Food law | UK Regulatory Outlook July 2025

Government set to repeal HFSS restrictions 

Earlier this month, the government published its NHS 10-Year Health Plan, setting out proposals to introduce significant changes in food law, most notably outlining its intention to repeal the legislation for volume price promotions and aisle placement of products high in fat, sugar or salt (HFSS). These measures were introduced by the previous government. The placement restrictions have been in force since 2022, and the volume price promotions are due to come into force in October 2025. 

However, with the government's plans to introduce "smarter regulation" focused on outcomes, it states that it "expect[s] to be able to repeal legislation restricting volume price promotions and aisle placement". No further information has been provided by it, but considering the implementation of the volume price restrictions is only three months away, we anticipate further details to be published soon.  

NHS 10-Year Health plan – other food law aspects  

In addition to its announcement on repealing the HFSS restrictions for volume price promotions and aisle placement, the plan also sets out a number of other changes affecting food law: 

• Mandatory nutritional info and health warnings on alcoholic drinks: the government plans to bring alcohol labelling in line with existing health and nutritional labelling requirements for tobacco, food and alcohol-free drinks.
• Mandatory health food sales reporting: this will apply to "all large companies in the food sector".
• Set new targets to increase the healthiness of sales: these targets will be enforced using the data collected from mandatory reporting. Targets will be mandatory but "companies will have the freedom to work out how to achieve the target, whether through reformulation, by changing their layout, introducing new healthy products or through changes to customer incentive and loyalty schemes."
• Update the nutrient profile model: the report notes that the current model categorising foods as more or less healthy is "plainly out of date".  

Businesses in this sector should closely monitor the forthcoming details that the government will publish regarding these changes. 

Government publishes food strategy for England 

On 15 July, the government published its food strategy, which it calls the "Good food cycle". It aims to "create a healthier, more affordable, sustainable, resilient food system." The strategy sets out ten priority outcomes which will help to deliver these aims. While only for England, the strategy states that it considers the UK food system as a whole and will help devolved nations with their own polices.  

Annex B of the strategy outlines the existing or ongoing policy areas which will contribute to delivering each of the priority outcomes: 

• Outcome 1: An improved food environment that supports healthier and more environmentally sustainable food sales. Policy areas include the 9pm watershed for less healthy food or drink advertising on TV and restrictions, on promotions of less healthy foods and food labelling (back of pack nutrition, front of pack voluntary traffic light, calorie content, allergy).
• Outcome 2: Access for all to safe, affordable, healthy, convenient and appealing food options. Policy areas include mandatory health sales reporting and targets to increase the healthiness of sales.
• Outcome 3: Conditions for the food sector to thrive and grow sustainably, including investment in innovation, and productivity, and fairer, more transparent supply chains. Policy areas include Precision Breeding Regulations, the FSA/ FSS Cell Cultivated Products Sandbox and the Circular Economy Strategy.
• Outcome 4: Food sector attracts talent and develops skilled workforce in every region. Policy areas include the Employment Rights Bill.
• Outcome 5: Food supply is environmentally sustainable, with high animal welfare standards, and waste is reduced. Policy areas include the Circular Economy Strategy and the Animal Welfare Strategy.
• Outcome 6: Trade supports environmentally sustainable growth, upholds British standards and expands export opportunities. Policy areas include Carbon Border Adjustment Mechanism.
• Outcome 7: Resilient domestic production for a secure supply of healthy food. Policy areas include UK Food Security Report and Precision Breeding Act.
• Outcome 8: Greater preparedness for supply chain shocks, disruption and impacts of chronic risks. Policy areas include Tariffs and Trade Deals (including UK-EU SPS Agreement) and Environmental Improvement Plan.
• Outcome 9: Celebrated and valued UK, regional and local food cultures. Policy areas include UK Geographical Indications Scheme delivery
• Outcome 10: People are more connected to their local food systems and have the confidence knowledge and skills to cook and eat healthily. Policy areas include Plan for Neighbourhoods and national curriculum.  

With a food strategy now established and key policy areas identified to support its implementation, it will be interesting to observe how the government advances these initiatives. Additionally, it remains to be seen if further regulatory reforms will be introduced to assist in achieving the strategy's objectives. 

FSA updates guidance encouraging CBD businesses to reformulate products 

Following new evidence published by the Food Standard Agency's (FSA) independent scientific advisory committees, the FSA is encouraging cannabidiol (CBD) businesses with applications on the public list to reformulate their food products to improve consumer safety. 

On 1 July 2025, the FSA published changes to the provisional acceptable daily intake (ADI) for an adult following the new evidence, the new levels being 10mg of CBD and 0.07mg of tetrahydrocannabinol (THC) per day. The FSA maintains that allowing businesses to "reformulate their products at this stage will make the authorisation process more efficient, while consumers will benefit from safer CBD products on the market." 

It is advising businesses to review product labelling to display the recommended CBD ADI limit and include key safety information, such as age restrictions (notably for under 18s to not consume CBD) and warnings for those who are pregnant, breast feeding or taking medications. 

Businesses with applications should review the updated guidance and make changes where necessary. 

'Not for EU’ label not to be introduced in GB

On 30 June 2025, the House of Lords debated the Marking of Retail Goods Regulations 2025, which would provide ministers with the power to introduce "Not for EU" labelling to agrifood products across Great Britain, as considered by consultation (as we reported in our February 2024 edition). 

Fewer than 30 members took part in the debate meaning that further debate will be required before the regulations move any closer to being implemented. Therefore, this change will not be implemented in the near future.  

The Food (Promotion and Presentation) (Wales) Regulations 2025: implementation guidance 

The Welsh government has published guidance on how the Food (Promotion and Presentation) (Wales) Regulations 2025 restricts “less healthy” products.  

In general, the regulations restrict the promotion of HFSS foods products by:  

• volume price;
• key in-store locations when retail stores are over 185.8 square metres; and
• free refills on certain drinks. 

These restrictions apply to medium and large businesses (with 50 employees or more) which are a "qualifying business" as described in the regulations. Businesses affected include: supermarkets, online food retailers (including those who sell any pre-packed food), and clothing stores that may sell pre-packed food.  

The regulations come into force on 26 March 2026. Businesses operating in Wales should review the guidance to determine whether they fall within scope of the regulations and to understand the impact of these changes on them.  

Commission proposes to ban on 'meaty' names for plant-based foods 

The European Commission has proposed that certain "meaty" names for products should be reserved for products exclusively derived from those meats at all stages of marketing. This will mean that plant-based alternatives will not be able to use such terms 

The proposal would ban 29 meat-related terms, several of which refer specifically to particular animal products (such as "beef" and "pork") but others that are more broadly associated with butchery (such as "chop" and "bacon"), from being used in relation to products that are not derived from animals.  

The full list of terms is as follows: beef, veal, pork, poultry, chicken, turkey, duck, goose, lamb, mutton, ovine, goat, drumstick, tenderloin, sirloin, flank, loin, ribs, shoulder, shank, chop, wing, breast, thigh, brisket, ribeye, T-bone, rump, and bacon. 

This is currently just a proposal and will need to be discussed and voted upon by the European Parliament and Council before it can be enacted. 

UK-wide Deposit Return Scheme to go ahead  

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