7th November 2026
A proposed UK-EU agreement could reopen important export markets for Scottish producers, remove costly paperwork and make it easier for smaller businesses to trade with Europe. But after six years of disruption, can the opportunities be recovered?.
There is growing evidence that some of the barriers to trading with the European Union introduced after Brexit are finally beginning to come down. A draft agreement between the UK and EU covering food safety, animal health and plant health has now been finalised, potentially opening the way for Scottish shellfish, seed potatoes and a range of other agricultural products to return to European markets.
The agreement, known as a Sanitary and Phytosanitary (SPS) agreement, is expected to be one of the important outcomes of the UK-EU summit scheduled for 20 November in Brussels. It could remove many of the certificates, inspections and administrative procedures that have made exporting food and agricultural products considerably more difficult since Britain left the EU.
For Scotland, this is more than another diplomatic announcement. It could have practical consequences for fishing communities, farmers, growers, food processors and exporters, particularly in rural areas where access to overseas markets can make the difference between maintaining and expanding a business.
The cost of Brexit paperwork
When Britain left the European Union, it also left the system under which food, animals, plants and agricultural products could move relatively freely between member states.
New requirements were introduced for exporters. These included health certificates, phytosanitary certificates, border inspections and additional administrative procedures. Each requirement added costs and potential delays.
For large exporters, these costs could sometimes be absorbed, although they still affected competitiveness. For smaller businesses, particularly those sending relatively modest quantities of perishable products, the additional expense could make exporting uneconomic.
Some export health certificates have cost around £200 per consignment, while phytosanitary certificates and inspection fees added further expenses.
The new agreement is intended to remove most of these requirements for goods covered by the arrangements. It could make it easier for smaller businesses to send products to European customers without having to deal with the same level of paperwork and inspection.
The benefits would not be limited to businesses exporting directly to Europe. Changes to domestic regulations, supply chains and certification requirements could also affect producers operating entirely within Britain.
Scottish shellfish could regain access to Europe
One of the most important developments for Scotland concerns live shellfish.
Scottish waters support an important seafood industry, including the harvesting and farming of mussels, oysters, clams and other shellfish. European markets have traditionally been important customers.
However, restrictions following Brexit created particular difficulties for exporters of live bivalve molluscs.
One problem concerns shellfish harvested from Class B waters. Under the existing arrangements, these shellfish can be made suitable for human consumption through a process called depuration. They are held in controlled, clean water to allow bacteria to be reduced before they are sold.
The proposed agreement is expected to reopen the EU market to live bivalve molluscs from Class B harvesting waters for depuration.
This is significant because it could allow producers to regain access to customers who have been unavailable to them since Brexit.
The agreement is also expected to remove export health certificates and many routine border controls for eligible seafood products traded between Britain and the EU.
There will still be food hygiene requirements and other controls. Rules covering illegal, unreported and unregulated fishing will also remain. The changes are therefore not a removal of all checks, but a simplification of the system for legitimate trade.
For Scottish seafood businesses, reducing delays is particularly important. Fresh and live products are time-sensitive, and every additional delay can increase costs, create waste and affect the quality of the goods reaching customers.
Seed potatoes could return to European markets
Another important Scottish industry that could benefit is seed potato production.
Scottish seed potatoes have a strong international reputation, supported by the country's growing conditions and established plant health controls.
Before Brexit, the EU was an important potential market for British seed potato producers. However, the EU stopped accepting seed potatoes from Great Britain following the UK's departure from the single market because of differences in plant health arrangements.
The proposed agreement would allow seed potato exports to resume.
For Scottish growers, this offers the possibility of rebuilding relationships with European customers and recovering business that has been unavailable for several years.
It could also benefit businesses involved in grading, storage, packaging, transport and distribution.
However, reopening a market does not automatically restore lost sales. European customers may have established relationships with alternative suppliers during the intervening years. Scottish producers will have to demonstrate that they can compete on price, quality and reliability.
Other products could benefit too
The agreement covers considerably more than shellfish and potatoes.
