Ten years after the UK voted to leave the European Union, the practical consequences for businesses are still reshaping how they operate. Between 2019 and 2024, food exports to the EU fell by 34% according to the Food and Drink Federation, and that drop is just one measure of a much wider shift. Trade rules, labour availability, and regulatory approvals now work differently on each side of the Channel, and many businesses are still adjusting to the new baseline.
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This article is general information only and does not constitute professional advice. For your specific situation, consult a qualified professional.
The picture is not uniform. Some sectors have found new opportunities in regulatory divergence, while others face higher costs and thinner margins. What matters now is understanding which changes are permanent and which are still evolving. Here’s what you actually need to know.
What the research reveals about Brexit’s business impact
The central concept here is regulatory divergence — the process by which UK and EU rules move apart over time.
What I tend to notice is that businesses which treat divergence as a one-off event rather than an ongoing process are the ones that get caught out. The UK and EU are not drifting apart at the same speed in every sector, and that unevenness matters. For a deeper look at how smaller companies are navigating this landscape, the article on Brexit’s impact on UK SMEs covers the specific challenges for smaller operations.
What changes when trade rules shift permanently
The most immediate consequence of Brexit for most businesses is the cost and complexity of moving goods across borders. Before the BTOM was introduced, much of the EU’s food flowed into Great Britain without border checks. Now, sanitary and phytosanitary (SPS) requirements apply to certain foods, and the paperwork burden has increased across the board.
In 2024 alone, UK food exports to the EU fell by 17%, while imports from the EU actually rose by 3.3%. That asymmetry tells you something important: the new barriers are not symmetrical. UK exporters face more friction than EU exporters sending goods the other way, partly because the UK’s border infrastructure and readiness have taken time to catch up.
For a business that previously shipped to the EU without thinking about customs, the change is not just administrative — it affects pricing, delivery times, and whether certain products are worth exporting at all. The cost of labour adds another layer: 38% of businesses with 10 or more employees now report it as their main challenge, according to the ONS Business Insights survey. When labour is both scarce and expensive, the margin for absorbing new trade costs shrinks.
Where businesses get the post-Brexit landscape wrong
Treating the Windsor Framework as a minor labelling issue
The ‘Not for EU’ labelling requirement under the Windsor Framework has been widely opposed by food businesses, but it’s not optional. Goods moving from Great Britain to Northern Ireland through the green lane must carry this label. The red lane, for goods bound for the EU, faces full checks. Businesses that assumed this would be simplified or dropped have had to retrofit labelling systems. The practical fix is to map your supply chain to determine which lane your products fall into before you print labels, not after.
Assuming EU and UK regulations will stay aligned
Many businesses still operate as if UK and EU rules are interchangeable. They are not. The UK’s novel food regulation under the Food Standards Agency is largely inherited from the EU framework, but they are now separate systems. An applicant must apply to one or both. The EU has explicitly prohibited regulatory sandboxes for novel foods in its Biotech Act, while the UK actively uses them. If you’re developing a product that needs regulatory approval, you can’t assume one approval covers both markets.
Ignoring the labour shortage as a temporary blip
The NFU directly links Brexit to ongoing agricultural worker shortages, and the hospitality sector reports similar pressures. This is not a post-COVID hangover that will fade. The end of the Seasonal Agriculture Workers scheme in 2013 combined with Brexit to create a structural gap. Businesses that rely on seasonal or migrant labour need to factor higher recruitment costs and longer lead times into their planning, not hope the situation resolves itself.
Overlooking the divergence in animal welfare and food tech
The UK banned the export of live animals in 2024 and pledged to ban boiling live crustaceans in 2026. The EU has not taken these steps. Meanwhile, the UK has loosened gene-editing rules for precision-bred crops, while the EU only recently aligned to a similar position. These differences matter for any business in agriculture, food production, or biotechnology. What’s legal in one market may not be in the other, and the gap is widening.
