Food law | UK Regulatory Outlook September 2025

Food Standards Agency launches consultation on first proposed CBD food product authorisations 

The Food Standards Agency (FSA) has launched a public consultation on proposed recommendations to authorise the first cannabidiol (CBD) food products as novel foods in Great Britain. Specifically, the FSA is considering issues that arise as a result of the first three novel food applications to have progressed through the initial safety assessment stages. 

The consultation consists of 14 questions and is open until 20 November 2025.  

UK government outlines timetable for UK-EU SPS agreement 

Following agreement between the UK and EU in May 2025 to agree a new sanitary and phytosanitary (SPS) agreement, on 27 August 2025 EU relations minister Nick Thomas-Symonds laid out more details on the timetable for codification and implementation during a speech. The plan is for there to be further negotiations with the EU in autumn 2025, with a view to UK legislation in 2026 and implementation in 2027. 

After the speech, the food security minister, Daniel Zeichner, and the minister for small businesses and exports, Gareth Thomas, visited small businesses to discuss the SPS agreement. The SPS agreement is expected to save businesses up to £200 per shipment of goods to the EU, by removing the requirement for Export Health Certificates. It is also expected that the agreement will see a lifting of the current EU ban on UK imports for fresh sausages and burgers, some shellfish, and seed potatoes. 

The SPS agreement, once implemented, will also mean that there will be no physical checks on GB food products at Northern Irish (NI) ports. As a large proportion of supermarkets in Northern Ireland are supplied from distribution centres in England and Scotland, the impact on the NI food market could be substantial. 

Reaction to the SPS has been broadly positive from industry, especially among smaller businesses that sell small batches of perishable goods. The NI reaction has also been positive, with the NI Chamber chief executive saying that the proposed deal "represents a significant step forward in addressing trade barriers". 

Department of Health and Social Care announces new baby food guidelines and labelling reforms 

On 22 August 2025, the Department of Health and Social Care announced new guidelines for commercial baby food to reduce salt and sugar, along with reformed labelling standards in a bid to increase clarity and help consumers make informed decisions. 

The voluntary guidelines outline a number of recommendations for salt and sugar levels in different product categories, from "main meals" to "soups, stocks and cooking sauces", and give baby food manufacturers 18 months from August 2025 to reduce the amounts of those substances in baby foods aimed at children up to 36 months old to the new levels.  

They also strongly encourage food producers to:  

• Label products in line with scientific and government advice to introduce solid foods at around six months of age.
• Provide honest labelling so that product names are not misleading and are aligned with the quantity of primary ingredients.
• Restrict inappropriate on-pack marketing and promotional statements that make "implied health claims" about health or nutritional benefits that are not based on scientific evidence.
• Have clear feeding instructions (for example "use a spoon" or "do not suck") on the front of products packaged in pouches with a nozzle.
• Not to label and market snacks or food products that can be eaten between meals as suitable for children aged 12 months and under (snacks for babies under the age of 12 months are not in line with government dietary guidelines). 

While voluntary, the government has stated that if businesses fail to implement the guidelines by February 2027, then the government will "consider additional or alternative measures" should businesses fail to implement the guidelines.  

Businesses manufacturing baby food and drink products should review the guidelines to identify where changes may need to be made to their products. 

Food and feed safety – simplification omnibus 

The European Commission has published a new initiative in line with its agenda to simplify regulatory frameworks across the EU in a bid to reduce regulatory burden on both businesses and Member States.  

Specifically, the initiative's goals will be to accelerate access to the EU market for biocontrol substances and products; to simply and clarify regulatory requirements on plant protection and biocidal products, feed additives, food hygiene and official controls; as well as other measures to simplify EU food law. 

A call for evidence has been launched proposing targeted simplification measures in several areas including: 

• authorisation and renewal procedures for plant protection products and biocidal products;  
• clarifications related to terminology and transitional measures for the setting of maximum residue levels for pesticides, the modification and renewal of authorisations, and labelling requirements for feed additives, including digital labelling options;  
• notification procedures for national hygiene measures;  
• flexibility in official checks of plant consignments at border control posts;  
• accreditation requirements for reference laboratories;
• clarification related to the legal status of fermentation products manufactured using genetically modified micro-organisms (GMMs); and
• more targeted pesticide application by drones under safe conditions. 

The consultation is open until 14 October 2025.  

Government launches consultation on the banning of high-caffeine energy drinks to children 

As part of its plans to tackle childhood obesity, the government has launched a consultation on the banning of high-caffeine energy drinks to children under the age of 16 to "provide them with a better and more prosperous future". 

The consultation includes the proposals for: 

• the minimum age of sale for high-caffeine energy drinks;
• the products and businesses in scope of the ban;
• how the ban will apply in vending machines;
• the length of time that businesses and enforcement authorities need to implement the ban; and  
• introducing a new power to allow enforcement by authorities through fines, as an alternative to criminal prosecution. 

The consultation closes on 26 November 2025. 

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

New brand advertising exemption regulations to come into force in January 

The Department of Health and Social Care has published its response and final proposed Advertising (Less Healthy Food and Drink) (Brand Advertising Exemption) Regulations 2025. These regulations provide an exemption for brand advertising from restrictions on less healthy food and drink advertising on television and online and are intended to reduce children's exposure to these products to tackle childhood obesity. 

The new regulations will come into force in the UK on 5 January 2026, with voluntary compliance encouraged from 1 October 2025. Implementation guidance will be issued by the Advertising Standards Authority before commencement. 

Please see Advertising and marketing for more.  

Future foods takeaway: Autumn 2025

How is the future of food changing? Read the first edition of our new quarterly newsletter which will bring you legal updates, regulatory developments and our Insights in relation to alternative protein products and the novel food sector. The first edition focuses on developments in the UK’s fast‑evolving regulatory landscape.

See our 'Preparing for the future of food' page for more detail.