Core Environmental Standards for UK Imported Agricultural Food Products

This policy report, commissioned by WWF UK and carried out jointly by TULIP Consulting and the Institute for European Environmental Policy (IEEP), examines how the United Kingdom can develop and apply core environmental standards (CES) to imported agricultural and food products — with a particular focus on pesticides and nitrogen use — in a manner consistent with World Trade Organization (WTO) rules.

The report addresses a growing concern in the post-Brexit era. As the UK transitions from the EU’s Common Agricultural Policy to a new domestic framework centred on environmental land management, UK farmers are subject to increasingly stringent environmental requirements. Yet these requirements do not apply to imported agri-food products, which make up nearly half of UK consumption. This regulatory asymmetry creates an undesirably large external environmental footprint, risks environmental leakage as production shifts to less regulated markets, and places UK producers at a competitive disadvantage — with potential long-term pressure to dilute domestic standards to level the playing field.

The report develops a methodological framework for the design and implementation of CES, setting out criteria for prioritising which environmental issues to address first, key design principles — including non-discrimination, proportionality, and grounding in scientific evidence — and considerations for an inclusive and fair implementation process that takes into account the specific circumstances of developing country exporters. It emphasises that CES must be designed in a WTO-consistent manner, drawing on the disciplines of the General Agreement on Tariffs and Trade (GATT), the Agreement on Technical Barriers to Trade (TBT), and the Agreement on Sanitary and Phytosanitary Measures (SPS).

The methodology is then applied to two detailed case studies: neonicotinoid insecticides, three of which are no longer approved for outdoor use in the UK due to their harmful effects on bee populations, and nitrogen use in agriculture, where excessive application causes significant environmental harm including water pollution and greenhouse gas emissions. For each case study, the report examines the environmental issue, the existing UK regulatory framework, trade implications, and policy design options, followed by a legal analysis of each option’s WTO compatibility.

The report concludes with practical recommendations for the UK government on how to develop a CES framework that is environmentally effective, legally sound, and sensitive to the needs of trading partners — offering a replicable model that could be extended to other environmental issues in the future.