15. Annex I – Summary of Call for Evidence Responses
Alliance to Save Our Antibiotics (ASOA):
ASOA raises serious concerns about the impact of the UK-India FTA on antibiotic resistance, highlighting stark differences in farm antibiotic regulation between the UK and India. The submission notes that India permits widespread use of antibiotics for growth promotion in animals and crops, including substances banned in the UK. ASOA warns that lifting tariffs on Indian dairy imports could undermine UK standards, especially given the high use of critically important antibiotics in Indian dairy herds. The FTA’s failure to require minimum standards for antibiotic use in imported products is seen as a major weakness, risking reversal of UK progress in responsible antibiotic use and contributing to the global spread of antimicrobial resistance.
Dairy UK:
Dairy UK expresses concern that the elimination of UK import tariffs on Indian dairy products under the FTA could pose a threat to human health. The Indian dairy sector currently lacks an approved residues monitoring plan, a requirement under retained EU law, and has poor production standards due to its fragmented structure. Dairy UK warns of commercial pressure on India to gain export eligibility and urges close scrutiny of any proposed supply chains. It stresses the importance of defending UK SPS standards and criticises the Indian sector’s misuse of antibiotics. The submission calls for robust enforcement of UK SPS rights and rejection of any Indian applications that fail to meet traceability and safety standards.
British Retail Consortium (BRC):
The BRC supports maintaining UK standards under the FTA and emphasises the importance of authenticity, quality, and safety in food imports. It highlights the role of UK retailers in upholding production standards through audits and certifications, beyond government checks. The submission underscores the need for continued surveillance of commonly imported commodities like spices, with collaboration between UK and Indian authorities. While generally supportive of the FTA, the BRC stresses that high standards must be preserved and that retailers are committed to ensuring compliance through their supply chains.
Fera Science Ltd (Fera):
Fera welcomes the FTA for its potential economic benefits but raises serious concerns about food safety and biosecurity risks associated with increased imports from India. It highlights a long-standing pattern of border rejections of Indian food products due to pesticide residues, mycotoxins, and other contaminants. Fera stresses the need for enhanced UK testing infrastructure to manage the anticipated rise in high-risk imports, particularly spices, processed foods, and aquaculture products. It questions the reliability of Indian safety certification systems and calls for assurances that UK standards will be upheld through robust surveillance and testing capacity.
British Egg Industry Council (BEIC):
BEIC warns that the UK–India FTA could undermine the UK's high food safety standards, particularly in relation to eggs and egg products. It emphasises the success of the British Lion scheme in reducing salmonella risk and calls for imports to meet equivalent standards. BEIC expresses concern over the rise in salmonella outbreaks linked to imported eggs from countries like Poland and Ukraine, and fears similar risks from Indian imports. It advocates for clear labelling of origin and production standards, and urges that only products from systems legal in the UK be allowed. The submission calls for robust risk assessments and stakeholder consultation before any regulatory changes.
Farmers’ Union of Wales (FUW):
FUW’s submission highlights the disparity in production standards between the UK and India, including the use of antibiotics for growth promotion, banned pesticides, and intensive farming practices. It argues that these differences give Indian imports an unfair advantage and pose risks to food safety, animal welfare, and environmental sustainability. FUW criticises the lack of enforceable “red lines” in the FTA and warns that the agreement could undermine UK efforts to reduce agricultural emissions. It calls for statutory protections to be embedded in trade agreements and urges the UK Government to ensure robust border checks and alignment with EU standards to protect domestic producers.
National Farmers’ Union (NFU):
The NFU expresses concern that while the UK–India FTA does not directly alter UK food safety legislation, its tariff liberalisation could lead to increased imports produced to lower standards. It criticises the lack of conditionality on market access and warns that this could undermine UK farmers and pressure domestic standards. The NFU highlights disparities in animal welfare, antimicrobial resistance controls, and environmental protections between the UK and India. It notes the absence of an ambitious animal welfare chapter and raises concerns about the potential for Indian dairy and poultry products to enter the UK market despite being produced under less stringent standards. The NFU calls for robust scrutiny of equivalence claims and stronger alignment between trade policy and domestic production standards.
National Sheep Association (NSA):
The NSA raises concerns about inconsistent enforcement of food safety standards in India, despite the existence of the Food Safety and Standards Authority of India (FSSAI). It flags specific risks including the use of banned substances like bromates, formalin, and carbides, and calls for UK testing and certification of Indian food producers. The NSA also highlights issues with cold chain management, antibiotic overuse, and inadequate labelling for nutrition and allergens. The submission urges the UK to ensure Indian imports meet the same high standards as domestic products to protect public health and industry integrity.
Pesticide Action Network UK (PAN UK):
PAN UK warns that food imported from India may contain pesticide residues at levels far exceeding UK limits, including substances banned in the UK. It provides examples of significant discrepancies in Maximum Residue Levels (MRLs) for hazardous pesticides and criticises the UK’s limited border and domestic testing capacity. PAN UK argues that Chapter 6 of the FTA undermines UK protections by promoting equivalence with weaker Indian standards and failing to uphold the precautionary principle. It also warns that the SPS Subcommittee could allow pressure from India’s agrochemical industry to weaken UK regulations. PAN UK calls for stronger safeguards to prevent contaminated food from entering the UK and protect consumer health.