Practical steps for navigating the new trade and regulatory environment
Map your supply chain against the BTOM and Windsor Framework
The first step is understanding exactly where your goods cross borders and which checks apply. The BTOM introduced SPS requirements on certain foods, but not all. If you import from the EU, you need to know whether your products fall under physical inspection requirements or can use simplified procedures. For Northern Ireland, the green lane/red lane distinction determines whether ‘Not for EU’ labelling is needed. This is not a one-time exercise — the rules are still being implemented, and the thresholds for checks can change.
Separate your regulatory approval strategies
If your business deals with novel foods, gene-edited crops, or plant-based products, you now face two distinct approval pathways. The UK’s FSA and the EU’s EFSA operate independently. A French cultivated meat company, Vital Meat, chose to submit its application in the UK rather than the EU, suggesting the UK process may be faster or more favourable for certain products. Worth weighing against the cost of dual applications if you plan to sell in both markets. For legal questions around intellectual property or compliance in either jurisdiction, JustAnswer Business Law can connect you with a solicitor who understands the specific regulatory landscape.
Adjust pricing and sourcing for persistent cost pressures
With 37% of trading businesses reporting increased prices of goods and services bought in May 2026, and 63% concerned about energy prices, the cost base has shifted permanently. The ONS data shows that 19% of businesses expect to increase their own prices in July 2026. If you’re sourcing from the EU, factor in both the direct cost of goods and the administrative cost of customs compliance. For some businesses, shifting to domestic suppliers reduces complexity, though not always cost.
Plan for further divergence, not convergence
The UK’s pledge to ban foie gras imports was reportedly dropped due to EU alignment negotiations, as The Guardian reported. That suggests the government is willing to trade regulatory independence for trade deals. But in other areas — gene editing, novel foods, animal welfare — divergence is accelerating. The safe assumption is that the two regulatory systems will continue to move apart, not back together. Build your compliance processes to handle two sets of rules indefinitely.
→ Scroll right to see all columns
| Area | UK Position | EU Position |
|---|---|---|
| Novel food regulatory sandboxes | Permitted and actively used | Prohibited under Biotech Act |
| Gene-edited crops | Loosened rules since 2022; some crops not classed as GMOs | Recently aligned; crops under threshold exempt from GMO rules |
| ‘Meaty’ names for plant-based products | No ban; full naming flexibility | Ban on 31 terms including ‘steak’ and ‘chicken’ |
| Live animal export | Banned in 2024 | Not banned |
| Boiling live crustaceans | Pledged to ban in 2026 | No equivalent pledge |
Frequently asked questions about Brexit and UK business
Do I need separate product approvals for the UK and EU now? ▾
What is the Border Target Operating Model and does it affect my business? ▾
Can I still hire EU workers for my UK business? ▾
What does ‘Not for EU’ labelling mean for my products? ▾
Are UK and EU animal welfare laws still the same? ▾
Will the UK and EU regulations ever realign? ▾
The next phase of divergence will test business adaptability
The first ten years after the referendum were about establishing new frameworks. The next ten will be about how those frameworks evolve independently. The UK’s regulatory sandbox for novel foods, the EU’s ban on meaty names for plant-based products, and the divergence on gene-editing rules all point in one direction: the two markets are becoming structurally different, not just administratively separate. Businesses that build their compliance and supply chain strategies around that reality will have a clearer path than those waiting for things to go back to how they were.
Remember: this article is general information only. For advice on your specific situation, speak to a qualified professional.
If this was useful, you might also want to read Navigating UK supply chain disruptions: resilience strategies for growth.
Sources and Further Reading
Brexit’s impact, opportunities and challenges for UK SMEs — A closer look at how smaller businesses are adapting to the post-Brexit environment.
Is the UK falling behind in the global tech race? — Examines how regulatory divergence affects the UK’s position in technology and innovation.
Food Navigator (2026). Brexit 10 impacts on food and beverage. 🔗
ONS (2026). Business insights and impact on the UK economy. 🔗
The Guardian (2026). Labour back down on foie gras and fur bans in EU trade deal. 🔗
