Written Evidence - National Farmers' Union of England and Wales (UIA0010)

The NFU represents 43,000 Farmer and Grower businesses across England and Wales.

The UK’s food and drink supply chains are complex and highly diverse, supporting more than one in ten jobs and contributing £150 billion to the economy. Our farmers and growers work hard to be the UK’s supplier of choice, in retail, in out-of-home and in public procurement, placing nutritious food on British plates three times a day. Ultimately, it is our farm businesses which underpin our national food security.

Executive Summary

1. To date British agri-food exports to India have been limited by significant tariff and non-tariff barriers.

2. We welcome that the government has listened to our concerns around upholding the UK’s production standards and safeguarding our most sensitive farming sectors by maintaining the current level of tariffs for imports of sugar, chicken, eggs and pork within this FTA.

3. It is also positive that the government has managed to secure full access to the Indian market for British lamb and infant formula milk. Although it is disappointing that it was unsuccessful in increasing export opportunities for other products such as dairy, apples and oats.

4. Our principal concern with this deal is that the UK dairy market has again been liberalised to a major dairy producing country. Yet our dairy farmers will not see any greater access for British cheeses and dairy products into the Indian market.[1] The cumulative impact of agreeing ever greater access to our domestic food markets in trade deals cannot be overlooked and is something our government must seriously consider.

Introductory question

Question 1. How important is India as a trading and geopolitical partner for the UK?

5. The Indian economy currently has the highest growth rate in the G20, which is expected to remain above 6% over at least the next 5 years. It has recently risen to become the fifth largest economy in the world and is expected to grow to the third largest by 2028. There are therefore opportunities for British agri-food businesses to grow exports to India as increasingly affluent consumers look to purchase high-quality, iconic British products.[2]

6. However, as noted by the Agriculture and Horticulture Development Board, to date there have been limited export opportunities for the UK agri-food sector due to prohibitive tariff and non-tariff barriers.[3]

7. Whilst this FTA clearly accounts for the UK’s agricultural sensitives to a greater extent than previous bilateral FTAs (see Q6), it secures few new opportunities for British agri-food (see Q3). Consequently, other markets – principally the European Union – will remain the predominant destination for British agricultural exports.

Question 2. What are the potential benefits, opportunities or risks of the India FTA for the UK, and why? When do you anticipate such benefits being realised?

8. As set out in Question 3, the principal opportunity for British agriculture in this FTA is the tariff reduction for lamb exports to India. Though in practice this trade is currently prohibited by the UK’s Export Health Certificate which is not commercially viable. The NFU calls on government to prioritise resolving this market access barrier by negotiating a revised EHC which will allow the UK sheep sector to benefit from the tariff reductions secured within this FTA.

9. Additionally, there may also be opportunities to export British infant formula milk to India due to significant tariff reductions. Disappointingly, whilst there was an opportunity to grow British exports of dairy, oats, and apples to India through tariff reductions within this FTA, the UK Government did not secure greater market access for any of these products in India.

10. As set out in Question 6, the NFU welcomes that the UK Government has listened to our concerns and upheld the UK’s production standards as well as safeguarded our most sensitive farming sectors by maintaining the current level of tariffs for imports of sugar, chicken, eggs and pork. This prevented further risk of our domestic farmers and growers having to compete in the market against imported products produced to standards not legal in the UK. It also sets an important precedent for future negotiations.

11. As set out in Question 4, our principal concern with this deal is the longer-term risk to the UK dairy markets through yet another highly liberalising FTA with a major dairy producing country. The cumulative impact of ever greater access to our domestic food markets in trade deals cannot be overlooked and is something our government must seriously consider. The liberalisation of the UK dairy market is particularly disappointing given that British dairy farmers will not see any greater access for British cheeses and dairy products on the Indian market.

Trade in goods

Question 3. Which UK sectors stand to benefit from greater access to the Indian market in particular? What will the value be to those sectors?

