Alternative Proteins Association (APA) – Written Evidence (DYN0018)

(APA) – Dynamic Alignment Call for Evidence

Written Evidence to the House of Lords European Affairs Committee

Inquiry into Dynamic Alignment

Submitted by the Alternative Proteins Association (APA)

April 2026

Introduction

The UK has put over £320 million in private capital, and considerable public funding, into becoming a global leader in alternative proteins. It is now being asked to align its regulatory framework with an EU system that is stalling in food tech regulation and innovation - the EU has explicitly excluded novel foods from its own regulatory sandbox provisions, and one member state has banned cultivated meat outright.

The Alternative Proteins Association represents the UK’s alternative protein sector. Including plant-based proteins, precision fermentation products, and cultivated meat. We are a UK industry body, and we work closely with government, regulators, research institutions, and other organisations who have aligned work streams on food systems transformation, to support the responsible growth of this sector.

We welcome this inquiry and the Committee’s aim of informing Parliament about the policy and institutional issues arising from dynamic alignment. Our response focuses on what dynamic alignment would mean for alternative proteins and novel foods in practice, and what the UK stands to lose if the scope is not drawn carefully.

Our central concern is that the UK–EU SPS agreement, as currently scoped, includes EU Regulation 2015/2283 on novel foods.[1] If novel foods are subject to dynamic alignment without exemption, the UK will be required to subordinate its own regulatory framework to the EU’s. This would undermine years of public investment in UK regulatory innovation and jeopardise a sector that could provide serious growth opportunities. It would also weaken the UK’s food security position at a time when supply chains are under serious strain.

Question 1: “What is dynamic alignment? How does dynamic alignment operate under EU agreements with non-EU countries other than the UK?”

We offer a sector-specific illustration. For alternative proteins, dynamic alignment does not simply mean adopting an existing body of EU law. It means committing to adopt future EU regulatory decisions in a policy area where the EU is actively moving in a more restrictive direction.

Three developments illustrate this. First, the EU’s Biotech Act (2025) explicitly excludes novel foods from regulatory sandbox provisions[2]. This is the opposite of the UK’s approach, where the FSA’s Cell-Cultivated Products (CCP) Regulatory Sandbox is the centrepiece of the government’s strategy. Second, the EU has provisionally agreed to restrict the use of 31 animal-associated terms (such as ‘beef’, ‘chicken’, and ‘steak’) for cultivated and plant-based products, despite evidence that such labelling is necessary for allergen disclosure. Third, the EU has approved zero cultivated meat products to date, while other countries including Singapore have moved ahead.

The pattern extends beyond cultivated meat. The UK’s Genetic Technology (Precision Breeding) Act is now fully operational, with £21.5 million awarded to 15 precision breeding projects in February 2026 and commercial products expected on shelves by late 2026. The EU has not yet finalised equivalent rules. The FSA has also launched a Precision Fermentation Business Support Service pilot, providing early-stage regulatory guidance to fermentation companies. In each case, dynamic alignment would require the UK to step back from a framework it has already built and is already using.

Dynamic alignment in this context means locking the UK into a regulatory trajectory that is slower, more politically contested, and increasingly hostile to the technologies the UK has invested in. This is not alignment with a stable framework. It is aligning with a system heading in a direction that diverges from the UK’s own regulatory strategy.

Question 3: “Can formal ‘decision-shaping’ by non-EU states, under agreements with the EU, deliver real influence over the EU law to which it applies? If so, what institutional arrangements and resources should the UK Government have in place—in London, Brussels and national capitals around Europe—to ensure that it can participate in EU ‘decision-shaping’ as effectively as possible?”

For fast-moving sectors like novel foods, we are sceptical that formal decision-shaping mechanisms can deliver meaningful influence over EU regulatory outcomes. The EU’s internal politics around cultivated meat and precision fermentation are deeply contested. Italy has enacted a domestic ban on cultivated meat production. A member state has outlawed the very product the UK is preparing to approve, and the EU framework permits this. Several other member states have aligned with opposition to novel food technologies. The EU’s own Strategic Dialogue on the Future of Agriculture has been subject to significant political pressure from incumbent agricultural interests.

In this environment, it is unrealistic to expect a non-member state, participating through a consultative mechanism, to materially shape outcomes on issues where EU member states themselves cannot agree. The UK’s most effective tool for influencing global regulatory standards here is not decision-shaping within the EU but leading by example through its own independent framework. The FSA’s CCP Sandbox has attracted international recognition and is being studied by regulators in other jurisdictions as a model. Aligning with the EU would surrender precisely the asset that gives the UK influence.

