Written submission from WWF-UK (UKT0043)

Who We Are
WWF is the world’s largest conservation organisation. Our mission is to stop the degradation of the planet's natural environment and to build a future in which humans live in harmony with nature by conserving and restoring the world's biological diversity, ensuring that the use of renewable natural resources is sustainable and reducing pollution and wasteful consumption. Globally, agriculture and land use are responsible for almost 60% of biodiversity loss and 30% of greenhouse gas emissions. Despite domestic efforts to transition to sustainable farming, UK trade policy is not adequately supporting these initiatives.

We welcome the opportunity to submit evidence to this important inquiry and would be happy to provide additional information, further testimony or an expert witness should it be helpful to the inquiry.

6. Do you believe the three agreements adequately safeguard UK standards in labour rights, environmental protection, consumer protection and food standards?

The agreements with the UK and India, and potentially the USA, do not adequately safeguard UK standards in environmental protection.  A central concern is that the UK market does not require imported goods to meet domestic production standards.

Since leaving the European Union, the UK has introduced sustainable agriculture and animal welfare policies, underpinned by the reformed Environmental Land Management Schemes (ELMS), to achieve the goal of halting and reversing biodiversity loss by 2030. Yet this transition has not been supported by UK trade policy. Rather than acting as an accelerator of sustainable practices, current trade arrangements risk hindering progress.

The UK’s approach to agricultural trade agreements risks undermining both environmental protections and domestic farming standards. Reducing tariffs without safeguards or conditions incentivises environmentally harmful production abroad, threatening ecosystems, livelihoods, and long-term food security, both locally and in the UK. To demonstrate the immediacy of these trade agreements, since the UK-Australia FTA, lamented for its liberalising of low-standard beef, came into effect in May 2023, imports of Australian beef have risen by 535%.[1].

The UK-USA agreement is set to allow 13,000 tonnes of American beef into the UK tariff-free. Environmental standards for beef production differ significantly between the UK and the USA. UK cattle are mostly pasture-raised, and regulations such as Nitrate Vulnerable Zones (NVZs) limit manure use to protect water quality. In contrast, feedlots, which generate significant manure pollution, account for 20% of American cattle inventory[2]. The WRI identifies them as a major source of nutrient runoff contributing to aquatic “dead zones”[3]. The UK enforces national rules to curb methane and water pollution; USA regulations vary by state and are often weaker, giving American beef a larger environmental footprint.

Regulatory approaches also diverge: the UK applies a precautionary, hazard-based system, while the US follows a risk-based model. As a result, pesticides banned in the UK on health and environmental grounds remain in use elsewhere, creating an uneven playing field for British farmers. India also poses challenges here. It currently approves 91 Highly Hazardous Pesticides (HHPs), compared with 73 in the UK, including bee-toxic neonicotinoids and herbicides that poison aquatic environments[4]. With 80% of its surface water directed towards agriculture, this puts immense pressure on groundwater resources. Despite banning such pesticides domestically, the UK does not apply equivalent standards to imports, only residue limits, allowing products grown with these chemicals abroad to enter its market. Recent tariff reductions on fruits, coffee, and grains, along with reaffirmed access for tea and cotton, increase the UK’s exposure to imports produced using practices prohibited at home and enabling unfair competition overseas.

Furthermore, Indian marine supply chains have a larger-than-average social and environmental footprint[5]. WWF highlights that warm-water prawns are among the riskiest seafood products for UK buyers, with Indian production linked to mangrove destruction, salination of rivers, and the loss of precious coastal ecosystems. The footprint is further amplified by the heavy reliance on aquaculture feed, where ingredients such as soy and fishmeal are associated with deforestation, land-use conversion, and biodiversity loss[6].

The new UK–India trade agreement removes tariffs on Indian frozen shrimp and prawns (previously around 4.2%), giving Indian exporters an immediate price advantage in the UK market. While the UK has no domestic prawn industry or production standards, this tariff reduction effectively opens the market to both the best and worst producers. In doing so, it risks allowing environmentally harmful products to undercut and displace more sustainable suppliers, further embedding UK supply chains in the social and environmental risks identified by WWF.

WWF finds that the bottom 10–20% of producers are responsible for 60–80% of environmental harm[7]. While free trade agreements often contain commitments to sustainability or references to international norms, they rarely include enforceable mechanisms or penalties for non-compliance, leaving trade largely unchecked in its environmental impact. This means that each new deal liberalising agricultural imports heightens the risk of a race to the bottom, as lower tariffs give an unfair advantage to goods produced to weaker standards- undercutting UK farmers, threatening their profitability, and undermining the UK’s environmental ambitions.

