Faced with low levels of economic growth, global conflict, and difficult international politics, the UK government wants to strengthen its relationships with reliable allies. Including the EU. The UK and EU are now negotiating a closer trading relationship. As part of this, the UK needs to negotiate a new Sanitary and Phytosanitary (SPS) agreement with the EU. SPS covers plant and animal health and welfare regulations. These are directly relevant to you, our members, as this applies to all products and not just those for export to the EU. These negotiations are ongoing and continuing quickly.
Overall, we expect the agreement will be a net positive for Scottish farming. With more trade meaning economic growth. But full alignment on plant and animal health regulations could also pose some threats. We are working on your behalf to highlight these threats to the UK Government. Asking that they are considered in the negotiations, to protect Scottish agricultural businesses, and by extension food and drink production.
Defra is currently carrying out a consultation, asking about the potential challenges that full regulatory alignment could pose to agriculture. We are engaging with you, our members, through our commodity committees, to inform our response to this consultation.
Our draft response
We have drafted a response, based on feedback from our Presidential team and our commodity committees (livestock, milk, pigs, poultry, combinable crops, potatoes, and horticulture). A summary of this draft response is below. We would value further input from you, our members, on our response. Please get in touch with your local NFUS representatives with feedback.
We can’t respond to the full consultation. Many questions relate to individual businesses. Which is why we are urging farmers and crofters to also respond to the consultation, to communicate the challenges full alignment with EU regulations could pose.
Pesticides
A “cliff-edge” move to full alignment on pesticide regulations would be massively disruptive.
We are asking for a lengthy transition period to use up existing stocks. We are also asking that current UK authorisations remain in place until they expire.
Mycotoxins
The EU has different mycotoxin limit regulations for cereals used for food processing. Sudden regulatory alignment could potentially mean oats and other cereals used for food processing would exceed these limits.
We are asking for a transition period to figure out how to grow and store cereals to minimise mycotoxin levels to those required in the EU regulations. We are also asking for a technical adaptation to the EU regulations that reflect Scotland’s unique growing conditions.
Antimicrobials
EU regulations require that only individual animals, and not groups, can be preventatively treated with antibiotics. This could limit veterinary options for treatments where there is a known risk of infection.
We are asking that, given the UK’s evidenced exceptional track record in reducing antibiotic use, we want our vets to retain the ability to prescribe antibiotics to groups of animals where there is evidence the treatment is necessary.
Cattle identification
Uncertainty over whether UHF-EID will be permitted under EU regulations risks losing a modern, industry-driven technology that significantly improves traceability, animal welfare, health and safety, and livestock management.
We are asking that, given EU regulations are silent on the use of technology for livestock identification, the EU accepts the principle that two visible tags are the only legal requirement for livestock identification. And that Scotland can proceed with its commitment to rolling out UHF-EID.
Bovine Tuberculosis (bTB)
Dynamic alignment with EU bTB rules could impose lengthier restrictions on infected herds working to regain their herd free status.
We are asking that given Scotland’s official TB-free status, these restrictions are unnecessary and should not apply.
Seed potatoes
If seed potato export issues are addressed through an SPS Agreement rather than the EU-exit Trade and Co-operation Agreement, there is a risk of new PCN biosecurity measures being imposed on growers.
We are asking that the seed potato export ban is resolved through the Trade and Co-operation Agreement, and not through the SPS Agreement.
Biocides
The loss of key biocides, including rodenticides and preservatives, would challenge farm operations by affecting vermin control, crop storage, and livestock management, while increasing costs.
We are asking for a transition period to use up existing stocks and enable products authorised in the EU to be approved for use in Great Britain. Current UK authorisations should remain in place until they expire.
Precision breeding
We are strongly in favour of precision bred crop varieties being made available in Scotland. We believe these varieties are essential to adapt to climate change and extreme weather. We welcome the EU’s agreement to establish a legal framework for crop varieties bred with New Genomic Techniques. We see future alignment on this as a great opportunity for Scottish farmers.
We are asking for UK precision breeding regulations to be exempt from dynamic alignment until regulations permitting the use of precision bred crop varieties are in place in the EU.
Your voice matters. As a member-led organisation we exist to represent your interests. Please
share your feedback and practical insights to help shape a response that truly reflects Scottish agriculture.