The border paperwork is going. The EU rulebook is coming.
What the draft UK-EU food deal means for sports and nutrition supplement brands, and what to do about it this winter.
Nearly six years. That’s how long protein brands have been fighting the paperwork that came with Brexit: export health certificates, BCP inspections, trucks held at the border, then returns and shipping fees on top. Into the EU and out of it.
This week the BBC reported that the UK and EU have agreed a draft SPS deal. A 200-page text has gone to EU member states, and leaders meet in Brussels on 20 November.
I’ll be honest. This one made me smile.
But I’ve been in this industry long enough to know that relief isn’t a plan. So here’s what the deal means for supplements, and what I’d be doing about it now.
What goes
For anything containing animal ingredients, the border friction falls away. Export health certificates go; the government puts their cost at up to £200 a consignment. Routine border post checks go too. So do the private attestations EU importers sign for shelf-stable products like protein bars.
Whey, casein, collagen, fish oil and colostrum gain the most. Protein has felt it hardest because dairy is its main ingredient, not a trace. Retail-packed supplements with small amounts of animal content have been exempt from border checks since 2021. A tub of whey never was.
Plant-based brands gain far less at the border, because most never needed a certificate. Their win is a single rulebook.
What comes with it
This is the part the headlines skip. The UK is signing up to dynamic alignment. Great Britain follows EU food law, 76 regulations and directives of it, and keeps pace as Brussels changes it. We get to comment. We don’t get a vote.
And it applies to every GB brand, whether you export or not:
GB-only novel food approvals stop counting. You’ll need EU authorisation.
The EU supplements directive never became assimilated GB law. It comes back with every update since 2021.
Titanium dioxide, banned as an EU food additive since 2022, looks set to go from coated tablets.
Every health claim gets read against the EU register.
What doesn’t change
Customs declarations. VAT. Rules of origin. Each of the 27 member states’ own supplement rules. The vet’s paperwork is going. The single market isn’t coming back.
When it happens
Not yet. The government is aiming for mid-2027, a target Defra itself has called ambitious. The summit was postponed once already, both sides still have to ratify, and border posts need European Commission sign-off. My central estimate is Q3 2027 for border relief, with full label and formulation compliance landing during 2028.
Northern Ireland and Ireland: the bit nobody’s talking about
“Not for EU” labels are still law for some supplements moving to Northern Ireland under the retail scheme. Pure animal-derived products such as whey and fish oil need one on every pack. Ministers told the Lords in September they expect that need to “diminish significantly”. Diminish. Not disappear.
If it goes the way it should, one stock pool and one pack could serve GB, Northern Ireland and the Republic. That’s a real distribution opportunity. Just don’t scrap your NI packs until Defra says so.
What I’d do this winter
Classify every SKU: pure animal product, composite, exempt composite or plant-only. Check capsule shells and where your vitamin D3 and omega-3 come from.
Screen every ingredient and claim against the EU novel food catalogue and claims register.
Hold label reprints until draft GB legislation appears, expected early 2027.
Keep “Not for EU” labels wherever they’re needed today.
Model shipping to EU customers from UK fulfilment against the cost of an EU warehouse you may no longer need.
The brands that move first will relabel once. Everyone else will do it twice.
Celebrate this one. Then get to work.
seventy-8 has produced a full briefing on the SPS agreement and supplements, with estimated dates of impact and a cost model. Get in touch for a copy, or for a view on what it means for your range.
Sources: BBC, Defra, Council of the EU, Hansard (Lords, 2 September 2026), House of Commons committee reports. The draft agreement is not yet signed; dates beyond 20 November 2026 are seventy-8 estimates.