Post-Brexit Food Safety: Navigating New EU Authorisations and Contaminant Limits

What's Changed and Why It Matters Now

The UK food industry is undergoing a significant regulatory shift as a direct consequence of Brexit. A recent GOV.UK update confirms that, from 30 July 2026, Great British food and feed authorisations will cease to apply. Instead, EU authorisations will be recognised and applied in Great Britain under the SPS agreement. This change impacts a wide array of regulated products and processes vital to many food and feed businesses across the country.

Concurrently, new, additional, and revised maximum levels for various contaminants are being introduced. These include substances such as per- and polyfluoroalkyl substances (PFAS), heavy metals (e.g., lead, cadmium), mycotoxins, and plant toxins, which will affect a diverse range of foods. All food and feed businesses are legally required to ensure compliance with these new contaminant levels, as stipulated in Regulation 2023/915.

This blueprint provides a clear, action-led guide to help you navigate these changes effectively. Adhering to these new regulations is not just about avoiding penalties; it's about upholding the highest standards of food safety, protecting your consumers, and maintaining your business's reputation. Ignoring these updates could lead to serious compliance issues, product recalls, and negative EHO inspection outcomes. Further government guidance is expected in summer 2026, but proactive preparation is crucial now.

Your Action Plan: Steps for Compliance This Week

1. **Review the Official Guidance Immediately:** Access the GOV.UK guidance on 'Food manufacturing, processing and standards: preparing your business'. Understand which specific regulated products and processes (e.g., extraction solvents, feed additives, flavourings, food contact materials, food additives, food enzymes, genetically modified organisms (GMOs) as food and feed, novel foods, and smoke flavourings) are affected by the shift to EU authorisations. Identify if your business currently uses or produces any of these.
2. **Identify Affected Products and Processes:** Create a comprehensive list of all ingredients, products, or processes within your operation that fall under the categories of regulated products or are susceptible to contaminant issues. This includes both raw materials and finished goods. For example, if you use specific food additives, you must verify their authorisation status under the new regime. Consider engaging with our [consulting services](/services/consulting) for a detailed impact assessment.
3. **Assess New Contaminant Levels:** Familiarise yourself with the new maximum levels for contaminants like PFAS, heavy metals, mycotoxins, and plant toxins as set out in Regulation 2023/915. Cross-reference these with your current ingredient specifications and finished product testing protocols. Pay particular attention to ingredients sourced from regions historically prone to higher contaminant levels.
4. **Update Your HACCP System and Food Safety Management:** Your Hazard Analysis and Critical Control Point (HACCP) plan and wider food safety management system must reflect these new regulatory requirements. Conduct a thorough review of your existing HACCP to identify where new critical control points (CCPs) or monitoring procedures are needed, especially concerning contaminant control and the use of authorised products. This might involve updating your supplier approval process or introducing new testing regimes. For assistance, refer to our [HACCP checklist](/free-guides/haccp-checklist).
5. **Engage with Your Supply Chain:** Contact all your suppliers to ascertain their awareness and compliance with the upcoming changes. Request updated specifications, certificates of analysis, and assurances that their products meet the new EU authorisation requirements and contaminant limits. Document all communications and responses as part of your due diligence. Transparency throughout the supply chain is paramount.
6. **Implement New Testing and Monitoring Protocols:** Based on your risk assessment, introduce or modify testing schedules for ingredients and finished products to ensure compliance with the new contaminant levels. This might require investing in external laboratory testing or upgrading in-house capabilities. Regular monitoring is key to demonstrating ongoing compliance to the FSA and EHO.
7. **Train Your Staff:** Develop and deliver targeted training for all relevant staff members on these new regulatory requirements. This includes purchasing teams, kitchen staff, quality control personnel, and management. Ensure they understand the implications of using unauthorised products or exceeding contaminant limits. Training should cover updated procedures, documentation, and reporting protocols. Consider enrolling key staff in our [Food Safety Supervisors Level 3 course](/courses/food-safety-supervisors-level-3) to embed a thorough understanding of advanced food safety management.

What Good Looks Like: Your Compliance Checklist

• You have a clear, documented understanding of which of your products and processes are affected by the shift to EU authorisations.
• Your supplier agreements and specifications explicitly reference compliance with new EU authorisations and Regulation 2023/915 for contaminant levels.
• Your HACCP plan has been reviewed and updated to include new control measures for identified contaminant risks and authorised product usage.
• You have robust testing and monitoring programmes in place, with documented results demonstrating compliance with new maximum contaminant levels.
• All relevant staff have received training on the updated regulatory requirements and their roles in maintaining compliance.
• You maintain comprehensive records of all due diligence activities, including supplier communications, risk assessments, and testing results, ready for EHO inspection.

Frequently Asked Questions

Frequently Asked Questions

What exactly are 'regulated products' in this context?

Regulated products refer to categories of food and feed ingredients and processes that require specific authorisation before they can be placed on the market. This includes, but is not limited to, extraction solvents, feed additives, flavourings, food contact materials, food additives, food enzymes, genetically modified organisms (GMOs) used as food or feed, novel foods, and smoke flavourings. The key change is that from 30 July 2026, their authorisation will be governed by EU regulations in Great Britain, rather than previous Great British specific authorisations.

How do I know if my products contain the new contaminants at levels that exceed limits?

The primary method is through risk assessment and laboratory testing. You should review the ingredients you use, especially those known to be susceptible to contamination (e.g., certain fish for PFAS, root vegetables for heavy metals, cereals for mycotoxins). Engage with your suppliers to obtain their contaminant testing data and certificates of analysis. If there's a risk, you may need to arrange for independent laboratory testing of your raw materials or finished products to ensure compliance with Regulation 2023/915.

What are the consequences if my business doesn't comply by 30 July 2026?

Non-compliance can lead to severe consequences. The FSA and local EHOs will enforce these regulations. This could include formal warnings, improvement notices, prohibition orders, seizure of non-compliant products, significant fines, and even prosecution in serious cases. Non-compliance can also result in product recalls, damage to your brand's reputation, and a reduced Food Hygiene Rating. Proactive compliance is essential to avoid these detrimental outcomes.