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

Section 7: Options Considered and Recommended

7.1 Options considered initially (or so far if this is a Partial BRIA)

The Veterinary Medicines Directorate, in partnership with the Scottish and Welsh Governments, published a joint consultation on revised charges for the NRCP between 24 November 2025 and 19 January 2026. The consultation paper explained the methodology and rationale for setting the charges, including details about the individual cost elements, future projections, and how the VMD achieves value for money. It also stated that the only change to the NRCP would be to the charges paid by industry. The scientific methodology, and standards of the surveillance and testing regime are defined in separate legislation and remain outside the scope of these proposals. The consultation set out three options with a recommendation to pursue Option C.

Option A

Do nothing, with charges being maintained at current levels. This would have risked food safety and international trade obligations.

Option B

A flat rate 22% increase to the charges applied across all sectors taking part in the NRCP. This would have carried the risk of sectors cross-subsidising others.

Option C (preferred)

A specific percentage increase tailored for each industry sector based on their specific sampling plan and production levels.

Option A would not achieve full recovery of costs. This option would therefore threaten the viability of the NRCP which is necessary to help protect human health. The NRCP also supports exports of products of animal origin worth £12 billion to the UK economy, and this may become compromised without action. Option B would lead to disproportionate increases in fees for some sectors and ongoing under recovery of costs in others. There are varying production volumes and costs of sampling each sector so, in effect, some sectors would cross-subsidise others. Option C is considered to be the most appropriate and equitable option as it recognises that not all sectors have the same cost profile. This is due to the different sampling and testing arrangements, which are carefully decided each year based on risk assessments and other factors.

7.2 Recommendations / preferred options

In September 2025, the then Minister for Agriculture and Connectivity agreed to consult on the introduction of legislation to update the charges for residues surveillance.

As detailed above, a specific percentage tailored increase for each industry sector based on their specific sampling plan and production levels was identified as the most equitable and effective approach for returning the NRCP to cost recovery status in line with financial forecasts.

As a result, the Scottish, Welsh and UK Governments agreed to separately bring forward the necessary legislation to update the charges.