It’s been a decade since Britain voted to leave the European Union. This decision delivered far-reaching consequences to almost every sector within the UK economy and brought with it major challenges, new opportunities, and an abundance of change.

When it comes to the world of regulatory compliance, these changes are extensive. 10 years on from the referendum, we explore how the UK has gradually sought to diverge from EU standards and where this currently leaves businesses looking to sell compliant, accurately labelled products in both UK and EU markets.

The All-New Regulatory Landscape

Brexit has completely transformed the UK’s relationship with the rest of Europe, but it’s worth noting that a lot of EU derived laws still remain in place in the UK.

For example, just under 50% of the laws covering foods in Great Britain (GB) are retained from the EU. Brexit also led to the complex Windsor Framework arrangements for Northern Ireland (NI), where EU legislation for product safety and standards continues to apply.

Many of the recent changes following Brexit have come in through passive divergence – this occurs when the EU introduces new regulations that the UK has not yet aligned its own domestic regulations with, creating friction between the two markets. This has been particularly noticeable where new barriers to trade between GB and NI have arisen through changes to EU rules.

The SPS Agreement

To counteract this passive divergence, a ‘Brexit reset’ deal was announced in May 2025. The Sanitary and Phytosanitary (SPS) Agreement should make it easier, cheaper, and more predictable for goods to move between both the UK and the EU – and between GB and NI – by dynamically aligning the UK’s food safety and information standards with those of the EU. The agreement is expected to take effect towards the end of 2027.

For some food and drink companies who sell into GB, NI, and the EU, the SPS Agreement is unlikely to bring too much change as they are continuing to align themselves with EU standards.

The hope of many is that the challenges of Brexit could be mitigated to some extent by the formation of a new regulatory relationship between the two markets, with the closer collaboration and alignment that comes with this helping to ease the burden of compliance.

Regulated Products

Currently food businesses must navigate two separate approval and registration systems for regulated foods such as additives and novel foods. This has led to increased administrative burdens for both UK businesses looking to export to NI and the EU, and European businesses trading with GB.

One example of differing food standards is that the EU has not renewed authorisation for 8 different smoke flavourings, meaning these may be unable to be used within foods sold in the EU from 2029 onwards. In Britain, no such ruling has taken place.

The UK also currently offers greater flexibility for novel foods. Since leaving the EU, the UK’s Food Standards Agency (FSA) has invested in novel food research, creating a regulatory sandbox to allow for greater exploration to streamline future regulation.

The EU has taken a much more hardline approach to novel foods through the recently proposed Biotech Act, which excludes novel foods – such as cultivated meat – from regulatory sandboxes due to ethical and cultural concerns.

Primary Production

The diversification of requirements at primary production level has also been felt within the agrifood industry.

For example, animal welfare laws have been subject to change, with the UK banning the export of live animals in 2024. Earlier this year, a proposal to ban the boiling of live crustaceans was put forward, although an earlier pledge to ban the import of foie gras has been dropped as the UK seeks to align with the EU in preparation for the SPS Agreement.

The UK has also diverged from the EU on many key environmental regulations – such as the EU’s regulations on deforestation and forest degradation (EUDR) and the Packaging and Packaging Waste Regulation (PPWR).

The control of pesticides is another area of concern, as the EU and GB maintain separate authorisation and permitted Maximum Residue Levels (MRL), creating pitfalls for businesses looking to export to the EU bloc.

The Changing Face of Product Labelling

In the years since Brexit, confusion over new rules and differing regulations is thought to have led to widespread non-compliance – for example, many imported cosmetics products have been found to be misaligned with the regulatory framework of the British market. This commonly occurs when a new product is developed for the EU and then sold into GB without undergoing a full adaptation.

Whilst these products aren’t necessarily unsafe, it does point to a wider issue as standards continue to deviate between the two markets.

In terms of food labelling, the EU has recently sought to ban several meat-related terms for plant-based foods, whereas meat-substitute products can enjoy much greater flexibility within the UK market as no ban currently exists.

Where there are new regulatory compliance requirements, new product labelling requirements often follow, and the changes brought about by Brexit and now the UK/EU SPS Agreement are no exception.

Following the Windsor Framework agreement in 2023, which brought about the Northern Ireland Retail Movement Scheme (NIRMS), the most notable change to packaging and labelling requirements in the UK is the ‘Not for EU’ label. This must be displayed on food and drink products and some pharmaceuticals moving from GB to NI. Goods must bear this wording to show that they will remain within the UK and will not enter the EU market.

Other post-Brexit packaging updates include country-specific labelling, with certain foods sold in the UK – including meat and fish, fruit and vegetables, honey, olive oil, wine, and eggs – required to clearly state the country of origin using ‘UK’ and ‘non-UK’ terminology, replacing the former ‘EU’ or ‘non-EU’ wording.

Regulated products such as medical devices and cosmetics must now also bear the UK-based Responsible Person’s name and address on the label, either showing the business responsible for marketing the goods or for importing them.

For companies operating across both the UK and EU markets, these changes have created additional compliance burdens as now a product correctly labelled for the EU is no longer automatically compliant in the UK, as it once was.

The need for differently labelled products has led to further artwork costs and added complexity as brands attempt to accommodate multiple compliance requirements across their products.

Getting it wrong can mean businesses face a series of escalating consequences, including market withdrawal, product recalls, enforcement notices, financial penalties, and even court action.

The Cost of Compliance

The price of Brexit is another area to consider when looking at the regulatory implications of the withdrawal process.

As it stands, the EU remains the UK’s biggest trading partner, but there’s no denying that trade with the bloc is now decidedly more complex. Since Brexit, businesses must navigate a greater number of checks, more paperwork, and a multitude of conflicting regulations – making compliance far more expensive, not to mention a whole lot slower than before.

As a result, the volume of exports from the UK to the EU has greatly decreased. Within the food industry, exports fell by 34% between 2019-2024, as British producers of both fresh and processed foods grappled with reduced access to the EU market. Before the UK’s withdrawal from the European Union, food products flowed freely, but the latest figures reveal that farmed exports to the EU have fallen by 47% whilst the value has dropped by 35% – and the variety of exports has also greatly reduced too, with 33% fewer products making their way across the border following Brexit.

Of course, it’s not just businesses that are affected by these changes. It’s estimated that Brexit has added around £7 billion to food prices for consumers, with the reduced access to the EU market ultimately leading to a lower quantity of food sold at higher prices.

But, with the SPS Agreement due to come into force next year, it’s predicted that food exports to the EU have the potential to increase by over 20% as barriers to trade are gradually removed.

Meeting The Challenges

A decade later, the one thing that appears to have been consistent about Brexit is the inconsistency. Regulatory change remains constant and unpredictable, and there is still much uncertainty.

It’s therefore crucial that businesses stay informed and prepared as both regulations and the control and monitoring systems they create continue to evolve post-Brexit.

Here at Ashbury, we help brands and retailers thrive despite the ongoing challenges posed by the rapidly changing regulatory landscape. As your dedicated compliance partner, we can support you with accurate product labelling, regulatory adaptation and translation, incident management, and horizon scanning to ensure you stay one step ahead no matter what comes next.

Get in touch with our regulatory experts to discuss how we can help you navigate the complexities of post-Brexit compliance with confidence.