UK-EU SPS Framework: Is the Era of Dual UK-EU Novel Food Notifications Coming to an End?

Since the UK’s withdrawal from the EU in 2021, food substances that have obtained EU marketing authorization have been required to undergo additional UK specific notifications to enter the UK market (for example, novel foods already approved in the EU cannot enter the UK market in compliance without resubmitting a notification to UK authorities) . However, in May 2025, the UK government reached an agreement with the EU to advance a new Sanitary and Phytosanitary (SPS) Agreement (hereinafter referred to as the “UK-EU SPS Agreement”). The agreement covers the trade, production, and transport of animals, plants, and related products; food and feed safety; pesticide regulation; and more, aiming to streamline the flow of goods between the UK and the EU. It is scheduled to officially enter into force in mid-2027.

Given that we are currently in a transitional phase, will businesses still need to submit declarations to both the UK and the EU in 2026?

Background: From “Decoupling” to “Realignment”

According to the latest update released by the UK Department for Environment, Food and Rural Affairs (DEFRA) in early March 2026, the UK and the EU have reached a deep consensus on the SPS Agreement and are fully advancing the “dynamic alignment” of regulations. In the food and feed sector, the food, feed, and beverage industries may face adjustments to hygiene codes, food legislation, additives, maximum residue limits for pesticides, marketing standards, labeling, and food contact materials.

DEFRA will begin providing detailed transition guidance to the industry starting in May 2026.

Direction of Adjustments: EU-Centric Approach

The UK Food Standards Agency (FSA) issued a notice in early March 2026 regarding the upcoming regulatory changes.

Key changes potentially resulting from the UK-EU SPS Agreement are summarized as follows:

1. Only products already authorized for marketing in the EU may be placed on the UK market;

2. UK marketing authorizations will no longer apply;

3. Before the agreement takes effect, it is unlikely that the large number of marketing authorization applications currently submitted to the UK will all be finalized.

Currently, UK regulations remain in effect; if further transition information is released in the future, the authorities will announce it simultaneously.

At this stage, if companies are considering submitting UK food substance notifications (novel foods, food additives, food enzymes, etc.), the FSA recommends that companies focus on:

• Potential Impact on Timelines

CIRS Analysis (using Novel Foods as an example): For novel food applications submitted to the UK, the timeline from acceptance to final approval typically ranges from 18 to 24 months. If an application is submitted to the UK now (early 2026), the UK-EU SPS Agreement may have already entered into force during the review period. At that point, the independent UK approval pathway will become redundant.

• Whether to Submit an EU Application

CIRS Analysis (using novel foods as an example): Two slightly different application dossiers would need to be prepared, and companies would have to simultaneously address regulatory review and modification requests from both EFSA and the FSA. Since the two systems will eventually merge into one, the current time and effort invested in duplicating these efforts is disproportionate to the benefits.

• Specific Product Requirements

CIRS Analysis (using novel foods as an example): Although future trends indicate that the UK and EU will align their regulations, if a UK application has already entered the late stages of risk assessment, it is advisable to see it through to completion in order to secure market share ahead of the agreement’s entry into force in 2027. Additionally, for the very few special substances that are highly controversial in the EU but may receive more lenient approval in the UK (such as cannabis extracts (CBD) or cell culture products), these can be handled on a case-by-case basis.

CIRS’s Perspective

The global compliance landscape is rapidly evolving. Against the backdrop of regulatory realignment between the UK and the EU, simplification and mutual recognition will become the dominant themes. Companies should promptly optimize the allocation of compliance resources to avoid wasting unnecessary costs associated with market entry during this period of policy benefits.

With the exception of special substances, CIRS recommends that food ingredient companies prioritize EU notifications to ensure dossier quality aligns with the latest EU guidance. Once the UK-EU SPS Agreement takes effect, EU marketing authorizations will serve as the basis for market access in both the UK and the EU.

Companies that have already submitted UK notifications should pay close attention to the transitional guidance details that DEFRA plans to release in May 2026. CIRS will continue to monitor policy developments in both the UK and the EU.

About CIRS Food Division

Established in 2012, the Food Business Division of CIRS Group has helped over 1,000 food companies globally in achieving one-stop compliance solutions. CIRS offers a full range of regulatory services, including but not limited to China novel food applications, synthetic biology-derived foods, US GRAS notice, EU novel food application, health food registration, and food for special medical purposes (FSMP).

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.