Toward an EU-UK Veterinary Agreement
Dr Elizabeth Mullineaux FRCVS has been recently appointed as the new President of the British Veterinary Association. In her first speech as President, speaking at the annual BVA Northern Ireland dinner at Stormont, she highlighted one of the biggest challenges facing the profession in the UK and Northern Ireland and which the UK government must prioritise; a EU-UK Veterinary Agreement.
Since the United Kingdom's departure from the European Union (EU) on January 31, 2020, one of the most pressing issues in post-Brexit negotiations has been the regulation of trade. The absence of a formal veterinary agreement between the EU and the UK has led to significant challenges for both parties, particularly regarding sanitary and phytosanitary (SPS) standards; but also challenges to accessing veterinary medicines in Northern Ireland.
A veterinary agreement between the UK and the EU could help ease trade frictions, protect public health, and maintain animal welfare standards while safeguarding the integrity of the UK's and EU’s markets.
The current challenges
Following Brexit, the UK can set its own standards for food safety and plant and animal health in Great Britain (GB), independent from the EU. The absence of an EU-UK veterinary agreement means that all goods of animal origin (such as meat, fish, dairy, and live animals) are subject to SPS checks when they cross borders. These checks, while essential for maintaining biosecurity, have led to disruptions in trade, particularly for businesses that depend on just-in-time supply chains.
Northern Ireland has a particular position, as it continues to follow the EU’s rules in this area due to the Windsor Framework and businesses which move agricultural from GB to the EU and, to a lesser extent, from GB to NI must now demonstrate compliance with EU rules.
Northern Ireland is also having to navigate the uncertainty of future access to veterinary medicines which play a crucial role in maintaining the health and welfare of animals, safeguarding public health, and supporting the agricultural economy; which is one of the most vital sectors in Northern Ireland. Given the importance of veterinary medicines to avoid disease, the European Commission issued a statement providing a three-year extension for the grace period for the supply of veterinary medicines to Northern Ireland until the end of 2025. However, once the grace period expires, there are significant concerns about the availability of veterinary medicines in Northern Ireland due to the requirement for batch testing , the need for a marketing authorisation holder (MAH) based in Northern Ireland or the EU, and potentially labelling or manufacturing requirements for Northern Ireland requiring bespoke manufacturing which may make it difficult for pharmaceutical companies to continue its supply to Northern Ireland as it is a small market.
The importance of a veterinary agreement
A veterinary agreement establishes a framework for mutual recognition of SPS measures related to food safety, animal health, and plant health. It ensures that trade in animals, animal products, and other regulated goods can proceed smoothly, by reducing border checks and delays, or the need for certain certifications
In the context of the EU-UK relationship, a veterinary agreement could facilitate trade between the UK and Europe whilst ensuring high standards of food safety and animal welfare. By harmonizing veterinary and sanitary standards, the agreement would help prevent the import or export of substandard products that could threaten public health, animal welfare, or plant health. It would ensure that both trading partners? maintain high levels of food safety, benefiting consumers and producers alike. The agreement could also end the uncertainty and anxiety around future access to veterinary medicines for Northern Ireland.
There are several potential models for an EU-UK veterinary agreement, with varying degrees of alignment and flexibility:
- Swiss-Style Agreement: The Swiss agreement through a series of bilateral agreements, including a veterinary agreement which creates a common veterinary area based on Switzerland and the EU having similar legislation, which in practice means Switzerland modifies its legislation when there are changes in the EU. This agreement allows for the free movement of agri-food products between Switzerland and the EU with minimal border checks.
- New Zealand-Style Agreement: The EU and New Zealand have a veterinary agreement that provides for mutual recognition of equivalence in certain SPS standards, meaning that each side accepts the other’s standards in an agreed list of products, while not applying the same SPS rules. This agreement reduces the need for inspections but does not require full alignment of regulations. The New Zealand model offers greater flexibility but would still require significant cooperation and trust between the UK and the EU.
- Custom Arrangement: The UK could negotiate a bespoke veterinary agreement that suits its unique circumstances. Such an agreement could involve partial alignment on key SPS issues while allowing for some regulatory divergence. However, any divergence from EU standards could mean more frequent checks and inspections at the border, limiting the agreement's effectiveness.
An EU-UK veterinary agreement could be a key step toward smoothing post-Brexit trade, particularly in agri-food products. It could benefit businesses, consumers, and public health while preserving the high standards that both the EU and UK are committed to upholding. However, political and regulatory challenges remain, and finding a solution that satisfies both parties will require careful negotiation and compromise.
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