EU laws have exerted a powerful influence on research, manufacturing, supply, sale and procurement of the products on which national health systems rely. Pre-Brexit, the UK was closely involved in the policy and operation of regulations affecting these goods. Since Brexit, ideological polarisation and the political salience of health during a global pandemic have driven a rhetoric of competitive divergence. However, active UK policy divergence to date is limited. It is unsettled whether the UK, as a small market in this global industry, genuinely seeks a higher risk, more industry-friendly regulatory paradigm. With regulatory and policy capacity also under strain, important decisions have been delayed. The position of Northern Ireland remains highly precarious, with negotiations ongoing on how to handle its unique partial status within the single market. The UK’s attempt to remain within the EU’s research funding programme has consequently been pushed into involuntary divergence.