12. Within agriculture the sheep sector stands to benefit from the UK-India FTA. British lamb and sheep meat exported to India will move from a 33% tariff to 0% upon the agreement’s entry into force. Whilst it is positive that the UK Government has managed to secure fully liberalised access to the Indian market for British lamb, it represents a long-term opportunity. There is potential for UK exports to grow over time as India’s middle-class population continues to expand, however there are currently practical challenges which make UK lamb exports unviable. To make the trade possible the UK Government must first update the required Export Health Certificate to make it fit for purpose. The NFU therefore calls on government to prioritise resolving this market access barrier by negotiating a revised EHC which will allow the UK sheep sector to benefit from the tariff reductions secured within this FTA.

13. There may also be new opportunities to export British infant formula milk to India as a result of this FTA. Currently exports of British infant formula to India face an MFN tariff rate of 50%. Under the terms of the FTA these products will face no tariffs when entering India, this materially improves British exporters’ ability to be competitive in the Indian market.

14. This FTA had the potential to create new opportunities for greater exports of British dairy products, oats and apples through the reduction of significant tariffs. For example, British apples exported to India are subject to a 50% tariff. It is disappointing that the UK Government has not secured greater access for any of these products, which were ultimately excluded from the Indian goods concessions.

Question 4. Which sectors will be exposed as vulnerable as a result of the deal? What are the trade-offs for UK industry and consumers?

15. The concern with this FTA is that the UK’s dairy markets have been liberalised yet again, this time in an agreement with the world’s largest dairy producing country. Under the terms of the agreement from its entry into force all Indian dairy products will be able to enter the UK tariff free. This is the third successive trade deal with major dairy producing countries, yet our dairy farmers will not see any greater access for British cheeses and dairy products onto the Indian market.

16. India is the world’s largest dairy producing nation, and whilst nearly all dairy production is currently consumed domestically in recent years there has been an increase in the number of private businesses operating in the Indian dairy sector. As the Indian dairy sector continues to transform and grow, so, some analysts predict, will their ability (and need) to export. Recent industry analysis forecast that milk collections in India will continue to grow at 4.5% per annum for the next five years, leading to an export surplus of Skimmed Milk Powder (SMP) of close to 100,000T by 2029.[4]

17. The cumulative impact of ever greater access to our domestic food markets cannot be overlooked and the NFU is clear that a precedent must not be set for the treatment of UK dairy within future trade negotiations.

Question 5. How might UK manufacturers gain or lose from the provisions on cumulation of origin? How, if at all, are UK consumers likely to benefit?

18. The NFU strongly supports rules of origin that encourage production within the territories. With regard to cumulation, this is more of a concern for the production of processed agri-food goods where there may be incentive to use cheaper raw materials. It is positive that this FTA features robust Product Specific Rules for agricultural products requiring most to be either wholly obtained, or to undergo a HS chapter change in order to confer origin.

Question 6. Has the Government adequately shielded sensitive sectors from competition?

19. It is extremely positive that the government has listened to our concerns around upholding the UK’s production standards and has safeguarded our most sensitive farming sectors by maintaining the current level of tariffs for imports of sugar, chicken, eggs and pork.

20. The exclusion of concessions on sugar has been a key ask of the NFU and NFU Sugar since negotiations with India began in 2022. India is a major sugar producer and, typically, a significant exporter. Its production is heavily dependent upon an extensive programme of subsidies, price guarantees and other direct support. The WTO (World Trade Organisation) ruled in 2021 that India’s sugar subsidy regime was illegal. However, with India having appealed against the ruling, and the WTO appellate body currently unable to process appeals, its illegal subsidy regime remains in place. It was therefore critical that the UK Government did not grant further market access concessions for Indian sugar.

