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Contamination ControlProcess ControlRegulatoryChemicalAllergensPackagingInternational Standards/Harmonization

2026 Trends in the EU/UK Food Law Space

By Chris McGarvey
EU and UK flags
Image credit: gpointstudio via Freepik
January 6, 2026

Some EU and UK food law changes in development could arrive sooner than expected, and others will take more time to go into effect. This article discusses food law changes to watch for in 2026, as explained by UK-based food lawyer Chris McGarvey from Walker Morris.

Bisphenol A

The EU has acted to further restrict the use of Bisphenol A (BPA) in food packaging. The change in legislation, which is based on scientific advice from the European Food Safety Authority (EFSA), means that the current restrictions on using BPA in infant bottles, which have been in place since 2011, will be extended to cover most food packaging. The new restrictions begin, with some exceptions, in July 2026.   

PFAS 

Per- and polyfluoroalkyl substances (PFAS) are also facing strict new EU controls, preventing them from being used in food packaging if they exceed certain concentrations. The new controls begin in August 2026. These chemicals, while incredibly useful in various manufacturing processes, are implicated in various health conditions and tend to build up in peoples' bodies over time.

CBD 

We can expect the first UK government-approved cannabidiol (CBD) food products to hit the shelves sometime during 2026. While CBD products have been on the UK market for some time already, they are, in fact, considered unauthorized novel foods. Now that several CBD products have been through a safety assessment by the UK Food Standards Agency (FSA), it is only a matter of time before lawful CBD food appears in peoples' shopping baskets.

Precision-Bred Organisms

The UK's new legislation, which allows the manufacture and marketing of precision-bred organisms (PBOs), is now in force. The first foods commercially manufactured using this biotechnology, which turbo-charges traditional propagation practices, may make an appearance in 2026. 

For the time being, the legislation only allows plant-based PBOs to be safety assessed for food use, but the provisions may extend to cover animal-derived foods in due course.

Folic Acid 

UK law will require millers and flour producers to fortify non-wholemeal wheat flour with folic acid from the end of 2026. This change will help counter neural tube defects in babies in the womb and will complement the UK's existing requirement to add calcium, niacin, thiamine, and iron to white flour to improve public health.

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Acrylamide

The tasty byproduct of the Maillard reaction is under scrutiny again. The UK FSA has launched a call for evidence to understand acrylamide occurrence levels and assess the effectiveness of existing mitigations used by food producers. 

Acrylamide, which forms when starchy foods are heated to high temperatures, has the potential to cause cancer in humans. Meanwhile, the EU has been discussing the introduction of specific, legally binding maximum levels (MLs) of acrylamide for certain foods. One to keep an eye on—any changes are not likely to be introduced until late 2026.

Allergens

The UK FSA is considering whether the approach to precautionary allergen labeling (PAL) should be standardized. PAL, or "may contain" labeling, is an important issue and affects the ability of large numbers of consumers with food intolerance to safely buy food without risk to their health. 

While it is tempting for food businesses to apply the label across a wide range of foods as a "defense" in case of cross-contamination, this can seriously reduce consumer choice and prevents people with food intolerances from enjoying food that may be perfectly safe for them to consume. 

The international body for food standards, Codex Alimentarius, has been developing a global standard to include the use of thresholds, and the UK FSA is interested in adopting it. No progress is expected in this area until late 2026.

New UK–EU Trade Agreement

Five years after Brexit, the UK and EU are back at the negotiating table, attempting to thrash out a new deal on food. UK food exporters have been feeling the pinch, and the documentation involved in exporting food to and from continental Europe is costing the industry dearly. 

Food price inflation is a real concern in the UK, and the cost of border control formalities may be driving some of the increases. There will be some tough issues to resolve. Will the UK once again accept EU food law as a superior form of law in the UK and subject itself to the jurisdiction of the EU Court of Justice? How will this affect the UK's ability to agree trade deals on food with other countries such as the U.S. and Canada? 

These were red lines for the UK during Brexit and could be politically explosive. Negotiations are not expected to produce an agreement before 2027, but it is possible that some progress might be made earlier.   

Changes to Watch for in 2026

As 2026 gets underway, the food safety sector faces a mix of changes that will demand attention now, and others that will take longer to materialize. From tighter controls on BPA and PFAS to the arrival of approved CBD products and precision-bred foods, there is plenty on the horizon for businesses to monitor. 

At the same time, issues like folic acid fortification, allergen labeling, and trade negotiations remain in the pipeline and will shape the conversation well beyond this year. Whatever the pace, staying informed and ready will be essential for navigating what promises to be a busy year for food law.

KEYWORDS: acrylamide BPA CBD EU Europe legal issues legislation PFAS precision breeding UK

Share This Story

Chris McGarvey is Director of the Regulatory and Compliance Team at UK-based law firm Walker Morris. He has over 25 years of experience working in both the private and public sectors. Chris has a track record of helping clients navigate complex legal challenges in areas of highly regulated economic activity. He specializes in food law, and he led the Food Standards Agency's legal team through Brexit, the COVID-19 pandemic, and supply chain challenges associated with the Ukraine conflict.

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