Food law | UK Regulatory Outlook November 2025

• A more flexible, risk-based approach to prioritising initial official controls of new food businesses, allowing the flexibility for local councils to triage businesses when they first register.  

• Greater use of alternative control methods, including, in some cases, remote assessments allowing local councils more choice to support more efficient use of resource.  

• Broadening the cohort of professionals who can undertake certain activities to support delivery of official controls in England and Wales to ensure that officers' expertise is dedicated to where it can have the most impact.   

• The introduction of the new Food Standards Delivery Model in Wales. This updates how local councils regulate food standards within food establishments in Wales. This was implemented in England and Northern Ireland in 2023.  

Companies should be aware of these changes and expect to see differences in local councils' approaches to enforcement from now on. 

Precision breeding regulations now in force 

The Genetic Technology (Precision Breeding) Regulations 2025 came into force on 13 November 2025 with government guidance on the releasing and marketing of precision bred plants released on the same date.  

These regulations set out the regulatory framework for precision bred plants to be used in food or feed, setting out the requirements for a food and feed marketing authorisation to allow the precision bred plants to be placed on the market. 

For more details on the regulations, please see our Insight.  

The introduction of these regulations mark a significant milestone for precision bred organisms in England by simplifying the pathway for businesses to bring these products to market.

Businesses looking to bring precision bred plants into the English market should familiarise themselves with this new framework in order to understand the process and requirements for placing these products on the market.  

EU

European Council authorises negotiations on EU-UK agri-food deal 

The European Council has formally authorised the European Commission to open negotiations with the UK on an agreement for a common sanitary and phytosanitary (SPS) area.  

The aim of the SPS agreement is to reduce the burden of trading agricultural products between the EU and the UK by aligning sanitary and phytosanitary rules. An SPS agreement would align Great Britain's standards with those of the EU, removing the need for most certificates and checks on animals, plants and related products moving between Great Britain and the EU. 

Through the Windsor Framework, these benefits would also apply to movements between Great Britain and Northern Ireland, while preserving Northern Ireland's dual access to both the EU single market and the UK internal market. 

Once negotiations are finalised, the agreement will require Council endorsement before entering into force.  

CJEU rules on the use of 'gin' to describe non-alcoholic beverages 

The Court of Justice of the European Union has ruled that a non-alcoholic beverage may not be sold under the name "gin", as that name is reserved for a specific alcoholic beverage under EU law. 

The case concerned a German association for combating unfair competition which brought an action against PB Vi Goods for an order prohibiting the company from selling a non-alcoholic beverage named "Virgin Gin Alkoholfrei" (non-alcoholic Virgin Gin). The association argued that the name is contrary to EU law, according to which gin should be produced by flavouring ethyl alcohol of agricultural origin with juniper berries, and the minimum alcoholic strength by volume must be 37.5%. 

The court found that there is a clear prohibition in EU law on presenting and labelling a beverage as "non-alcoholic gin", due to the beverage not containing alcohol and the fact that the legal name "gin" is accompanied by the term "non-alcoholic" is irrelevant. The prohibition does not prevent the product from being sold, but merely from being sold under the legal name reserved for gin. 

Those wishing to export from the UK to the EU will need to ensure they comply with the EU rules around the definition, description, presentation and labelling of spirit drinks and, while this judgment is not binding on the UK courts, the definition of gin between the UK and the EU is the same so manufacturers for the UK market should ensure they are not falling foul of this definition to avoid potential challenges, similar to that of PB Vi Goods, in the future.