21. During this FTA negotiation the NFU also raised significant concerns with government about the animal welfare standards in the production of poultry meat, eggs, and pork in India. It is therefore positive to see that the government has excluded chicken meat, eggs for human consumption, and pork from liberalisation within this FTA. However, the NFU notes that all other forms of poultry meat will be fully liberalised from the agreement’s entry into force. In the UK, poultry meat is produced to high animal welfare standards through a combination of legislative requirements (e.g. the Welfare of Farmed Animals (England) Regulations 2007), government codes of recommendations, and widely adopted farm assurance schemes which mandate additional standards and are routinely audited. The NFU is not aware of equivalent protections or standards for the production of non-chicken poultry meat in India.

Labour and environmental standards and human rights

Question 14: What is your assessment of the labour and environmental provisions in the UK-India FTA? Do these provisions offer sufficient safeguards to uphold workers’ rights and environmental protections, and do they ensure a level playing field for UK and Indian firms?

22. India does not appear to have domestic environmental requirements for agricultural production equivalent to those in the UK, which is concerning for British farmers in the context of a liberalising FTA. The NFU believes that to enable and support a thriving British agriculture sector it is crucial that the UK’s trade policy is consistent and compatible with our high domestic production standards and the ever-increasing environmental standards required from our domestic industry.

23. UK Government’s environmental ambitions, legislated for domestically, should be reflected in its engagement internationally. The government should therefore be using trade policy to incentivise high standards of production and climate-friendly farming models. We therefore support the inclusion of an environment chapter in the UK-India FTA but note that in some of these policy areas the UK already goes much further than India. We remain concerned about the import of products produced to lower standards which undermine our approach to protecting and enhancing the environment.

24. Whilst it is difficult to find precise information on the authorisations of plant protection products and active substances in India it is apparent that the UK has moved further away from more hazardous pesticides towards newer classes of chemistry that are less harmful to humans, animals, and the environment. For example, based upon a 2024 study of pesticide usage in India, the three most found residues in produce across India are active substances not authorised for use in the UK.[5] Even if residues of banned active substances are below the UK’s maximum residue levels or the limit of detection – to meet the UK’s phytosanitary import requirements - this does not mean that the Indian crop was not grown using those actives, potentially putting UK growers at a competitive disadvantage.

Devolution

Question 17: What is the potential impact of the agreement on the devolved administrations and their responsibilities?

25. As discussed in response to Q4, the NFU is concerned that this deal has liberalised the UK’s dairy market to the largest dairy producing country in the world whilst also achieving no greater access for British cheeses and dairy products into the Indian market. If, in the longer term, the cumulative liberalisation of the UK dairy markets to significant international competitors negatively impacts the domestic industry this will be felt disproportionally in Wales due to significance of dairy farming to the Welsh rural economy.

26. In 2024, the production of milk and milk products contributed £760 million to the Welsh economy[6], and the sector employs more than 5,200 people directly on Welsh dairy farms. The sector also supports a further 1,625 jobs beyond the farmgate[7] in Welsh milk processing and retailing, with 85% working full time. Further employment is supported in the allied industries, such as artificial insemination technicians, veterinarians, feed mills and merchants, all of which helps to support the prosperity of rural communities across Wales.

Concluding questions

Question 18: Are there any other aspects of the UK-India FTA that could be of concern for UK manufacturers, producers and consumers, and for UK interests in general?

27. It is positive that the UK Government has upheld the UK’s high food safety standards within this FTA, however the NFU continues to be concerned that there is a risk that the FTA’s wide-ranging tariff liberalisation could lead to an increase in the volume of food imported into the UK from India. Some of which may have been produced to standards different to those legislatively required of domestic farmers and growers.

28. It is disappointing that there is no conditionality attached to the market access concessions made within the FTA, which could have prevented further agri-food imports produced to different production standards from entering the UK tariff free. Should UK farmers face increased import competition, this could further pressurise the UK market and impact upon farm business profitability in the future.

29. The NFU believes that it is unreasonable for government to demand ever-increasing production standards from our farmers and growers while allowing product to be sold on our market that fails to meet equivalent production standards. Given that competition from imports, including from India, can influence UK agricultural markets, the NFU calls upon government to begin a formal process of developing and establishing a set of core production standards that apply to all agri-food marketed in the Uk including imports.             

14 October 2025