The Charges for Residues Surveillance Amendment (Scotland) Regulations 2026: final business & regulatory impact assessment (BRIA)

Section 1: Background, aims and options

1.1 Background to policy issue

The proposals amend The Charges for Residues Surveillance Regulations 2006 to vary the fees required to be paid in relation to surveillance of animals and animal products for residues of veterinary medicinal products and other substances.

The VMD is an Executive Agency of the Department for Food, Environment and Rural Affairs (Defra) and works in close partnership with the Scottish and Welsh Governments to deliver the NRCP in Great Britain.

The NRCP is a statutory industry-funded programme that is delivered by the VMD and helps to protect human health by taking samples of meat or other animal products to test for unsafe levels of residues of veterinary medicines, or other prohibited substances which may be harmful. The NRCP helps to provide assurances about the safety of food products, and by doing so also supports UK food exports worth approximately £12 billion to the UK economy. The NRCP conforms to international standards which are underpinned by the World Trade Organization agreement on sanitary and phytosanitary measures.

The programme operates on a full cost recovery basis, so each of the livestock sectors that take part are invoiced each year. The programme currently costs approximately £6.6 million per annum, and this is forecast to reach approximately £7m per annum by 2028. This is due to a rise in the costs of procured services which are necessary to deliver the programme such as sampling, testing, and consumables. Without the revisions to the current charges that industry pays, it is forecast that there will be an under recovery of the costs of the programme by £1m in the current financial year, and the deficit would be expected to rise further in future years. If action were not taken to address this issue, we run the risk of further deficits and facing a recovery of costs being sought from the VMD.

The proposals are compatible with the Scottish Government’s second priority, Growing the Economy, helping deliver the NRCP on a full cost recovery basis that continues to provide assurances on food safety and supporting food exports.

1.2 Current position – before proposed changes

The proposed changes are necessary to return the programme to a full cost recovery basis for the 2026-27 financial year and onwards. This full cost recovery approach means that the regulated bear the cost of regulation, as well as ensuring the VMD does not profit from fees or make a loss which must then be subsidised by Defra of wider Government.

There are currently no existing policies that could address this issue, and no other reliable options are available if the Scottish Government intends to meet cost recovery principles alongside their government counterparts. No other policy changes are being considered in other areas of the Scottish Government that could help address this problem.

The Scottish Government, Welsh Government and the VMD regularly monitor the delivery of the programme and publicly consult when revisions to charges are considered necessary. Stakeholder engagement via a joint public consultation was launched on 24 November 2025 and ended 19 January 2026.

1.3 Types of Business, Economic Sector, Groups or Communities that could be affected by the issue and its proposed solution

Livestock sectors involved in the NRCP, who are invoiced each year by the VMD, are directly affected by the update to fees associated with the surveillance programme. No specific size of business is singled out or impacted by these changes, it would apply to all food business operators (independent of size) within each of the livestock sectors that take part in the NRCP. Similarly, this is not a location-specific proposal and the changes would apply to all Scottish businesses involved in the programme as it is UK-wide.

Consumers, primary producers, or others within the supply chain could be indirectly affected, dependent on whether additional costs due to increased rate charges are absorbed or transferred down the chain.