Question 4: “Are current arrangements for parliamentary scrutiny of UK-EU relations adequate for scrutinising dynamic alignment? What would an ideal system for parliamentary scrutiny of UK dynamic alignment comprise?”

Dynamic alignment in novel foods creates a particular scrutiny challenge. The UK’s regulatory sandbox programme is an active, resourced, public-interest innovation in food regulation that Parliament has supported through funding and legislative framework. The FSA received £1.6 million to deliver the CCP Sandbox, and DEFRA, DSIT, and DBT have all participated in its governance. The £184 million Engineering Biology Infrastructure Programme, announced in 2025 as part of a broader £380 million engineering biology investment, is predicated on the UK maintaining an independent regulatory pathway.[3]

Parliament has endorsed and funded an independent regulatory programme for novel foods. If dynamic alignment sweeps novel foods into EU rules without Parliament specifically choosing that outcome, the programme gets reversed as a side effect of a broader trade deal rather than through any deliberate legislative choice. In practice, the executive would be undoing through negotiation what Parliament built through legislation.

Question 5: “What impact are the three new UK-EU agreements that are currently in prospect likely to have on UK GDP? (the three agreements being on: the creation of a Common Sanitary and Phytosanitary (SPS) Area; the linkage of the UK and EU Emissions Trading Schemes (ETSs); and UK participation in the EU’s internal electricity market)”

We acknowledge that the SPS agreement is expected to deliver GDP benefits through reduced trade friction for conventional agri-food products. We do not dispute this. However, the aggregate GDP assessment must account for the innovation costs of blanket alignment in sectors where the UK holds a competitive advantage.

The UK alternative proteins sector has attracted over £320 million in private investment, the second-highest level in Europe. Oxford Economics projects that cultivated meat alone could add £2.1 billion to the UK economy by 2030.[4] Green Alliance estimates the broader sector could be worth £6.8 billion annually and create 25,000 jobs by 2035, with at least 4,000 of those in farming and food production.[5] The global precision fermentation sector represents a $100–150 billion opportunity in new ingredients by 2050.[6]

These projections depend on the UK maintaining a regulatory environment that enables commercialisation. If alignment extends approval timelines by the 18–36 months implied by EU precedent, the UK loses its first-mover advantage and the investment case weakens. Companies and investors making jurisdiction decisions now are watching the SPS negotiations closely. We have personally heard about companies reconsidering their commitment to the EU regulatory framework on this basis.

Beyond the direct economic case, there is a significant food security dividend. When adjusted for imported animal feed, the UK’s true self-sufficiency in meat drops from the headline 85% to just 57%.[7] A 20% substitution of factory-farmed chicken and pork with alternative proteins could bring UK protein self-sufficiency to 106%. In a period of rising geopolitical instability and biosecurity threats (including 491 bird flu outbreaks in 2021–2022 and recent reports of ASF-infected meat entering UK supply chains), alternative proteins represent near-term resilience infrastructure, not speculative technology. A recent CSIS analysis places food biotechnology alongside semiconductors and AI as strategic national priorities.[8]

Question 6: “To what extent are the drawbacks and benefits of these prospective agreements for the UK, including with respect to GDP, likely to depend on their precise terms—for example, with respect to the scope and operation of, and exemptions from, dynamic alignment?”

The evidence above shows what the UK stands to lose in investment, food security, and global regulatory standing. The question is what to do about it. The benefits and costs of the SPS agreement for the UK depend critically on whether novel foods regulation is subject to dynamic alignment or carved out.

The EFRA Committee's February 2026 report recommended specific exemptions from dynamic alignment for precision breeding and animal welfare standards.[9] The Committee’s reasoning was that the UK had moved first and built a competitive advantage, and should not be required to align downward with a framework that would eliminate it. The same logic applies with equal force to novel foods and cultivated meat, where the UK's regulatory sandbox programme is internationally recognised and no EU equivalent exists.

We acknowledge the administrative trade-off: carve-outs add complexity to the agreement and require clear boundary definitions. However, this is manageable and precedented. Switzerland's SPS arrangements with the EU include sector-specific exemptions. The EFRA Committee has already endorsed the principle. The government has itself acknowledged that the agreement includes 'a short list of limited exceptions'. Novel foods should be on that list.

Without a carve-out, the UK does not just adopt a different regulatory approach, it risks eroding what has been built. The FSA’s CCP Sandbox, the Precision Fermentation Business Support Service, the Innovation Research Programme, NAPIC, CARMA, the Bezos Centre for Sustainable Protein at Imperial College: these represent years of coordinated public and private investment.

