England updates high-risk food import rules Jan 2026
England has confirmed a fresh round of import controls on high‑risk food and feed of non‑animal origin, with rules taking effect on 1 January 2026. The Statutory Instrument was made on 3 November and laid before Parliament on 5 November 2025, updating the retained version of EU Regulation 2019/1793 as it applies in England. The measure replaces Annexes I and II in full via new schedules and was signed by Parliamentary Under Secretary of State Ashley Dalton, according to Legislation.gov.uk.
For importers, wholesalers and retailers, this is a practical change rather than a headline‑grabbing one. The update resets which consignments attract identity and physical checks at Great Britain border control posts and which need special conditions to enter. Annex I lists products facing a temporary increase in official controls; Annex II lists those that can only enter when specific certificates and test results accompany the shipment.
The legal presentation has been modernised. References to EU ‘CN codes’ and ‘TARIC’ have been replaced by UK ‘commodity codes’ aligned to the Integrated Tariff under the Taxation (Cross‑border Trade) Act 2018. Several legacy ‘ex’ markings have been removed or rationalised, and footnotes have been streamlined to point to agreed sampling and analytical methods. In day‑to‑day terms, businesses must ensure their customs commodity code matches the SPS documentation precisely.
The revised annexes continue to target categories where contamination risk has been documented. Examples include groundnuts and peanut products, sesame seeds and derived foods such as tahini and halva, pistachios, hazelnuts, dried figs, palm oil, vine leaves, enoki mushrooms, okra, peppers, aubergines, yard‑long beans, and fresh herbs such as basil, mint and parsley. Country‑specific listings cover origins including China, India, Iran, Israel, Kenya, Georgia, Ghana, Egypt, Sri Lanka and Syria. Importers should confirm the exact line‑item status for each supplier and SKU rather than relying on broad product names.
The risk themes remain familiar to quality teams. Annex notes reference aflatoxins for nuts and seeds, pesticide residues across herbs and vegetables, and ethylene oxide and certain dyes or plant protection substances in spices and compound foods. Where a product sits in Annex II, the consignment must travel with the exporting country’s official certificate and results of sampling and analysis; for Annex I, businesses should expect elevated rates of identity and physical checks at the border.
Consider how this lands operationally from New Year. A consignment flagged for sampling can spend longer at the border while analyses are completed, driving storage, demurrage and handling charges. If paperwork is incomplete, goods can be held or refused, with knock‑on effects for fulfilment. Finance teams should refresh landed cost models for Q1 runs and build in a margin for testing and potential dwell time on higher‑risk lines.
A spice importer in Leicester brings in cumin and turmeric from India for foodservice packs. Their practical response is to map each SKU to the updated UK commodity code, check whether those codes fall under Annex I or II, and obtain the required official analyses from the exporting authority before booking. They split multi‑origin loads to avoid a single non‑compliant lot holding up the entire container and schedule arrival dates to steer clear of the early‑January peak at port health.
A London wholesaler of Middle Eastern foods sources tahini from Syria. Under the revised Annex II entry for sesame products, shipments must arrive with the correct official certificate and lab results. The buyer moves to earlier purchase orders in December, adds two weeks of buffer stock into stores, and agrees with the forwarder on which control point will handle any inspections to reduce secondary haulage.
For retailers, this is a small but real cost pressure on categories like nuts, seeds and spices. The best mitigation tends to be planning rather than price rises: earlier ordering for January arrivals, tighter supplier QA clauses, and clear instructions for brokers so commodity codes, invoices and health documentation match. Where ranges rely on seasonal fresh produce from listed countries, buyers may want a secondary supplier on standby for the first quarter.
The shift to UK‑specific commodity codes is the hidden trip‑wire. Copying an old EU CN/TARIC reference from historic paperwork can push a line into the wrong control regime. The practical fix is an internal ‘code audit’-clean the tariff codes in the ERP, confirm them with the customs agent, and make sure the same code sits on the invoice, the pre‑notification and any certificates. One mismatch is often enough to trigger a hold.
Although the instrument extends to England and Wales, it applies in relation to England only. Checks themselves are performed at border control posts and control points in Great Britain. Businesses trading into Scotland and Wales should watch for parallel measures and guidance from the devolved authorities, while assuming similar operational expectations at the GB border.
Process‑wise, the Department of Health and Social Care notes that it consulted as required under food law, and the changes are made under the UK’s Official Controls framework. An Explanatory Memorandum and the full schedules are available on Legislation.gov.uk. For most firms, the real work now is translating legal text into supplier instructions and shipment‑by‑shipment routines.
Timings are tight but manageable. With the instrument made on 3 November 2025, laid on 5 November and in force from 1 January 2026, businesses have roughly eight weeks to update codes, pre‑notification templates and supplier documentation. Teams that complete this before the Christmas cut‑off typically avoid the New Year queue at port health. That’s the difference between a smooth first quarter and stock‑outs in high‑margin aisles.