On a grey morning at a British port in 2022, a small family-run cheesemaker faced a choice that would have been unthinkable before 2021: either hire a specialist export health officer to certify each consignment bound for France at a cost that sometimes exceeded the value of the goods themselves, or simply stop selling to European customers. For many smaller producers, that was not a difficult choice. They stopped.
This scenario, while illustrative, captures something that trade data and policy documents have since confirmed in aggregate: the bureaucratic machinery erected after the United Kingdom left the European Union’s single market and customs union imposed real, measurable costs on businesses, and those costs fell most heavily on the smallest exporters who could not absorb them. To understand the debate over what to do about it, you first need to understand precisely what the machinery was.
What the Paperwork Actually Required
When the UK left the EU’s single market at the end of 2020, it also left a system built on mutual recognition of standards and near-frictionless movement of goods. Replacing that system required both sides to treat each other as third countries, which in practice meant a substantial documentary burden.
For food and agricultural products, the most significant requirement was the Export Health Certificate (EHC). Any consignment of animal-origin products, from fish to cheese to sausages, moving from Britain to the EU required an EHC signed by an Official Veterinarian. The certificates themselves varied by product category, but they ran to multiple pages and had to attest to specific conditions of production, processing, and transit. The Official Veterinarian had to be approved by the relevant national authority, and their time was not free. Industry groups representing food exporters reported certification costs running to several hundred pounds per consignment, sometimes more for complex mixed loads.
Plant-based products required their own set of phytosanitary certificates, attesting that goods were free from pests and diseases. These, too, required approved inspectors and carried fees. For a haulier moving mixed loads of food, a single trailer might require multiple certificates covering different product categories.
Beyond certification, the EU introduced physical checks on British goods at points of entry. Under EU rules governing imports from third countries, products of animal origin are subject to checks at designated Border Inspection Posts. These checks are not optional formalities. They involve documentary verification, identity checks, and in some cases physical examination of goods, including laboratory testing. The frequency of checks varies by product type and country of origin, but even a relatively low check rate, applied to high volumes of traffic, creates meaningful delays and costs.
Customs declarations were another layer. Inside the single market, intra-EU trade required no customs paperwork. After Brexit, every consignment crossing the UK-EU border needed a customs declaration, with associated commodity codes, valuations, and in many cases, rules-of-origin documentation to qualify for the zero-tariff rates provided under the Trade and Cooperation Agreement.
The Asymmetry That Drove Frustration
One of the central grievances that built pressure for reform was the asymmetry in how quickly each side implemented its checks. The EU applied its third-country rules to British exports from January 2021. The UK, by contrast, repeatedly delayed the introduction of equivalent checks on EU imports into Great Britain, citing concerns about supply chain disruption and import cost inflation.
The full regime of checks on EU imports into Great Britain was repeatedly pushed back through successive government decisions. A Border Target Operating Model was published in 2023, setting out a phased schedule, and checks on medium-risk EU food, animal and plant products finally began on 30 April 2024, but the delays had already generated significant political friction. British exporters argued, with some justification, that they were bearing the full cost of third-country treatment while EU exporters into the UK continued to enjoy relatively easy access. Industry bodies representing food producers and exporters made this case repeatedly to government committees.
The asymmetry also had a structural dimension. The EU is a single regulatory space with coordinated border infrastructure. The UK was building new border systems, staffing Border Control Posts, and developing IT infrastructure more or less from scratch. The combination of regulatory complexity and infrastructure gaps made the UK’s position as an exporter to the EU significantly more burdensome than importing from the EU during that transitional period.
What the Data Showed
Measuring the precise impact of trade red tape is methodologically difficult, because trade volumes are affected by exchange rates, economic conditions, and demand as well as by administrative barriers. But the direction of the evidence was consistent.
UK food and drink exports to the EU fell substantially in the period following the end of the transition period. The Food and Drink Federation, the main industry body for the sector, published figures showing that total exports to the EU were lower in 2021 and 2022 than they had been before Brexit, even as exports to non-EU markets showed more resilience. The federation attributed a significant part of this to the new trade barriers.
Research by UK in a Changing Europe, an academic research organisation, found that UK goods trade with the EU was materially lower than would have been predicted based on pre-Brexit trends, with estimates suggesting a significant reduction compared to a counterfactual. The precise figure is contested and depends on modelling assumptions, but the general finding of trade suppression was broadly consistent across independent analyses.
Smaller businesses were disproportionately affected. Large food multinationals could absorb certification costs and employ dedicated trade compliance staff. A specialist cheesemaker or a regional butcher with a modest export business often could not. Several trade bodies documented members exiting EU export markets entirely in 2021 and 2022. Once those trading relationships are broken, they are not automatically rebuilt when barriers fall.