To address this, the UK should establish core environmental standards in domestic law. Such standards would set a minimum regulatory floor based on meeting similar standards as UK producers for market access, rooting out the environmentally worst-performing producers, while ensuring that imports cannot undercut UK farmers.

Core Environmental Standards would still allow the UK to negotiate and benefit from free trade agreements, while ensuring that food on supermarket shelves reflects the values and expectations of UK consumers. At the same time, they would secure a level playing field for sustainable producers both at home and abroad.

Without explicit requirements tying trade to domestic production standards, these agreements leave UK environmental and animal welfare standards, as well as UK farmers, vulnerable, undermining the principle that trade policy should support, rather than compromise, a resilient, sustainable food system.

7. How well has the Government communicated its progress in negotiations – and how much has it listened to stakeholders during those negotiations?

The UK’s system for scrutinising and consulting on trade agreements urgently requires reform to maintain public confidence in trade negotiations. Without robust parliamentary oversight and public engagement- particularly in the absence of environmental core standards for imports- there is a real risk of undermining domestic food and farming standards. Cheaper, low-standard commodities produced through environmentally harmful practices abroad could flood the UK market, placing unfair pressure on British producers and compromising sustainability goals.

MPs, especially those representing rural constituencies, must be empowered to assess the impact of trade deals on their communities. The Australia Free Trade Agreement, the first signed post-Brexit, highlighted the issue: despite its liberalisation of agricultural trade, it was passed through Parliament without a general debate or vote. This lack of scrutiny denies MPs the opportunity to meaningfully engage themselves or their constituents in the trade policy process, jeopardising domestic standards and eroding public trust.

The Department for Business and Trade (formerly DIT) has pursued trade negotiations on a deal-by-deal basis, without considering the cumulative environmental impacts of successive agreements. Although the Government maintains that each trade agreement will be negotiated independently, the Australia FTA has effectively established a new baseline. If such liberalisation is repeated across multiple agreements, the UK risks offshoring environmental harm- from deforestation to water pollution- and significantly increasing its global environmental footprint.

Viewed in isolation, each deal may appear to have only a marginal impact, but taken together, their effects are far greater. Liberalisation across multiple FTAs compounds pressure on UK farmers, weakens incentives for sustainable production abroad, and accelerates global environmental degradation. Without a cumulative impact assessment, these risks remain invisible in policymaking.

To address this, WWF calls for a strengthened scrutiny process that ensures transparency, accountability, and environmental integrity in trade policy. This includes a public consultation on negotiating objectives and greater parliamentary involvement. After negotiations, both Houses of Parliament should hold a debate and vote on a final deal before ratification, with impact assessments for the environment, public health, human rights and global development should be published in advance of signing or any ratification vote.

Communication during the India agreement process was haphazard at best. Engagement with stakeholders was infrequent, and it was unclear how WWF-UK could best contribute environmental evidence relevant to the UK-India trade relationship. Transparency around the UK–USA negotiations has been entirely lacking. For example, the agriculture industry was caught off guard by the decision to open the UK market to 13,000 tonnes of American beef.

It also remains unclear what ratification process will apply to a trade deal that does not constitute a full free trade agreement, such as a potential UK-USA arrangement. This committee should therefore seek assurances from the Minister by requesting a clear outline of a robust process for scrutiny, debate, and a parliamentary vote on any final agreement with the USA.

To improve public and parliamentary engagement, the UK must reform the trade scrutiny process. Future trade deals, of all kinds, must be subject to pre-negotiation public consultation on objectives and enhanced parliamentary oversight, including a requirement for debates and votes in both Houses on any final agreement. Additionally, the timely publication of impact assessments- covering the environment, public health, human rights, and global development- should be mandatory and made available well in advance of signing or ratification. These measures would strengthen democratic accountability and build public trust in the trade process.

In parallel, the Government should introduce flanking policies, including legally binding core environmental standards for imports, which would apply across all forms of trade- not just formal FTAs. This approach would present clear red lines for negotiators and ensure that British values are upheld across our trade relationships, and reduce the scrutiny burden. It would also reduce the risk of offshoring environmental harm, such as deforestation and water pollution, by requiring imported goods to meet environmental standards comparable to those applied within the UK.

August 2025