Fresh sausages and burgers are among the products expected to regain access to European markets. Cheese, flowers, plants and a range of other agricultural and food products could also benefit from simplified trading arrangements.
The removal of many phytosanitary certificates should help businesses involved in horticulture and plant production.
This could be particularly useful for smaller companies that previously found the cost of exporting relatively small consignments prohibitive.
There is also a potential benefit for British retailers importing European products. Smaller shops and specialist food retailers could find it easier to buy smaller quantities without facing the same administrative costs.
The agreement is therefore about improving trade in both directions, rather than simply helping British exporters.
What does Britain have to give in return?
There is, however, an important condition attached to the proposed agreement.
Britain will have to align its rules covering food safety, animal health and plant health with those of the European Union.
This is known as dynamic alignment. In practical terms, when relevant EU regulations change, Britain will generally have to update its own rules to remain within the agreed system.
The UK will have opportunities to contribute to discussions about future regulations, but it will not have the same decision-making powers as an EU member state.
This will inevitably revive some of the arguments surrounding Brexit.
Supporters of the arrangement will point to the economic advantages of reducing trade barriers with Britain's largest nearby trading market. Critics may argue that Britain is accepting rules over which it has limited influence.
There are also practical implications for farmers and growers. Differences in permitted pesticides, maximum residue levels and other plant protection requirements will have to be addressed.
The Government has acknowledged that some businesses may need to change their practices, products or supply arrangements. The precise exemptions and transition periods will be important.
When will the changes happen?
Although the draft agreement has been finalised, businesses cannot yet start trading under the new arrangements.
The agreement is expected to be discussed at the UK-EU summit in Brussels on 20 November. Political agreement will still need to be followed by the necessary legal and implementation arrangements.
There is also some uncertainty about the timetable.
The UK Government's published guidance has previously identified mid-2027 as its intended implementation date. However, recent reporting suggests that the delay to the summit and the work required to align legislation could push the practical start towards the first quarter of 2028.
Some products may also require additional transition arrangements.
Businesses should therefore prepare for the changes but should not assume that existing export requirements have already disappeared.
What could this mean for the Highlands?
For Caithness, Sutherland and the wider Highlands, the agreement deserves attention.
The region has a considerable interest in maintaining and developing its seafood, agricultural and food-processing industries. Many rural businesses operate at a distance from major markets and have to contend with additional transport costs before their products even reach an export customer.
Removing unnecessary paperwork and reducing border delays could help make some exports more commercially viable.
For shellfish producers, the reopening of European markets could provide opportunities to increase sales. For agricultural producers, access to the seed potato market could be particularly valuable.
There may also be opportunities for local transport companies, food processors, packaging businesses and other suppliers.
However, the benefits will not arrive automatically. Businesses will need information, practical support and help identifying potential customers. Highlands and Islands Enterprise, trade organisations and local business groups should be considering how producers can take advantage of the changes.
It would be unfortunate if a market that took years to develop before Brexit was reopened but smaller Scottish businesses were left without the resources to make use of it.
Recovering lost ground
The proposed agreement represents a significant change in the UK's approach to trading with Europe.
It does not mean Britain is rejoining the single market or reversing Brexit. Nor does it remove all customs requirements or restore the previous trading relationship.
But it does recognise that regulatory barriers can impose real economic costs, particularly on industries dealing with fresh food, agricultural products and live animals.
The National Farmers' Union has highlighted the substantial decline in British food exports to the EU since Brexit. The challenge now is not simply to remove paperwork but to rebuild trade, restore customer relationships and give businesses the confidence to invest.
For Scotland, the return of seed potatoes and improved access for shellfish are particularly welcome possibilities.
The question is whether this will be followed by a wider effort to help Scottish producers recover European markets and develop new ones.
After years of discussing the difficulties created by Brexit, businesses may finally be approaching a period when some of those difficulties can be reduced. The real test will be whether the opportunities translate into more orders, stronger businesses and employment in the communities that need them.