Food law | UK Regulatory Outlook October 2025

UK 

HFSS volume price restrictions now in force  

From 1 October 2025, the government’s restrictions on volume price promotions for foods and drinks that are high in fat, salt or sugar (HFSS) are in force in England. Businesses within scope of the rules must not run volume-based price promotions on in-scope products. These include: 

• promotions that indicate an item (or any part of it) is free, such as “buy one, get one free”; and
• multibuy offers, such as “3 for 2”. 

Products in scope are prepacked foods and drinks that are assessed as HFSS or “less healthy” under the Nutrient Profiling Model and that fall within the categories listed in Schedule 1 of the regulations. 

To ensure compliance with the regulations, businesses in scope (particularly those in the retail sector) will need to ensure that promotions on these foods are not being made. 

FSA consultation on proposed bisphenol A, other bisphenols, and bisphenol derivatives ban 

On 2 October 2025, the Food Standards Agency (FSA) launched a consultation on the proposal to implement a ban on the use of bisphenol A (BPA), other bisphenols, and bisphenol derivatives in food contact materials (FCMs). The proposed ban is looking to ban all newly manufactured FCMs containing BPA or its analogue. FCMS include such as plastics (for example, reusable containers and kitchenware), varnishes and coatings (such as in metal cans), adhesives, printing inks, rubber, silicones, ion exchange and resins. 

The consultation does not seek to revisit the scientific consensus on BPA's risks, but to gather any further evidence that may justify an alternative approach to a full ban for BPA. The consultation also aims to identify any practical considerations with implementing a potential ban, or similar measures, including transition periods and/or potential exemptions. The consultation paper outlines that a transition period with the same end date to the EU regulation is being proposed in order to allow for a "smooth transition". 

The consultation runs until 24 December 2025 at 5pm and responses can be provided here. 

Businesses should review the consultation to determine whether they wish to respond.  

FSA launches new Market Access Innovation Research Programme 

The Food Standards Agency (FSA), in collaboration with Food Standards Scotland (FSS), has launched its Market Authorisation Innovation Research Programme (IRP), including a new guidance hub and pilot for Precision Fermentation Products. 

The FSA’s IRP is a one year, government funded initiative to strengthen UK regulators’ capability and specialist expertise for innovative food technologies, with a focus on precision fermentation. Precision fermentation adapts traditional fermentation by bioengineering microorganisms (such as yeast or bacteria) to produce specific food components, proteins, sugars and fats. Some precision fermented ingredients are already authorised and in use (for example fats in Omega3 oil supplements), but applications are becoming more complex (such as dairy proteins for milk alternatives). This creates new regulatory challenges that the IRP aims to address. 

The programme complements the sandbox for cell cultivated products and aims to increase scientific knowledge to assess the safety of innovative foods as well as providing practical support to industry on applying for market authorisation in Great Britain.  

EU  

MEPs back changes to reserve meat terms for meat products  

The European Parliament has adopted its mandate for negotiations with Member States on amendments to Common Agricultural Policy (CAP) laws. 

As reported in our July issue, part of this proposal is to ban certain meat terms for products which are not exclusively derived from that meat. This will mean that plant-based alternatives will not be able to use such terms. In its proposal, the European Parliament has introduced a new definition of meat as “edible parts of animals” and specified that names such as steak, escalope, sausage or burger must be reserved exclusively for products containing meat and excluding cell-cultured products. 

MEPs are also backing clearer labelling and advertising rules, including criteria for terms like “fair” and “short supply chain,” and require that the latter only be used for EU‑produced goods with limited intermediaries or distance. New import provisions would allow entry of food and feed only if pesticide residues are below EU maximum residue levels; public procurement should prioritise EU‑origin, local and seasonal products with priority for geographical indications.  

Businesses that place meat alternative products on the EU market should closely monitor the proposal and, if it is adopted and enters into force, ensure their products comply with the new requirements.