A 200-page draft agreement that would commit Britain to follow EU food and farming rules as they change has been circulated to EU capitals before the full text has been made available for public and parliamentary scrutiny. The BBC reported on 3 November that the draft sanitary and phytosanitary (SPS) text is with EU governments, through their ambassadors at Coreper, ahead of the Brussels summit on 20 November. The deal is not signed; as of 9 November neither its full text nor any impact assessment had been published.
What dynamic alignment would mean
The May 2025 summit set the framework. The summit may produce or endorse an agreed text, but that would be a political step only: signature, ratification, domestic legislation and implementation are separate stages, and the European Partnership Bill, the legal mechanism for applying new EU rules, would be needed to bring the arrangements into effect. The Government’s guidance explains that Great Britain would apply certain EU rules domestically, whether or not a business trades with the EU, and that as EU rules change, British rules would update too. Britain would take part in the decision-shaping process, but, as the Agricultural Industries Confederation set out in February, through non-voting access to the committees where the rules are made, alongside a financial contribution and disputes ultimately interpreted by the Court of Justice of the European Union. The legislative vote would remain with EU member states. Asked on 29 October what payments Britain would owe, Defra confirmed financial arrangements remain under negotiation. The Food Standards Agency’s September board paper is blunter: from entry into force, all GB authorisations for regulated products such as food and feed additives would cease, businesses needing an EU authorisation instead, with only “very limited exceptions”. The Government is aiming for implementation in mid-2027, subject to negotiations; trade reporting points to early 2028. Neither date is confirmed.
The farming sums
An Andersons Centre study for CropLife UK modelled the cliff-edge case, where post-Brexit EU decisions on plant protection products simply override British ones: growers could lose more than 10 per cent of their income, up to £810 million in the first year. On farm, Alfie Jackson of the buying group AF explains the arithmetic: flufenacet, a blackgrass mainstay banned in the EU, costs £9 or £10 a hectare; the alternatives run to about £49. Products such as Miravis and Vimoy are approved in Britain but not Europe, and he reports some manufacturers have slowed or stopped UK research pipelines. This is industry-commissioned worst-case modelling; CropLife says managed alignment would mitigate most of it, and no comprehensive government impact assessment has been published.
If the agreement is concluded and implemented, relevant export health certificates could be removed and many border checks reduced, subject to the final terms and transitional arrangements. Such certificates typically cost up to £200 a consignment, and exports of sausages, shellfish and seed potatoes could resume. NFU President Tom Bradshaw, whose members send 68 per cent of agri-food exports to the EU, backs cutting border friction but insists farmers “must retain access to precision breeding technologies” and “science-based plant protection products that help protect food being grown for 29 million households”. The guidance confirms pesticide approvals and residue limits would mirror EU decisions.
Cold stores and corner shops
The British Meat Processors Association welcomes the draft, while chief executive John Powell warns against “a cliff-edge date when perfectly good, legally produced meat suddenly becomes unsellable because the rules have changed”. The Nationwide Caterers Associationtells members the deal “fundamentally rewrites domestic British food law”, so even kitchens that never export could find “certain ingredients that are currently legal in Great Britain might become prohibited”.
Then there is the bill on non-EU trade. Defra’s guidance states that inspections of certain rest-of-world imports will increase to EU levels. The Fresh Produce Consortium estimates that extra certification, inspections and fees would cost more than £300 million a year across four million tonnes of imports, half Britain’s fresh produce, and wants a long-term exemption for produce sold only here. Costs will not automatically reach shoppers, but delays shorten shelf life and squeeze smaller importers, and no net price estimate has been published.
Animal welfare: what is law, and what is at risk
Nothing in the draft removes a British protection today. Sow stalls have been banned since 1999 and conventional battery cages since 2012, though enriched cages remain lawful; the ban on live exports for slaughter was legislated after Brexit; farrowing crates, enriched cages and CO2 stunning are subjects of consultation only. The RSPCA warned on 5 November that aligning with an EU that has implemented none of these reforms could row back “hard gotten gains”: “These issues must be red lines for the Prime Minister.” The Telegraph reported the same day that negotiators have secured opt-outs preserving the puppy import rules and the live export ban, which the charity welcomed, while its wider red lines stand. Defra’s CO2 stunning consultation opened on 26 October; the EU still permits the method.
Fisheries: the price already paid
Fishing was settled separately, and painfully. At the May 2025 summit the Government extended EU fleets’ access to British waters to 2038, a deal the Scottish Fishermen’s Federation called “a horror show for Scottish fishermen, far worse than Boris Johnson’s botched Brexit agreement”. It fears scope creep: chief executive Elspeth Macdonald warned on 27 October that the veterinary agreement “must not become a back door through which elements of the Common Fisheries Policy are reintroduced”. That is a concern, not an established plan; the answer is a written assurance.
The Government’s case
Ministers argue the prize justifies the price: a government forecast of £5.1 billion a year for the UK economy by 2040, easier trade between Great Britain and Northern Ireland, and a seat shaping European rules. Andy Burnham promises to “negotiate the best deal that I can”; Kemi Badenoch calls dynamic alignment a red line that takes Britain backwards. Ministers have yet to set out how Parliament will scrutinise the final text or vote on it.
GREAT BRITISH PAC REACTION
Steve Wright, Campaign Lead for Campaign Brexit at Great British PAC, said:
“The EU have provided the text of the agreement they intend to sign to their member states, but our Government has not done the same with Parliament. The details are already out there, so what is it about the deal that is so bad, that they do not want to admit what they are signing us up to? Surely if the terms were believed to be good for the British people, then they would be shouting them from the rafters. The silence on this front is very telling – they know the British people do not support it”
Great British PAC is calling on the Government to meet four essential conditions before Britain is bound by any new agreement with Brussels:
- Full transparency before any agreement is signed. Publish the complete proposed SPS agreement, all available impact assessments and the financial contributions Britain would be expected to make. Parliament and the British public must be able to examine the terms before the Government commits the country.
- No surrender of democratic control over British laws. Guarantee meaningful parliamentary scrutiny and an explicit vote before implementation. Any mechanism requiring Britain to adopt future EU rules must be transparent, subject to parliamentary oversight and accompanied by clearly defined safeguards protecting Britain’s ability to make its own laws.
- Protect British farmers, food producers and animal welfare standards. Secure enforceable protections for British agricultural businesses, including access to essential plant protection products, precision breeding technologies and existing animal welfare safeguards. British producers must not be placed at a competitive disadvantage by regulatory changes negotiated without their consent.
- Defend British fishing waters and economic interests. Provide a binding assurance that the SPS agreement cannot be used to extend EU control over British fisheries management or reintroduce elements of the Common Fisheries Policy. Publish a credible assessment of the agreement’s costs and benefits for British businesses, food importers, consumers and coastal communities.
Britain voted to take back control of its laws, borders and economic future. Cooperation with our European neighbours must never come at the expense of democratic accountability or the right of the British people to determine their own future. If the Government believes this agreement serves Britain’s interests, it should publish the terms, explain the costs and allow Parliament to scrutinise them properly. British sovereignty is not a bargaining chip, and Great British PAC will continue to demand transparency, accountability and a fair deal for the people and industries of this country.
