil, olive oil composed of refined olive oils and virgin olive oils, or olive-pomace oil may be part of blends of olive oil

When businesses change the composition of their products, or adjust their practices, they may need also to change their labels to ensure they remain accurate and compliant with food labelling rules. In addition to this, there will be some changes to the rules on how these types of food products should be labelled, even if no changes are made to the product itself, and these are set out in the food labelling section. 

Bottled waters – alignment with Directive 2009/54/EC 

Domestically produced natural mineral waters that have been granted domestic recognition would be able to be marketed on the EU single market without having to seek additional recognition from an EU member state.    

This will also be the case for third country waters recognised in Great Britain – they too can be sold in the EU without additional recognition from the EU.   

Likewise, EU-recognised natural mineral waters will be recognised here in Great Britain without additional process.   

For spring waters, only the below treatments will be permitted, with specific rules attached to each treatment:   

• filtration or decanting 
• removal of free carbon dioxide 
• adding carbon dioxide to produce carbonated or sparkling water 
• ozone-enriched air oxidation technique  
• activated alumina 

This means that UV treatment will no longer be permitted. 

Fresh produce and hops subject to rules on marketing standards 

It’s expected that businesses will be able to choose to make changes under some of the new rules. For example: 

• mixes of fruit and vegetables: will be able to be marketed up to a weight of 10kg (previously it was 5kg)
• bananas: relaxation around how they can be presented – minimum number of fingers in a cluster of bananas will be removed 
• hops: the maximum weight limit will increase for small packages of hops and hops products for sale to private individuals for their own use which are exempt from certification requirements 
• poultry meat: water content testing can now only be done via the chemical method rather than by drip testing  
• new poultry cuts are now defined in marketing standards: bone-in thigh with a portion of the back, inner fillet, feet, paws, neck, head, supreme, wishbone, scapula
• the requirement to display whether the poultry meat is class A or class B as well as the recommended storage temperature on accompanying commercial documents has been removed, however, the definitions for class A and class B are expected to remain – this does not remove or change existing temperature requirements on handling fresh or frozen poultry meat

New rules will mean some businesses may need to make changes to marketing: 

• certain citrus fruits (limes, grapefruits, pomelo and shaddock) and new apple varieties are expected to be brought into scope of specific marketing standards for the first time 
• shell eggs:
  • quality characteristic requirements for class A eggs in change from no foreign smells to no “unintended” foreign smells, to accommodate aromatised eggs 
  • new on-farm marking rules in Article 8(1) of 2023/2465 mean eggs will be marked with the producer code before leaving the production site 
  • Article 8(2) of 2023/2465 sets out a requirement that, where a destination member state exempts a supplier from marking rules, consignments must be accompanied by a copy of the delivery contract

Changes to food labels 

The main food labelling rules (under the EU’s Food Information to Consumers Regulation 1169/2011) have changed very little since the UK’s exit from the EU. The fundamental rule will remain that food information must not be misleading. However, changes to sector specific rules such as food compositional and marketing standards rules may require information on food labels to be changed.

Changes are not expected to the compulsory labelling indications for fresh and frozen beef. This means that in respect of Great Britain, we expect that the country indications for birth, raising, slaughter and cutting will continue to be ‘United Kingdom’.

It’s expected that businesses will be able to choose to make changes under some of the new rules to their labels. For example: 

• allergen labelling: high purity behenic acid derived from mustard seeds is exempt from mandatory mustard allergen labelling in the EU, emulsifiers such as E 470a, E 471 and E 477 made from behenic acid will no longer require the word mustard to be highlighted or listed in the allergen declaration
• food business operator address: a UK or an EU food business operator address should be acceptable for food sold in either the UK or the EU and so you may choose to change the food business operator address on your label – Northern Ireland businesses will be able to continue to use an address in Northern Ireland, the EU and Great Britain
• fruit juice: you can choose to make the statement ‘fruit juices contain only naturally occurring sugars’ 
• coconut water or juice: you will be able to use the term ‘coconut water’ interchangeably with ‘coconut juice’ 
• jams, jellies and marmalade: you will no longer need to label the sugar content as ‘total sugar content [number] g per 100 g’ and instead provide sugar information as part of the nutritional information panel 

