A year has passed since the last NFUS Conference and AGM, where we welcomed the First Minister’s announcement on using Ultra High Frequency (UHF) in the implementation of Bovine EID, with the Cabinet Secretary for Rural Affairs and Islands confirming this will be introduced by the end of 2026. With that only being 11 months away, we are working with the Bovine EID Industry Stakeholder Working Group to engage with Scottish Government officials on how the phased approach will be delivered and the timelines alongside it.  

Mandating the introduction of UHF EID by the end of 2026 follows a decade of lobbying from industry, showing the significance of the announcement last year. However, it hasn’t been plain sailing to get the ball rolling, so what has happened from then and now, and what is the stumbling block? 

The simple answer, is regulation. In May 2025, the UK-EU Sanitary and Phytosanitary (SPS) agreement to hold negotiations on a closer trading arrangement was announced. This means the UK Government are currently negotiating a new post-Brexit trade agreement with the European Union (EU), which aims to reduce post-Brexit agri-food trade barriers by aligning food safety, animal, and plant health standards.  

This has implications for the implementation of UHF EID. Under proposals for an EU–UK SPS agreement, GB will likely be dynamically aligned with animal traceability and identification EU legislation. The impact of dynamic alignment on the use of ultra-high frequency (UHF) electronic identification (EID) in GB is unclear, and this lack of clarity is due to different interpretations of the relevant EU regulation.   

Regulation isn’t always as clear-cut as it seems. There can be various interpretations that mean it can be hard to determine the specific impact. This has made the negotiations, and our input into them, complicated and tricky. We’ve put forward positions that will best support our members, in response to these different interpretations.  

In simple terms, EU rules do not mention UHF electronic identification (UHF-EID) for cattle, but they don't prohibit it either. The only identification method the EU requires is two matching visual ear tags on each animal. One view is that UHF-EID could still be used, as long as those visual tag requirements continue to be met in Great Britain. 

Another view is that UHF-EID cannot currently be used for cattle, not because the EU rules forbid it, but because of how “standards equivalence” is being interpreted. Under this interpretation, livestock identification would be limited to low-frequency (LF) EID only. However, it’s worth noting UHF-EID is already being used in the EU, across the pig supply chain in Denmark.  

 

We want an agreement that enables us to continue to use ultra high frequency (UHF) electronic identification (EID) in Scotland.  

We have made two asks, reflecting the different interpretations of the EU regulation.    

1. Our first is a confirmation ask, reflecting the interpretation that UHF-EID could be used in GB due to the regulation’s silence on its use.  

2. The second is a carve-out or technical adaptation ask, reflecting the alternative, standards equivalence interpretation of the EU regulation.    

We are confident we have made a very strong case to UK negotiators and hope they have taken that on board. We are regularly engaging with UK and Scottish Government, as well as politicians and relevant organisations. In particular, we have worked very closely with our colleagues in the BAB office. The main aim is to find a way forward that allows UHF EID to be implemented in Scotland within the committed timeframe.  

As mentioned, we are working closely with the Scottish Government on this, and we have asked the question if their commitment to implement UHF-EID by the end of 2026 is still achievable despite the delays. For clarity, their position is as follows: 

“The Scottish Government remains committed to supporting the Scottish cattle industry and the delivery of Bovine EID using UHF technology. 

As EU/UK SPS negotiations progress Ministers are doing all that they can to ensure that Scotland’s case for UHF EID will be recognised by our EU partners. It is important that Scotland’s leadership in developing UHF technology for livestock traceability is recognised, both domestically and internationally. Once negotiations have concluded we will look to deliver without delay. 

Concurrently, The Office for the Internal Market recently carried out a review into the potential effects on UK internal market trade from proposed legislation relating to EID.  The report was published on 29 October 2025 and concluded that the adoption of two technical standards for EID within the UK, if managed carefully, is likely to have a limited impact on the pattern and total volume of internal market trade.  Officials are working to address the recommendations within the report. 

There is no action to be taken by industry at this time regarding bovine EID.  Stakeholders will be provided information in advance of implementation of EID to allow them to prepare.” 

Aside from the SPS agreement, in June 2025 Defra announced their decision to implement Low-Frequency EID. There has been concern from some about cross border moves following DEFRAs announcement to use Low Frequency (LF), while Scotland has mandated UHF. Fundamentally UHF EID gives those who want to use technology the opportunity to get the most out of it, however if someone doesn’t, the tags will continue to be What You See Is What You Get (WYSIWYG), meaning the animal’s ID will be printed on the tag and can continue to be identified as they are today, via manual reads.  This mitigates any concern about cross-border trade.  Furthermore, we urge both DEFRA and Scottish Government to work together to ensure effective roll out of forward-looking technology. 

In conclusion, I hope the above provides some context to the situation with UHF Bovine EID implementation in Scotland, and the work we are doing to represent members interests. I appreciate bEID has been a very long time coming, and after the Scottish Governments clear commitment, we are working hard on behalf of members to ensure UHF EID is implemented for the benefit of the industry.