North America: Market access and barriers to trade

In this section, we look at tariff and non-tariff barriers to entry for UK red meat and dairy exports to North America. The UK signed the UK–US Economic prosperity deal in May 2025 and has trade continuity agreements in place with Mexico and Canada; both countries are expected to fully ratify the UK’s accession to CPTPP in 2026.

The UK’s market access for animal products has improved, with export health certificates (EHCs) allowing beef and lamb into the USA from September 2020.

In 2021, UK pork was granted access to Mexico, followed by pork offal in 2024.

In August 2025, Mexico approved 12 British businesses to export pork products – a major breakthrough – expected to be worth £19 million over five years.

The UK has EHCs in place to send most red meat and dairy products to North America, the exception being beef and lamb to Mexico (Table 1).

Table 1. GB export health certificate 2025

Source: Animal plant and health agency (APHA) Find an export health certificate - GOV.UK

North American most-favoured nation (MFN) tariffs under World Trade Organization (WTO) rules vary by country and product.

The USA and Canada apply high duties on beef, while Mexico applies none.

Pork is duty-free across all three markets. For lamb and sheep meat, Mexico maintains a uniform 10% tariff, while US and Canadian rates range from 0 to 3%.

Dairy tariffs are highest in Canada, moderate in the USA and variable in Mexico.

For cereals, tariffs are steep in Canada, minimal in the USA and zero in Mexico (Table 2).

Preferential access is granted only where Free Trade Agreements (FTAs) or tariff-rate quotas (TRQs) are in place.

Table 2. Average ad valorem tariff rates for red meat, dairy and cereals in North America

n.e.s: not elsewhere specified

Source: World Trade Organisation

Canada enforces rigorous CFIA (Canadian Food Inspection Agency) certification for all food exports, including traceability and animal health checks.

Bilingual labelling (English and French) is mandatory for packaged goods.

UK cereals must meet strict pesticide residue standards, and as precision breeding (PB) develops, this needs to be monitored.

It is common for UK cereals regulations to differ from Canadian regulations, especially in food safety and labelling.

UK exporters face stringent Sanitary and Phytosanitary (SPS) controls, especially for meat and dairy, with United States Department of Agriculture (USDA) and United States Food and Drug Administration (FDA) inspections required.

Labelling regulations and FDA-compliant nutritional and allergen disclosures are also needed.

For beef, a certificate of authenticity is mandatory to access the 13,000-tonne TRQ the UK has been granted under the UK–US Economic Prosperity deal.

Dairy imports require licences, and UK-approved additives may be restricted. Customs procedures are complex, and out-of-quota tariffs can be prohibitive.

Thanks to the de minimis exemption, UK exporters could send goods under $800 to the USA without paying import duties or dealing with full customs procedures.

This rule helped reduced costs and kept paperwork minimal, especially useful for small, frequent shipments of perishable goods such as tasters and samples, especially for dairy products such as cheese.

But, from 29 August 2025, the USA removed this exemption for imported goods. Now, every shipment, regardless of value, faces tariffs and full customs checks.

For UK farmers and food producers, this change will have an impact on smaller exporters as well as increased costs to market entrants or new products for current participants.

This has brought new challenges: exporters may have to rethink pricing, packaging and logistics to stay competitive in a tougher US trading environment.

Mexico imposes layered sanitary and phytosanitary (SPS) barriers via SENASICA, requiring health and plant protection certificates for meat, dairy and cereals. Spanish-language labelling must comply with NOM standards (Normas Oficiales Mexicanas), including front-of-pack nutritional warnings.

Import permits (automatic or non-automatic) are needed for sensitive goods like dairy and pork. UK exporters must provide EUR1 certificates of origin to claim preferential tariffs under the UK-Mexico Trade Continuity Agreement (TCA).

Regulatory divergence includes restrictions on additives and strict genetically modified organisms (GMO) labelling laws.

The UK has FTAs in place with both Canada and Mexico, following on from when the UK was a member of the EU.

However, in some sectors the EU has more favourable arrangements with Canada and Mexico, leaving UK producers at a relative disadvantage until CPTPP ratification is complete.

In the USA, shifting tariff policy under Trump and limited concessions beyond beef mean UK exporters face indirect pressure from both EU competition and volatile trade networks.

These developments will need close monitoring, as delays and indirect effects from other trade deals could shape UK access to North American markets.

As of late 2025, the UK’s accession to the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) has been agreed upon, but it is still pending ratification with Mexico and Canada. Canada confirmed its intent to ratify the agreement following bilateral discussions earlier in 2025.

Mexico has expressed support, but it has not yet completed its domestic legislative process. These delays mean that, for now, the UK cannot begin to take advantage of the market access benefits of CPTPP and can only trade under continuity agreements with both countries.

Trade policy under the second Trump administration is likely to remain a key watch point. 

At the time of writing (January 2026), the USA has imposed, postponed and re-introduced tariffs at various levels on goods from a raft of countries around the world. 

The consequences of these tariff levels will not just be felt by countries on which they are imposed but on trade networks. The UK is likely to experience indirect effects, as the EU is its largest trading partner.

The UK–US Economic Prosperity Deal signed in May 2025 expands market access for UK agri-food exports. Beef benefits the most, with the introduction of a UK-specific 13,000t beef quota. Pork, lamb and cereals see no new market access opportunities.

The EU–Canada Comprehensive Economic and Trade Agreement (CETA) , provisionally applied since 2017, eliminates most tariffs on EU exports and simplifies customs procedures. EU dairy, beef, cereals and processed foods benefit from preferential access and protected geographical indications.

The EU and Mexico have agreed to a modernised trade deal that expands agricultural access and strengthens protections for EU food products. Key beneficiaries include EU dairy, cereals and processed goods.

While the EU lacks a full FTA with the USA, sectoral arrangements allow quota-based access for high-quality beef and strong exports of cheese, wine and processed foods. However, tariffs and SPS barriers still apply.

Routes to market – To come