Food law | UK Regulatory Outlook April 2026

UK 

Government rejects transition period for UK-EU SPS Agreement 

The government has formally responded to the Environment, Food and Rural Affairs Committee's report on the proposed UK-EU Sanitary and Phytosanitary Agreement, rejecting the committee's recommendation to seek a 24-month transition period to assist agri-food businesses in adapting to new requirements. The government maintains that the agreement will take effect from mid-2027 and has committed to working with businesses to ensure a smooth transition, but without a formal lead-in period. 

The response also confirmed that the government will not pursue a veterinary medicines agreement alongside SPS negotiations, instead relying on recently launched schemes, and will seek a carve-out from dynamic alignment on animal welfare regulations to protect UK standards. 

On pesticides and precision breeding, the government supports consultation on pesticide regulations and maintains the UK's right to set its own rules, raising the prospect of further divergence from EU standards in these areas. England currently permits the release and marketing of precision-bred plants under the Genetic Technology (Precision Breeding) Regulations 2025, while the EU's equivalent regime remains more restrictive; England also uses looser definitions for what qualifies as a precision-bred plant, has no explicit labelling requirements, and no IP transparency requirements. 

For businesses across the agri-food supply chain, the rejection of a transition period increases the urgency of preparations ahead of the mid-2027 implementation date.  

FSA sets out plans to modernise food regulation 

The Food Standards Agency Board has agreed the scope of its Future of Food Regulation programme, which will develop proposals to strengthen the food regulatory system in response to a government request made at the 2025 Budget. 

The programme covers five areas:  

• enhancing the food business registration system;
• developing a national approach to regulation for large businesses such as major supermarkets, making better use of existing data and assurance systems alongside in-person inspections;
• improving guidance to local authorities and businesses;
• strengthening enforcement powers to enable swift and proportionate action; and
• making the display of Food Hygiene Ratings mandatory in England.  

The FSA has indicated that the reforms aim to help identify food safety risks more quickly while reducing unnecessary administrative burdens for businesses. The programme is at an early stage and the FSA will now engage with local authorities, consumers, businesses and industry bodies to shape its proposals. Large food businesses in particular should look out for opportunities to feed into that process. 

Government consults on overhaul of school food standards 

The government has launched a nine-week consultation on proposed reforms to the school food standards, the first update in over a decade. The proposals include banning deep-fried food entirely, restricting high-sugar "grab and go" options to less than a daily occurrence, and requiring fruit to replace sugar-laden desserts for the majority of the school week. New dedicated breakfast standards are also proposed, covering all breakfasts served by schools, with the aim of ensuring children begin the school day with food that supports learning, rather than high-sugar or high-fat options. 

For food businesses supplying schools, including caterers, food manufacturers and distributors, the proposed changes will require a review of existing menus, product lines and supply arrangements. A phased approach is proposed for secondary schools to allow time to develop recipes, update menus and train staff. The government is also consulting on a national enforcement mechanism, with full details expected in September 2026 and enforcement beginning in September 2027. 

The consultation closes on 9 June 2026.

Government consults on applying updated nutrient profiling model to food and drink advertising restrictions 

See advertising and marketing section. 

EU 

EU Council adopts new rules on gene-edited plants, bringing 2028 application into view 

The EU Council has formally adopted the new genomic techniques (NGTs) regulation, the latest step in a process ongoing since the Commission's 2023 proposals. The regulation now awaits formal adoption by the European Parliament before it enters into force, with most provisions expected to apply from mid-2028 following a 24-month transition period. 

The regulation establishes a two-tier system. NGT-1 plants, those considered equivalent to conventionally bred varieties, will benefit from a simplified regulatory pathway and will not require labelling, except for seeds and other reproductive material. NGT-2 plants, involving more complex genetic modifications, remain subject to existing GMO legislation, including mandatory labelling and authorisation requirements.  

On intellectual property, the adopted text introduces patent transparency measures for NGT-1 plants, requiring developers to disclose relevant patents in a public database, with an expert group to be established to monitor the effect of patents on the sector. 

For businesses with NGT products in development or in the pipeline for the EU market, the adoption by the Council confirms the direction of travel and the likely 2028 timetable. The two-year transition period is an opportunity to assess into which tier the products will fall and to start planning for the labelling, authorisation and patent disclosure requirements that will follow. 

New EU regulation strengthens cross-border enforcement against unfair trading practices in agri-food supply chains 

Regulation (EU) 2026/697, published in the Official Journal of the European Union on 20 March 2026, establishes an enhanced framework for cross-border cooperation between national enforcement authorities responsible for tackling unfair trading practices in business-to-business relationships in the agricultural and food supply chain. It enters into force on 9 April 2026 and will apply directly in all Member States from 10 September 2027, with no national transposition required. 

The regulation introduces a mutual assistance mechanism allowing authorities to request information and coordinate investigations across borders, and enables coordinated enforcement action where a widespread unfair trading practice is suspected in three or more Member States.  

Authorities are expressly empowered to act on their own initiative without requiring a formal complaint from a supplier, addressing the reluctance of suppliers to report abuses for fear of commercial retaliation. The regulation also extends its reach to buyers established outside the EU, who may be required to designate a contact person responsible for facilitating investigations. 

For food and agricultural businesses with cross-border sourcing or purchasing arrangements, the regulation materially increases enforcement risk. The 18-month implementation window before the rules apply should be used to review commercial practices and contractual terms for compliance with the Unfair Trading Practices Directive across all relevant jurisdictions, build capacity to respond to information requests from enforcement authorities, and assess whether non-EU sourcing arrangements require a designated EU contact person. 

European Commission abandons Sustainable Food Systems initiative 

The European Commission has officially abandoned its proposed Sustainable Food Systems initiative, which had been intended to establish general principles and obligations across the EU food system, including sustainability labelling rules, minimum criteria for sustainable public procurement of food, and governance and monitoring requirements. 

The initiative had attracted significant support through its public consultation but was sidelined for four years before being dropped entirely. Its abandonment leaves a gap in coherence between EU agriculture, health, climate and biodiversity policies, and the question of how to create a common framework for sustainable agri-food systems operating within planetary boundaries remains unaddressed. 

For food businesses operating across the EU, the absence of a harmonised framework means continued uncertainty on sustainability labelling and procurement standards at EU level.