New rules will mean some businesses may need to make changes to labels even if the food product itself does not need to change. These include the following: 

Restrictions on what can be included on the label: 

• fresh fruit and vegetables: restrictions on additional terms that suggest superior quality, or any descriptor of quality not specified in the marketing requirement set out in Annex I of Delegated Regulation 2023/2429
• olive oils: the harvesting year will be permitted only on extra virgin olive oil and virgin olive oil; olive oil legal names will not be permitted where other food stuffs are added to extra virgin olive oil, virgin olive oil, olive oil composed of refined olive oils and virgin olive oils, or olive-pomace oil
• origin labelling: for mixed fruit and vegetables, minced meat, blended olive oils and any food providing information about the origin of the primary ingredient, the use of “non-UK” to describe origin will not be permitted, this will be replaced with the option to provide origin information using the terms “EU” and “non-EU”

New mandatory information requirements: 

• ID marks applied to products of animal origin including meat, dairy, fish and egg products: you may need to change the form of the ID mark: under EU rules (Regulation 853/2004), establishments within the EU must use the EU suffix
• marmalades: citrus spreads marketed as marmalade will need to be labelled as ‘citrus marmalade’ or refer to the name of the citrus fruit for example, ’orange marmalade’ or the number of fruits used 
• prepacked fruit and vegetables: the net weight will be required as per Article 7 of Regulation 2023/2429 
• blended honeys: the countries of origin in descending order of contribution with percentages per country contribution must be provided
• nuts (both in-shell and kernels, and their mixtures), dried fruits, mushrooms, capers, saffron and ripened bananas: country of origin labelling required 
• potatoes from Lebanon: additional origin and producer information required

Changes to nutrition-related labelling composition and standards rules 

Businesses will need to comply with EU rules on nutrition-related labelling, composition and standards (NLCS), which cover: 

• nutrition labelling on all food (see also section on food labelling) 
• nutrition and health claims 
• food supplements 
• fortified food 
• food for specific groups (including infants and young children, food for special medical purposes, and total diet replacement for weight control)

Since EU Exit, the main changes the EU has introduced relate to regulations for total diet replacement for weight control products. In 2022, Commission Delegated Regulation (EU) 2017/1798 came into force, which introduced new compositional, labelling and marketing requirements for food business operators. These include:  

• compositional changes including a requirement for higher levels of protein in products – businesses may need to reformulate products  
• prohibition of nutrition and health claims on these products 
• the introduction of a requirement to notify competent authorities when placing TDR products on the market

The EU has also restricted and prohibited certain substances in food and food supplements. This is set out in the annexes of Regulation 1925/2006 on the addition of vitamins, minerals and of certain other substances to food.   

Additional changes to NLCS legislation are optional for businesses. For example, changes that allow: 

• different forms of vitamins and minerals to be included in specific foods 
• additional protein hydrolysates (protein hydrolysed into its component products including amino acids and peptides) to be used in infant formula

Composites 

For information relating to composite products, please see the importing and exporting section below. 

Importing and exporting 

The new SPS agreement is relevant to all businesses and organisations involved in importing and exporting SPS goods between the UK, EU and the rest of the world. 

For trade between Great Britain and the EU, the SPS agreement will reduce the requirements for routine SPS documentation and controls. The requirements for export health certificates, phytosanitary certificates and routine border checks for most agrifood goods will be removed. Alignment with EU rules will mean there will be alignment with the EU’s approach to checks on rest of world SPS trade. Requirements for trade with countries outside the EU will also continue to apply, in line with international rules. 

Import rules for composite products from non-EU countries will change. A composite product is one that contains processed products of animal origin and a plant product used as a main ingredient, not just for flavouring or to aid processing. For example, a lasagne or cream liqueur. 

Composite products imported into Great Britain will need an export health certificate if they contain meat, or need to be transported in a chilled or frozen state (meaning not shelf-stable). 

