UK ministers have extended the power in the Trade Act 2021 used to implement EU‑era trade agreements until 31 December 2030. The move is set out in the Trade Act 2021 (Power to Implement International Trade Agreements) (Extension to Expiry) Regulations 2025, made on 13 November 2025 and due to take effect on 30 December 2025. Signed by Chris Bryant at the Department for Business and Trade, the regulation keeps a key legal tool available for another five years, lowering the risk of administrative gaps for firms trading on continuity deals.

For context, section 2(1) of the Act lets an “appropriate authority” make secondary legislation to implement agreements the UK replicated from EU deals after Brexit. In practice that means technical statutory instruments that adjust tariff rate quotas, rules of origin, licensing regimes or procurement schedules, rather than headline policy shifts. The extension does not itself change duty rates or product standards; it simply keeps the mechanism alive to make precision updates when required. For importers and exporters, the headline is continuity: government can keep updating the plumbing behind your preferences.

Two dates matter for planning. IP completion day was 11pm on 31 December 2020; the new regulation confirms that no regulations can be made under section 2(1) after the end of the ten‑year period beginning then, i.e. after 31 December 2030. The instrument comes into force on 30 December 2025, so the extended window applies immediately from that point. Regulations already made under section 2(1) remain in force unless amended or revoked, so this is a limit on new instruments, not a sunset on existing ones.

Who can act under the power also remains unchanged. “Appropriate authority” includes UK ministers and devolved governments in Scotland, Wales and Northern Ireland, as defined in section 5 of the Act. Businesses operating across UK nations should therefore expect notices from both Westminster and devolved administrations where a change is devolved, for example in aspects of procurement or labelling. Coordination has been the norm to date, but parallel notices can land at different times.

What does this mean week to week for trade teams? Expect periodic tidying SIs that adjust quota allocations, update product‑specific rules of origin or change evidence requirements for statements on origin. These are typically flagged by DBT or HMRC notices and can have short lead times for compliance. Build a quarterly checkpoint into your customs and procurement calendars from Q1 2026 to capture any updates that affect tariff planning and supplier declarations.

The extension is targeted at EU‑era or ‘rollover’ agreements, not brand‑new trade deals. Implementation of newer accords such as the CPTPP continues to rely on separate primary legislation and distinct secondary powers. In other words, this instrument preserves a specific piece of post‑Brexit machinery; it is not a route for broad changes to new trade policy. That clarity matters for boards assessing regulatory risk and resourcing.

The Explanatory Note indicates no full impact assessment was produced, with no significant effect anticipated on the private, voluntary or public sector according to the Department for Business and Trade and legislation.gov.uk. In practice, even minor rule changes can create operational costs if origins documentation, supplier statements or IT tariff tables need updating. Factor in a small contingency in compliance budgets for 2026–27 to handle document refreshes and training.

Contract clauses tied to tariff headings and preferences deserve a look. If a product‑specific rule of origin shifts or a quota fill rate tightens under a technical SI, the landed cost can move mid‑contract. Consider adding price‑adjustment language linked to customs codes and preference eligibility, and make sure your ERP maps any HS code updates that arrive on the usual 1 January timetable each year. This is unglamorous work, but it preserves margin.

Take a practical example. A UK importer sourcing home appliances under a continuity agreement benefits from preferential tariffs provided origin rules are met and statements on origin are valid. If ministers tweak the evidence requirements or cumulation arrangements under this extended power, the importer must update supplier declarations and retain records accordingly, or risk a duty re‑assessment at audit. The extension means those treadmill‑style updates can continue through to 2030.

The takeaway is straightforward. The government has bought itself headroom to maintain and refine the legal underpinnings of EU‑era trade deals through 31 December 2030, reducing the chance of cliff‑edges for businesses using preferences. Keep an eye on DBT and HMRC updates from 30 December 2025, schedule internal checks, and brief commercial teams that the rulebook can still change-incrementally, but decisively-over the next five years.