The Veterinary Agreement: What It Would Actually Do
The political response to these pressures, which gained momentum through the mid-2020s, centred on the idea of a veterinary agreement or Sanitary and Phytosanitary (SPS) agreement between the UK and the EU. At their May 2025 summit the two sides agreed to negotiate one, and the UK government had aimed for it to take effect in mid-2027, though trade press now suggests entry into force could slip later. As of early November 2026, a draft text had reportedly been agreed in principle, but the deal had not been formally concluded, signed or brought into force. The concept drew on the model of agreements the EU has with some third countries, which reduce the burden of checks by aligning standards and creating mutual recognition arrangements.
Under a veterinary agreement of the type broadly discussed, the UK would commit to maintaining standards for food safety, animal welfare, and plant health that are equivalent or aligned to EU rules. In return, the EU would reduce or eliminate the requirement for Export Health Certificates on products moving from the UK into the EU, and would reduce the frequency or eliminate the need for physical checks at Border Inspection Posts.
The practical benefit would be significant. Removing the EHC requirement alone would eliminate a substantial per-consignment cost for food exporters. Reducing physical check rates would speed transit times and reduce the risk of spoilage for perishable goods. For sectors like Scottish seafood, where products are time-sensitive and the EU is a major market, these changes could make the difference between a viable export business and one that is not.
The political cost, depending on your view, is equally significant. A veterinary agreement requires the UK to accept ongoing EU food safety and agricultural standards, and crucially, to accept updates to those standards as the EU evolves them, without having a vote in the process that sets them. Critics argue this is precisely the kind of rule-taking that Brexit was meant to end. Supporters argue that UK food standards are already closely aligned with EU standards in practice, and that the sovereignty argument is largely theoretical when weighed against the concrete economic cost of non-alignment.
There is also a geographic complication. Any UK-EU SPS agreement would cover Great Britain, but Northern Ireland already operates under different arrangements through the Windsor Framework, which keeps Northern Ireland aligned with EU single market rules for goods. A broader SPS agreement would need to be designed carefully to avoid creating new inconsistencies within the UK’s internal market.
The Hidden Costs Beyond Food
The food sector has attracted the most attention in discussions of trade red tape, partly because the Export Health Certificate system is so tangible and its costs so direct. But the friction extended well beyond sausages and cheese.
Businesses in sectors from manufacturing to creative industries faced new requirements around rules of origin. To benefit from zero tariffs under the Trade and Cooperation Agreement, goods had to meet minimum local-content thresholds, which created paperwork burdens and in some cases required supply chain restructuring. A manufacturer using EU-sourced components had to document that sufficient value was added in the UK for the final product to qualify as British-origin for tariff purposes.
Service industries, which make up a large share of the UK economy, faced their own set of new barriers. Professionals including lawyers, architects, and engineers lost the automatic right to practice across the EU, and the mutual recognition of professional qualifications that made cross-border work straightforward effectively ended. This did not involve physical border checks or paper certificates in the same way, but it created friction that affected trade in services, which is harder to measure but no less real.
For businesses that relied on temporary movement of staff between UK and EU locations, new visa and immigration requirements added costs and delays. Musicians and touring performers faced particular difficulties with work permit requirements across multiple EU member states, and this issue received sustained public attention in the years following the end of freedom of movement.
What Scrapping the Red Tape Actually Means
The phrase “scrapping red tape” requires careful unpacking, because there is no single switch to flip. Some of the barriers are inherent in third-country status and can only be reduced through specific bilateral agreements. Others reflect the UK’s own choices about how to implement its side of border controls. Others are structural features of the Trade and Cooperation Agreement itself, which would require renegotiation to change fundamentally.
A veterinary or SPS agreement would reduce a specific and important category of barrier for food and agricultural trade. It would not address rules of origin, services, professional qualifications, or the broader architecture of third-country treatment.
There is also the question of what the EU requires in return. EU negotiators have consistently linked any deepening of trade access to governance arrangements, including the role of the European Court of Justice in overseeing the agreement and mechanisms for resolving disputes. Previous UK governments found these governance demands politically difficult to accept, and they remain contentious. Reports in early November 2026 said negotiators had agreed a draft SPS text, with a UK-EU summit in Brussels expected on 20 November to mark its conclusion, but the full text was not public and the final terms, including the role of the European Court of Justice, had yet to be confirmed.
For the businesses that stopped exporting to the EU after 2021, any reduction in barriers comes with the practical challenge of re-establishing supply chains, customer relationships, and distribution networks that took years to build and may have been permanently replaced by competitors from EU member states or from other third countries with existing preferential access to the EU market.
The red tape was always specific: pages of certificates, approved signatories, Border Inspection Post queues, commodity codes, rules-of-origin declarations. Unwinding it will be equally specific, and the political debate would benefit from matching that specificity rather than treating the issue as a single, binary choice between free trade and regulatory sovereignty.