Food law | UK Regulatory Outlook September 2026

UK

FSA Board backs plans to overhaul food safety regulation, including national scrutiny of the largest retailers

The Food Standards Agency (FSA) Board has agreed to move ahead with designing detailed reforms to the food safety system under its Future of Food Regulation programme, following engagement with over 1,200 stakeholders across the UK.

The plans include strengthening local authority food teams' tools and enforcement powers, improving food business registration, applying a more consistent national approach to scrutinising the very largest food businesses, better use of supply chain data, and making it compulsory to display food hygiene ratings online across the UK, and in shops and restaurants in England.

In the autumn 2025 Budget, the government asked the FSA to develop proposals for a national system of regulation for large food businesses in England, starting with major retailers. The board has previously agreed that this approach has the potential to strengthen oversight and improve visibility of risk across the sector, and plans for this approach will now be designed in further detail. The vast majority of food businesses, over 99.5%, are micro, small and medium businesses, but over 97% of food sold in shops comes from 10 national retailers with extensive global food supply chains. A recent FSA trial with retailers demonstrated that national level scrutiny of their data could be used to identify food safety issues and risks at a systemic level, alongside checks on the ground.

The programme will return to the FSA Board in March 2027 with developed proposals for the whole system, followed by a public consultation later in 2027.

FSA publishes policy paper on its approach to economic growth

The FSA has published a policy paper setting out its approach to supporting economic growth while safeguarding public health and consumer protection in food regulation across England, Wales and Northern Ireland. It states it has delivered regulatory action plan pledges made in March 2025, including new risk-based approaches to local authority food regulation. It has also been formally designated as competent authority for recycled plastics in Great Britain. It also points to completion of six inward trade audits from the EU, South Korea and the USA, and publication of the UK's first safety guidance for cell-cultivated products.

The FSA has agreed five economic growth goals with the Department of Health and Social Care (DHSC). These cover supporting delivery of a UK-EU sanitary and phytosanitary (SPS) agreement, a new national approach to regulating large food businesses in England, and a regulatory sandbox programme for cell-cultivated products. The remaining two goals cover greater use of data and AI in regulatory work, and support for DHSC's 10-Year Health Plan commitment to introduce healthier food targets and reporting.

The goals signal where FSA attention and resource are likely to concentrate over the coming months.

Origin and 'true' claims under scrutiny: UK tribunal ruling and EU Parliament briefing both test the limits of what 'origin' labelling protects

Two recent developments test where the legal concept of "origin" starts and stops when it comes to consumer-facing claims, one in a UK tribunal ruling on a geographical indication (GI), the other in a European Parliament briefing on customs-based origin claims.

In the UK, campaign groups Animal Equality and Wildfish challenged the Department for Environment, Food and Rural Affairs (Defra)'s decision to approve a non-minor amendment to the Protected Geographical Indication (PGI) for "Scottish Farmed Salmon," which removed the word "farmed" so the PGI would read "Scottish Salmon".

The appellants argued this was likely to mislead consumers as to the product's true origin, contrary to Article 6(2) of the Assimilated Regulation 1151/2012, because removing "farmed" obscured the product's method of production. The tribunal dismissed both appeals, finding that "true origin" under Article 6(2) refers only to geographical origin, not method of production, so removing "farmed" could not mislead consumers as to true origin. It separately confirmed that consumer and animal welfare organisations, not just competing producers, have standing to bring such challenges.

For businesses holding or relying on geographical indications, this confirms that production-method claims (such as farmed versus wild) sit outside the protection Article 6(2) offers against misleading "true origin" claims, only geographic origin claims are protected on that basis. Advocates for Animals, who acted for Animal Equality, have indicated an intention to appeal, so the point may not yet be settled.

At EU level, a European Parliament briefing has raised a related but broader concern: that the customs concept of origin, based on where a product undergoes its "last substantial, economically justified processing or working" is increasingly relied on to support consumer-facing origin claims despite being designed for a different purpose (determining a good's economic nationality for customs and trade purposes, not informing consumers where a product is genuinely made). The briefing finds this mismatch means a product can lawfully claim a given origin even where most of its actual production occurred elsewhere, while products incorporating substantial local expertise and inputs can fail to qualify for that origin, because the sole test is where final substantial transformation occurred, a distortion the briefing says can disadvantage businesses making accurate claims against those structuring supply chains for a favourable label.

