With the EU now setting out a draconian list of demands to allow the UK is to “reset” its relationship with the EU, UK policy makers should accurately assess whether the UK needs such a reset.

Comically the mad remainiacs — and there is no other term for them when you look at the dire economic statistics of the EU — are trying to pretend that the UK is a large agri-food exporter, that the EU is our only possible customer, and that they have ceased to trade with us because we haven’t dynamically aligned with their Sanitary and Phytosanitary (SPS) regulations. None of these things are true. But that doesn’t mean that the mad remainiacs aren’t inventing statistics to promote their case.

The latest paper, from something called the Centre for Inclusive Trade Policy (CITP), is full of half-truths and mathematical errors, all cherrypicked to support the case for dynamic alignment.

The paper’s authors don’t understand the Rules of Origin in the UK EU TCA and how these have changed the way we measure UK-EU trade. Nor have they considered the UK’s agricultural production limitations that have constrained UK agri-food exports to any destination — whether EU or non-EU. Instead, they believe that only post-Brexit border checks could have caused a decline in UK agrifoods exports to the EU.

The CITP is meant to focus on inclusive trade policy, using an £8 million grant from the Economic and Social Research Council (ESRC), the UK’s largest public funder of research on economic and social issues. The ESRC is meant to support high-quality research. But the CITP paper is neither high quality nor focused on its raison d’etre — inclusive trade. Instead, it is promoting dynamic alignment with the EU, an institution that excludes agri-food trade with the imposition of high tariffs, small quotas and strict SPS and TBT regulations. The EU is the antithesis of trade inclusivity.

Dodgy Maths
The TICP paper uses many misleading statistics, such as implying the UK’s agrifood sector is an important part of UK-EU trade because it employs 13 per cent of the UK’s workforce without mentioning that the vast majority (85 per cent or 3.7 million) are not involved in trade but employed domestically in restaurants, food retailing and food manufacturing. These industries will continue to operate without EU SPS alignment. Whilst very few of the 400,000 employed in agriculture and fishing and the 200,000 involved in food wholesaling would benefit from SPS alignment with the EU.

The CITP paper miscalculated the fall in agri-food exports, by claiming that “UK agrifood exports to the EU have decreased by on average 16.34 per cent per year compared to the previous 3-year period.” Was this an honest mistake or was it designed to get media attention? Either way, it’s not true, but it is a warning about the inaccuracy of the whole paper.

Using Defra’s figures in constant 2023 prices, the UK’s average agri-food exports to the EU in the three years post-Brexit (2021, 2022 and 2023) was 16.3 per cent lower than the average for the three pre-Brexit years (2018, 2019 and 2020). This is not a per-year change but a single difference between two 3-year averages. However the three years before Brexit were the UK’s highest agri-food exports ever, measured in 2023 prices. Theresa May’s strategy of threatening to leave the EU without a trade deal encouraged agrifood stockpiling. All product sectors saw record agri-food exports to the EU in 2019 except animal feed and sugar which both made record-highs in 2018.

However, whilst a 16.3 per cent reduction sounds enormous, this is only £2.8 billion — a mere 0.3 per cent of total UK exports in 2023 (£843.5 billion). Why is the CITP worried about this tiny variation in EU exports when it didn’t bother to mention the increase in UK agrifood imports and exports to non-EU countries? Surely this would be of greater interest for a think tank focused on inclusive trade.

The tiny fall in exports was not evenly spread across the agri-food industry. For example, the 3-year average of UK Fruit and vegetable exports to the EU fell by over 41 per cent simply because of the Rules of Origin in the UK EU Trade and Cooperation Agreement (TCA). Before Brexit, many tropical fruits and nuts grown in Commonwealth countries were landed in the UK and then re-exported to other EU countries. When the UK was a member of the EU these re-exports were recorded as UK exports by the EU’s Intrastat. Now they are recorded as exports from their true countries of origin. This is also true for some of the UK “exports” of Sugar and sugar preparations, down 35 per cent between pre and post-Brexit 3-year averages, and UK “exports” of Coffee and tea, down 19 per cent.

Economic growth won’t come from agriculture
Rather incredulously, the CITP paper, claims the new government’s ambitions for economic growth could be met by growth in the agri-food sector. This is comical. Agri-food is already one of the UK’s smaller export sectors and current government policy will reduce agricultural production: Defra is paying farmers to take land out of agricultural production with overly generous Environment Land Management Scheme (ELMS) payments for growing wildflowers, planting trees or reinstating bogs, whilst the Department for Energy Security and Net Zero (DESNZ) is subsidising farmers to cover their flat agrarian land with solar panels instead of crops. The only chance the UK has of increasing its agri-food exports would be to sell more high value whisky and gin to the US, China and the CPTPP countries, not to tie itself to EU regulations.

Why would UK animal rights campaigners want to realign with countries that still allow the force-feeding of geese?