Composite products will require a new ‘private attestation’ document, signed by the importer or import agent in Great Britain, if they are shelf-stable or contain no meat.  

When one is needed, the type of EHC required may vary. For example, there are specific rules for composites where the only POAO component is honey, gelatine or snails. You do not need an EHC at all if the only meat component in a composite is gelatine, collagen or certain highly refined products. 

Both groups will need to enter Great Britain via a suitably approved border control post and will be subject to border checks.  

Certain shelf-stable composite products that do not contain meat may be exempt from official controls at border control posts, provided they meet specific requirements set out in EU legislation (including labelling, packaging and heat-treatment conditions). This exemption applies only to products listed in Regulation (EU) 2021/630 (as amended), such as certain confectionery, cereal-based products, pasta and breads. 

Special considerations are required for food supplements under this exemption, owing to the particular uses of plant materials in these products. 

Customs controls will remain. 

Great Britain to Northern Ireland movements  

Under the SPS agreement, most agrifood goods will not need routine SPS certificates, checks and paperwork when moving from Great Britain to Northern Ireland. 

This will mean export health certificates and phytosanitary certificates, and the checks and controls associated with them, will no longer be required. 

This will apply to all products that can be moved into the EU, which will include all food for processing, many retail products and, for example, plants for planting, seeds, and used agricultural and forestry machinery. The final restrictions on the movement of certain tree species will disappear. 

The Windsor Framework will continue to apply, addressing Northern Ireland’s unique circumstances and safeguarding the Good Friday Agreement. This facilitates Northern Ireland’s dual market access to both the UK internal market and the EU single market. 

In practice, the movement schemes set up under the Windsor Framework should no longer be needed, other than potentially for a limited number of goods not covered by the agreement. The Northern Ireland plant health label (NIPHL) scheme will not be needed at all. 

Early considerations for your business 

To prepare for the UK-EU SPS agreement, you can now take the following steps: 

• sign up for Defra email alerts and the SPS readiness mailing list to receive the latest updates 
• check whether the SPS agreement is likely to apply to your business, especially if you produce, handle, move or trade animals, animal products, plants, plant products, food or feed – check how to prepare your business 
• review your current supply chains and movements (including domestic movements and movements from Great Britain to Northern Ireland) to understand where SPS requirements may apply 
• consider where your business currently follows EU rules and where you may have diverged since EU Exit 
• speak to relevant partners (for example suppliers, customers, hauliers, vets or certification bodies) about potential future changes 
• check with trusted sector organisations or trade bodies for any sector specific advice and updates 

Exceptions 

The EU has accepted there will need to be areas where the UK will retain its own rules, as set out in the May 2025 Common Understanding. Details of these are subject to the ongoing negotiation.  

The government has been clear about the importance of being able to: 

• set high animal welfare standards 
• support public health 
• support the use of new and innovative technologies 

Further information will be provided following the completion of the negotiations.  

What happens next 

It is our intention that the agreement will take effect in mid-2027. Some detailed requirements and exact timings of when arrangements will change are still being finalised as part of ongoing negotiations.  

Defra will continue to work with the sector to help shape future communications, guidance and support as further detail becomes available. We have set up an SPS Readiness Business Advisory Council, which is now meeting regularly. The council includes major trade associations and businesses.   

The following timeline sets out the expected stages for introducing the SPS agreement and when further information will be published: 

• summer 2026 – further details on upcoming changes announced, including on any exceptions and transition periods
• autumn 2026 – detailed guidance and support, including checklists and practical tools, made available 
• mid-2027 – agreement takes effect (subject to negotiations) 

Further information will be provided following the completion of negotiations. 

Stay informed 

We will continue to publish updates as further detail is confirmed. To keep up to date, you can: 

• sign up for Defra email alerts and the SPS readiness mailing list
• engage with your trade body or industry association for sector-specific updates, where relevant 

You can also get additional support from other government agencies if you are a small or medium-sized enterprise (SME), contact:  

• Department for Business and Trade: Ask our export support team at the Department for Business and Trade a question
• Food Standards Agency: Regulated products application guidance