This highlights a specific enforcement gap. Current systems catch unlawful misrepresentation but not lawful ambiguity, where a business fully complies with customs origin rules while still creating what it calls an "economically incomplete impression" of where a product is made. Rather than proposing new legislation, the briefing recommends a targeted programme of regulatory clarification, including clearer guidance on voluntary origin claims, stronger coordination between customs, consumer protection and market surveillance authorities, more consistent enforcement, and targeted support for smaller businesses.

Read together, both developments point the same way: regulators and tribunals are increasingly willing to draw a sharp line around what "origin" legally means, geography under the UK's GI regime, customs-based economic nationality under EU rules, while leaving related claims about production method or true economic value largely unprotected or unmonitored.

Businesses making "Made in," geographical, or origin-based claims on internationally sourced, assembled or processed products should treat technically accurate claims that diverge from consumer expectations as a growing area of reputational and future-regulatory risk, even where current enforcement gaps mean they are not yet unlawful.

Windsor Framework inquiries: end-of-life vehicles and food supply chain

See sustainable products section.

EU

EU bans certain meat names for plant-based products

Regulation (EU) 2026/1739, amending the Common Agricultural Policy framework to strengthen the contractual position of farmers in the food supply chain, was published in the Official Journal of the European Union on 29 July 2026 and entered into force on 18 August 2026.

It amends Regulations (EU) 1308/2013, (EU) 2021/2115 and (EU) 2021/2116, and includes provisions clarifying the use of the terms "fair" and "equitable" in the labelling of agricultural products. Notably, it introduces a statutory definition of meat as "edible parts of animals" and reserves a list of specific terms, including beef, pork, chicken, steak, bacon and sirloin, exclusively for products containing meat, meaning they may not be applied to lab-grown or cell-based products.

Most substantive provisions will apply from 19 August 2028, with Article 1(13) (general function claims) applying from 19 August 2029; non-conforming products already in the market may continue to be sold until stocks are exhausted or 19 August 2032, whichever is the earlier.

Although the regulation only entered into force last month, the debate on restricting plant-based terms has been reignited. Members of the European Parliament have tabled amendments to extend the ban to include terms such as "rabbit" and "roast", currently exempted terms such as "burger" and "sausage" and products containing a combination of animal and plant-based proteins. Some industry groups have opposed the proposed amendments, arguing that further restrictions would have commercial implications across the food sector, including for manufacturers and farmers, and create uncertainty for the consumer.

The EU clampdown on meat names will require many plant-based and cultivated-alternatives producers to reconsider how they name their products and rebrand ahead of the August 2029 deadline. The UK is watching closely as regulatory alignment under the forthcoming sanitary and phytosanitary (SPS) agreement with the EU is expected to take effect by mid-2027. Elements of dynamic regulatory alignment are envisaged, which could extend to labelling. The FSA has warned that UK businesses may be required to follow the EU rules under the SPS agreement, as it could bring similar labelling obligations.

European Commission launches call for evidence on implementing measures for New Genomic Techniques Regulation

Following the European Parliament's adoption of a new genomic techniques regulation, the European Commission has launched calls for evidence on measures needed to implement the EU's regulatory framework for plants developed using new genomic techniques (NGTs).

The proposed delegated and implementing acts would establish procedural and information requirements for verifying whether NGT plants qualify as Category 1, which are treated similarly to conventionally bred plants. They would also set requirements for applications and notifications relating to Category 2 plants and their products, which remain subject to regulatory assessment.

The Commission says the initiatives aim to ensure consistent application of the regulation, supporting transparency, safety and legal certainty for placing NGT plants, food and feed products on the market. Businesses in the NGT space should consider responding by the 28 September 2026 deadline.

Delegated regulation under EUDR updating covered products published in the Official Journal

See ESG section.