The significance of this goes beyond protecting what the UK has already built. The EU is actively pushing innovative food companies away. Its Biotech Act excludes novel foods from sandbox provisions. Its labelling restrictions create market barriers. Its approval pathway has produced zero cultivated meat authorisations. The UK has built precisely the regulatory infrastructure these companies need, and has the opportunity to become a regulatory safe harbour, attracting innovators whom the EU framework is driving out. This is not speculative: the FSA’s CCP Sandbox already includes participants from the Netherlands, France, and Australia alongside UK companies, drawn by the FSA’s more collaborative and proportionate approach. Dynamic alignment without exemptions would close that door.

Our preferred outcome is a permanent carve-out for novel foods from dynamic alignment. However, if that is not achievable, we would urge the Committee to recommend, at minimum, a time-limited exemption which allows sufficient time for regulatory approval as well as commercial runway to understand market feedback better. A carve-out period of approximately five years should offer such a benefit.

Question 8: “What are the implications of the three prospective agreements with the EU, and of the Government’s general policy of dynamic alignment with the bloc, for the UK’s trade relations with countries outside the EU—with respect especially to the United States, and the UK’s membership of the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP)?”

Dynamic alignment with EU SPS rules has significant implications for the UK’s trade relationships with countries outside the EU, particularly in alternative proteins.

The USDA Foreign Agricultural Service has noted that UK regulatory alignment with the EU could constrain flexibility in negotiating agricultural chapters of other free trade agreements, particularly with the United States. Singapore has already approved three cultivated meat products; the EU has approved none. If the UK aligns with EU novel foods regulation, it locks itself into a slower approval pathway at a time when other markets are moving ahead.[10]

This matters for two reasons. First, UK companies developing products through the FSA's sandbox may find that their UK-approved products cannot be easily exported to markets with different regulatory frameworks, because the underlying regulatory basis has shifted from the UK's independent approach to the EU's. Second, the UK loses its ability to pursue bilateral regulatory recognition agreements with faster-moving jurisdictions. Singapore's approach has demonstrated commercial success, having approved three cultivated meat products, but has been criticised for a lack of transparency and business support during the approvals process. The FSA, by contrast, has been widely praised for its collaborative approach, and is now pursuing desk-sharing arrangements with Singapore's food authorities. An independent UK regulatory framework would allow these relationships to strengthen and enable mutual recognition; alignment with the EU would constrain that.

The UK’s membership of the CPTPP makes this particularly significant. CPTPP provides a framework through which the UK could pursue mutual recognition of novel food approvals with Singapore and other member states with advanced regulatory systems. Dynamic alignment with the EU would constrain the UK’s ability to use that framework for novel foods. More broadly, the UK’s food security and economic interests are not exclusively oriented toward Europe. In a period of global realignment, maintaining regulatory flexibility to trade with non-EU partners on terms suited to the UK’s own strengths is a strategic asset. The alternative proteins sector is a case study of why that flexibility matters: the growth markets for these products are global.

Question 10: “What actions need to be taken and arrangements put in place—in legal, institutional and practical terms—before UK dynamic alignment under the three prospective agreements is operating fully and smoothly? How long might this process take?”

There is a direct timeline collision between the SPS agreement and the UK's novel foods regulatory programme. The FSA's CCP Sandbox is targeting completion of safety evaluations for cultivated meat by February 2027.[11] The government's target for SPS agreement implementation is mid-2027. If alignment takes effect at that point and novel foods are within scope, the sandbox programme would lose its potential for major impact just as it reaches key milestones.

If neither a permanent carve-out nor a time-limited exemption is secured, continued regulatory resource must be supplied for business support services that can help newly emerging alternative protein businesses navigate whatever framework applies.

We are not asking for special treatment. The principle is the same one the EFRA Committee endorsed for precision breeding: where the UK has moved first and built a genuine competitive advantage, that advantage should not be sacrificed as a side-effect of an agreement designed to facilitate conventional food trade.

Conclusion

The SPS agreement offers real benefits for the UK–EU agri-food trade. We do not oppose it. But its value to the UK depends on getting the scope right. Novel foods regulation is an area where blanket alignment would cost the UK more than it gains, in investment, innovation, food security, and global competitiveness. A permanent carve-out for novel foods is our preferred outcome. A time-limited exemption of at least five years is the minimum that would protect existing public and private investment. Either is feasible, precedented, and consistent with the government’s own stated ambitions for the UK as a science and innovation leader. We welcome the opportunity to provide further oral or written evidence to the Committee.

Received 16 April 2026

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