Designing environmental regulation of agricultural imports: Options and considerations for the UK
The United Kingdom’s departure from the European Union (EU) has created both the need and the opportunity to rethink the relationship between its trade and environmental policies. As the UK works toward net zero and commits to increasingly stringent domestic environmental standards under the Agriculture Act and Environment Act, these requirements do not currently extend to imported agri-food products — which account for nearly half of UK food consumption. This regulatory asymmetry creates risks of carbon and environmental leakage, undermines the competitiveness of domestic producers, and risks counteracting the UK’s broader sustainability ambitions. Policy measures proposed by the government to date — including voluntary labelling schemes and multilateral advocacy — are insufficient to guarantee that the environmental standards embedded in UK domestic regulation are upheld across the full scope of the UK’s agri-food system.
It is against this backdrop that this think piece explores the concept of Core Environmental Standards (CES) as a trade policy tool — a set of regulatory requirements applicable to both domestically produced and imported agri-food products. It sets out four criteria for identifying the environmental issues most suitable for CES: the importance of the environmental issue; its global rather than purely local character; the existence of a regulatory gap between the UK and its trading partners; and the implications for domestic competitiveness. Applying these criteria, the think piece identifies four priority areas for case study development: biodiversity protection through pesticide approval regulation, focusing on neonicotinoids; biodiversity protection through the regulation of crop nutrient management, particularly nitrates; climate protection through targeted contributions to net zero in the agriculture and land use sectors; and measures to protect climate and biodiversity by establishing a “not associated with deforestation” standard for products such as beef, soy, and palm oil.
The think piece also examines the implications of CES in the context of WTO rules. It analyses the distinction between product-based requirements and process and production method (PPM) based measures — a critical legal distinction given that many environmental requirements for agri-food products focus on how a product is produced rather than its physical characteristics. Drawing on WTO case law and emerging regulatory practice, including the US Marine Mammal Protection Act and the ongoing WTO dispute between Indonesia and the EU on palm oil, it identifies key design principles that would minimise the risk of WTO inconsistency — including non-discrimination, proportionality, and a focus on levels of environmental protection achieved rather than the specific means of production.
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The analysis presented was the first contribution to a broader research project commissioned by WWF UK. The findings and recommendations were subsequently developed and deepened in a full research report, which can be accessed here.
