The Food Standards Agency (FSA) Board has approved the next phase of work on proposed changes to the UK’s food regulatory framework.
Developed through the Future of Food Regulation programme, the proposals aim to overhaul and modernise a system that has remained largely unchanged for decades. The programme reflects wider food and beverage industry trends, including more complex supply chains, greater use of data and rapid advances in food processing technology.
What will change?
The proposed reforms would reinforce the role of local authority food teams, introduce a more consistent national approach for monitoring the country’s largest food businesses and increase transparency around food hygiene.
Further work will focus on:
– Equipping local authority food teams with the expertise, tools and resources required to address problems and support businesses in their areas.
– Improving the registration process for food businesses so regulators have a more accurate view of organisations operating across the food system.
– Allowing local authorities to continue regulating and supporting businesses locally, while national oversight concentrates on a small number of the very largest operators.
– Making more effective use of data and intelligence gathered throughout the supply chains of major businesses.
– Providing businesses with guidance that is clearer and more consistent.
– Increasing transparency around food hygiene, including a potential requirement for food hygiene ratings to appear online throughout the UK and in shops and restaurants in England.
The reforms could also influence future food and drink regulations, as well as the way businesses demonstrate compliance across manufacturing, retail and distribution.
Why is the system being reviewed?
FSA chair Professor Susan Jebb said the existing framework had delivered strong protection for consumers, but needed to reflect changes across the sector.
“The system that protects our food has served us well for many years, maintaining some of the highest food standards in the world.
“But the way people buy, sell and produce food has changed enormously, and we need to keep pace with that change so that we can be confident of continuing to keep food safe into the future.”
The proposals respond to a request included in the Autumn 2025 Budget. The government asked the FSA to develop a national regulatory model for large food businesses in England, beginning with retailers.
Supermarkets were selected because of their extensive consumer reach and significant influence over suppliers. Although more than 99.5% of food businesses are micro, small or medium-sized organisations, more than 97% of food sold through shops is supplied by just 10 national retailers.
In response, the FSA launched a pilot using data-led supervision of major supermarkets. The trial indicated that national analysis of retailer data could identify food safety risks and broader systemic issues, complementing inspections and other checks carried out at individual sites.
“The idea was not to replace the food role of local authorities, but rather to help local authorities make better use of their stretched resources,” explained Chris McGarvey, Director in Regulatory & Compliance at Walker Morris, who previously led the FSA’s legal team.
“By combining a supermarket’s own enterprise-level safety and compliance data with local information, the FSA could help assess the overall risk posed by that retailer, which should reduce the need for local, premises-based inspections.
“This was something new for the FSA and for the big retailers who took part in the pilot exercise. Among other things, the pilot underlined the fact that a food regulatory system designed for the 20th century was failing to make use of data generated by sophisticated food businesses whose focus and challenges are firmly those of ‘the 2020s’.”
The approach reflects several food manufacturing trends and food distribution trends, particularly the growing importance of enterprise-wide data, digital traceability and supply chain visibility.
Applying the model to manufacturers
After testing its proposed supervisory role with large retailers, the FSA plans to assess how the model could extend to other sectors, including food manufacturers.
However, significant practical and legal challenges remain. Questions have already been raised about the proposed ‘triaged regulatory pathway’ for large businesses, particularly where retail operations appear to carry a lower level of risk.
“The FSA will want to look ‘under-the-hood’ to assess risk, which won’t always be comfortable for the businesses concerned,” McGarvey told Food Manufacture.
“A further complication is that any holding of food business data by the FSA could attract freedom of information (FOI) requests, leading to its disclosure to the public at large. There are some exemptions under FOI legislation that might prevent disclosure, but there is no guarantee they will always apply.”
McGarvey also questioned whether FSA inspectors would always be able to interpret highly technical information generated by individual manufacturing systems.
“It is difficult to see how there will be a direct read-across here, because manufacturing introduces an additional layer of compliance and data complexity that doesn’t always exist for retailers,” he said.
Manufacturers may be harder to assess using the same data model applied to retailers because production environments generate more complex operational information. Modern food processing technology, for example, can produce extensive exception reports that combine safety indicators with efficiency, maintenance and commercial data.
“Depending on how data is shared, the complexity of exception reporting in modern production systems might lead to many ‘false positives’ where the FSA thinks there is a safety problem, when in fact all that is being flagged is an efficiency or other commercial marker, unrelated to safety or labelling.
“One advantage for food manufacturers of being in a later phase of the Programme is that the FSA may, by then, have developed a better feel for enterprise-level data analysis and interrogation of large datasets. ”
Louise Grinyer, head of food safety and membership at Leatherhead Food Research, also identified potential difficulties in managing the volume and variety of information already produced by major food businesses.
“Large food businesses already generate a lot of information through audits, supplier assurance programmes, testing, complaints and internal monitoring.
“Deciding which information is meaningful, bringing it together in a consistent way and using it to identify emerging or systemic risks – without creating duplication or unnecessary reporting burdens – could be a significant challenge.”
The same considerations may eventually affect areas such as food and drink packaging, food and drink sustainability reporting and the data used to support food and drink marketing claims.
What should manufacturers do now?
The FSA is working with local authority food teams, businesses and other stakeholders through a technical advisory committee. The group will help shape the proposed model and resolve the operational details of each reform as part of a broader regulatory redesign.
The FSA Board is expected to review progress in March 2027, after which the agency plans to launch a public consultation.
Grinyer advised manufacturers to follow developments closely, even though the proposals are unlikely to create immediate compliance changes.
“While the proposals are unlikely to result in immediate change, they signal a wider move towards more intelligence-led and risk-based regulation, with greater emphasis on understanding risks across businesses and supply chains,” she added.
McGarvey offered similar advice: “Keep an eye on FSA announcements about progress with the programme.
“Look afresh at your internal compliance data, perhaps with a non-expert, to see how easy it is for an external reviewer to understand; and consider whether system reports can be adapted/redacted so that they can be shared externally.”
Manufacturers should also maintain constructive relationships with environmental health and trading standards officers at local authority level.
“They are not going anywhere soon and may even get more powers to intervene at the site level.”
For businesses, the developing framework forms part of wider food and drink industry innovation. Companies that improve data quality, strengthen supply chain oversight and clearly distinguish food safety information from broader operational reporting will be better placed to respond as the FSA advances its plans. These preparations will also support organisations navigating evolving food and drink consumer trends, food and drink sustainability expectations and future food and drink regulations.