Beverages make up more than a fifth of all UK agri-food exports to the EU by value and exports to the EU were close to record levels in post-Brexit 2022 without an SPS agreement. But these are high-value products whose exports are susceptible to foreign prosperity. It is disingenuous of the CITP to fail to consider how economic conditions in EU markets affect UK trade and ignore the increase in 3-year average beverage exports to non-EU countries. This was three times larger than the decrease in 3-year average beverage exports to the EU. Greater diversity in UK export markets helped alleviate the export reduction caused by the EU’s economic troubles.

Upper bonds of UK food exports
The UK agricultural production has been steady or falling since the 1980’s. This was not caused by Brexit and SPS alignment will not change this. We can’t export agri-foods we don’t produce.

Defra’s Agriculture in the UK, Data sets, Supply and Use tables show UK fruit, vegetable and potato production have all been falling since 2015, sugar production reached its peak in 1997, and oilseed rape production has been falling since 2011. UK wheat production was highest in 2008. UK Barley production was highest in 1984 but this is also the beginning of Defra’s records so it may have been higher before that. Whilst UK Oat production had its largest production year in 2021, after Brexit.

The UK is not a large exporter of raw agricultural produce because of its rapidly growing population and its shrinking agricultural land. The UK exports less than 3 per cent of its vegetables to the EU by weight and only 6 per cent of its fruit. The table below, using DEFRA trade in tonnes, shows the proportion of UK crops that were exported to the EU over the last ten years. They have remained unchanged since Brexit other than the sectors that included re-exports of tropical products that inflated pre-Brexit export figures. SPS alignment will not increase these export proportions, just as being a member of the EU didn’t increase these per centages.

UK agricultural exports will continue to fall to both EU and non-EU destinations because of the UK’s reduced farmland. SPS alignment with the EU will not change this. Instead, it would help EU producers by enforcing supply chain integration to the detriment of UK consumers. According to Defra, the UK imports around 3 times as much agri-food from the EU as it exports to the EU. This was also true before Brexit and very bad for UK food security. The EU is not the cheapest supplier, and it has the same seasons and weather patterns as the UK.

Unfortunately, there has been little change in UK import supply chains despite Brexit. The UK’s new trade agreements only lower tariffs and increase quotas for agri-food products over many years. Although the reduction of UK sugar tariffs has caused some import substitution of French beet sugar with Brazilian cane sugar.

Exports are also limited by domestic consumption
The UK population has increased by 10 million people since 2000 and now consumes most of the UK’s agri-food production. Consequently, we have less food to export. The UK’s production-to-supply ratio was 62 per cent in 2023, up from only 60 per cent in 2020. This means we are supplying more of our own food. Why would the CITP want to prevent this?

The CITP’s ignorance of the upper bounds associated with UK agricultural production and UK agri-food exports is not surprising. A similar mistake was made in a paper published in June 2024 by Aston Business School, Would a Veterinary Agreement be a boost for UK-EU agrifood exports? The CITP paper cites the Aston paper as supporting its case for EU SPS alignment even though the Aston Paper’s conclusions are ludicrous — its authors have assumed that the UK has unlimited capacity to produce and export agri-food to the EU and that the EU has an unlimited appetite for UK agri-food. Neither is true. Even when the UK was a member of the EU, with full access, the UK didn’t export 22 per cent more agri-food to the EU despite miscounting its fruit, vegetable, coffee, tea and sugar re-exports as UK exports.

The UK has set its own regulations since Brexit
Dynamic Alignment with the EU would also conflict with the UK’s post-Brexit animal welfare regulations. Since Brexit the UK has banned live animal exports for slaughter — an area that did not interest the EU even when we were members. After all of these years of campaigning, why would UK animal rights campaigners want to realign with countries that still allow the force-feeding of geese, amongst other things?

EU SPS alignment would also undermine the UK’s more open attitude to gene editing for precision plant and animal breeding which could increase UK agricultural productivity and potentially increase UK agri-food production.

The UK does not have a single set of agricultural regulations, devolved nations have developed agricultural regulations that suit their weather and type of agriculture. Enforced alignment with EU SPS regulations would take away this regulatory freedom.

The CITP paper also fails to mention that a large part of the UK’s agri-food exports to the “EU”, go to the Republic of Ireland from Northern Ireland rather than from Great Britain. Northern Ireland farmers still comply with EU regulations. SPS alignment would make no difference at all to this trade. Nor for that matter would a veterinary agreement. For example, the UK is largely self-sufficient in eggs, and exports a small quantity to the EU, of which 86 per cent went to the Republic of Ireland in 2023. It is highly likely that these eggs were produced in Northern Ireland. This is also true of UK milk exports.

The CITP paper correctly states that the EU has a comprehensive veterinary agreement with Switzerland without reminding its readers that Switzerland is landlocked by the EU, all its food imports must come from or pass through at least one EU country and Switzerland also provides a major highway for agri-food goods traveling from Italy to Germany or from France to Austria. Their veterinary agreement benefits EU exporters as much as the Swiss. This is not the case for the UK — an island with over 80 ports.

