UK-EU SPS Agreement Looms: EU Authorisation Mandate for GB Supplement Market
The UK government is negotiating a UK-EU Sanitary and Phytosanitary (SPS) Agreement, potentially mandating EU market authorisation for regulated food and feed products sold in Great Britain. This signifies a major shift, aligning GB with EU regulatory requirements for novel foods, food additives, and other regulated ingredients.
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London, United Kingdom — 07 October 2026
The UK Food Standards Agency (FSA) has updated its guidance, signaling a significant impending change to the market authorisation process for regulated food and feed products in Great Britain (GB). Following a commitment at the UK-EU Summit in May 2025, negotiations are underway for a UK-EU Sanitary and Phytosanitary (SPS) Agreement to establish a common UK-EU SPS Zone. This agreement, if based on dynamic alignment, would mandate EU market authorisation for regulated products entering the GB market, replacing existing GB-specific authorisations.
This shift means that EU conditions of use and post-authorisation requirements would extend across the entire UK, including GB, where previously EU authorisations only directly applied to Northern Ireland. Consequently, existing GB authorisations would no longer be valid. The FSA explicitly states that a substantial number of applications currently within the GB Market Authorisation Service are unlikely to reach ministerial decision before the agreement's implementation, rendering those applications potentially void.
Businesses across the food and farming sectors, including supplement manufacturers, are strongly advised to begin preparing for these changes. Defra has issued guidance on this. Key areas of impact include novel foods, food additives, flavourings, and feed additives – all critical components within the supplement industry. The guidance points to EU legislation (EUR-Lex, European Commission portals) as the new de facto standard for future regulatory strategies.
While exceptions might be negotiated in limited areas, the overarching implication is a re-alignment with EU regulatory frameworks. For products already authorised by the European Commission before 1 January 2021, those authorisations remain valid in GB. However, any products authorised solely under GB post-Brexit rules will face regulatory uncertainty and likely require re-evaluation under the forthcoming SPS regime.
What this means for United Kingdom
UK supplement manufacturers must urgently review their product portfolios and regulatory strategies. Products containing novel foods, food additives, or other regulated ingredients authorised solely under GB rules will face market discontinuity; brand owners must initiate EU authorisation processes, which typically incur costs exceeding £50,000 per application and extend lead times beyond 18 months. Procurement teams should prioritise sourcing ingredients with existing EU authorisations to mitigate supply chain disruption. Non-compliant products risk market withdrawal, impacting brand reputation and sales projections by Q4 2027.
The FSA reiterates that existing GB rules apply for now but advises proactive engagement with EU regulatory documentation. The quality of application dossiers will remain critical for efficient assessment, whether for current GB processes or future EU-aligned procedures. Incomplete applications will face significant delays or outright refusal, highlighting the importance of robust regulatory submissions.
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