Producers can follow the regulations that suit their customers
A country does not have to formally align with the EU for its exporters to meet the EU’s SPS requirements. For example, farmers who rely on exports to the EU will have already reduced their pesticide use to meet the EU’s new Maximum Residue Limits (MRL) for pesticides, without the need for all UK farmers to do so. Most UK farmers don’t rely on exports to the EU so will meet the UK’s MRLs instead.

Australia has lodged a formal complaint with the WTO over the EU’s new lower MRLs, arguing that the EU’s stringent MRLs are not based on sound science and unfairly create trade barriers to their agricultural products. Both Canada and New Zealand have also raised concerns over this issue. The WTO dispute resolution process is now examining the case to determine whether the EU’s MRLs are indeed trade-restrictive and not justified by scientific evidence.

The EU’s restrictions of neonicotinoid use started before the UK left the EU. Due to the ban, the UK has gone from a net exporter of rapeseed to a net importer and Ukraine is the UK’s largest rapeseed supplier, even though Ukraine still allows the use of neonicotinoids. The EU also imports rapeseed from Ukraine. Under WTO rules, a country cannot ban crops produced using a pesticide if the crops meet that importer’s MRL for the pesticide. WTO law prohibits import restrictions that do not have any connection with the animals, plants or the environment of the importing country but are solely focused on the animals, plants or the environment of the exporting country (except for animal welfare issues).

Other EU regulations
The CITP also claims that the EU’s Carbon Border Taxes (CBAM) will somehow affect UK agri-food exports even though the UK government plans to introduce a similar CBAM on imported fertilisers — the only agricultural product covered by CBAM in either jurisdiction.

Additionally, UK agri-food products shouldn’t be affected by the EU’s new Deforestation-Free Products regulations as the UK’s agricultural land was deforested hundreds of years ago and Defra is currently paying UK farmers to plant trees instead of crops. If anything, the UK is over-complying with this EU regulation.

The CITP paper is concerned that UK exports will be restricted if we don’t comply with the EU’s packaging and waste, single-use plastic, arsenic levels and geographical indication requirements. But any UK agri-food manufacturers that export to the EU will have already complied with these regulations and often do so for all of their production including domestic sales. For example, most people will have noticed that some drink bottles sold in the UK have the lids attached to the bottle as required in the EU. These UK manufacturers have made their own decisions to align with EU regulations, but the government should not force all UK food manufacturers to comply.

The CITP paper also implies that required trade documentation is overly arduous and beyond UK exporters’ intelligence with a table listing the documentation and processes needed for UK-EU agri-food trade. But none of these things are unusual. Any business that exports goods will quickly learn which Harmonised System codes apply to their products and they will know the source of their inputs for rules of origin calculations etc. These things are required for trade with any country. Any food manufacturer, whose products have multiple inputs, generally have computer programmes that calculate this.

Other suppliers
The CITP paper also claims that if the UK imports agri-foods from CPTPP countries, produced to non-EU regulatory requirements, this would force the UK to accept border controls with the EU. But all UK exports to the EU already require Rules of Origin documentation which alerts the EU to any goods being re-exported from countries that don’t meet EU SPS requirements. That is literally the point of the paperwork that the CITP believes is too arduous.

The EU has trade agreements that include agri-food products with nine of the CPTPP countries and it imports agri-food products from the others under WTO rules. None of these countries have dynamic alignment with EU SPS regulations and Chile, a member of the CPTPP, does not allow its farmers to treat their beef cattle with hormone pellets, so there should be no pressure on the UK to do so.

I expect to see additional import substitution with agri-foods from CPTPP countries now that this has come into force. This would benefit both UK consumers and CPTPP producers. Several CPTPP countries would still be regarded as developing nations. Why is the CITP, a think tank dedicated to “Inclusive Trade” and funded with public money, trying to tie the UK to EU imports instead of encouraging more trade with CPTPP countries?

Conclusion
The CITP paper proposes to turn the UK into an EU vassal state. All apparently for the sake of slightly less paperwork for our very small amount of agri-food exports even though it would leave UK farmers with considerably more regulations and less leeway for innovation to improve productivity.

The UK is reliant on imported food as its population has outgrown its agricultural production. But luckily it now has free trade agreements with some large agricultural producers including the EU. Why would anyone want to tie UK producers to EU SPS rules, when we are the buyer of their products not the seller? Of the 24 Harmonised System agrifood sectors, the UK is the EU’s largest non-EU customer in 16 of them: meat, (buying 4 times as much as China), dairy products (buying twice as much as the US), vegetables, fruit, milling industry products, oilseeds, preparations of meat, sugar and confectionary, cocoa and cocoa preparations, preparations of cereals, preparations of fruit, nuts or vegetables, miscellaneous edible preparations, live animals, trees and plants, vegetable plaiting materials and even food industry waste. And the UK is the EU’s second largest customer in a further five agrifood sectors.

The UK should import agri-food products from any country whose goods meet UK SPS regulations. The UK and EU should recognise the equivalence of each other’s SPS measures as the UK does with Australia and New Zealand. This does not require dynamic alignment. If the EU refuses to grant the UK mutual recognition, then they deserve to lose their captured UK market to more competitive producers.