In 2021, the EU implemented Regulation (EU) 2021/382, which sets food safety culture requirements for European food business operators (FBOs) in line with Codex guidance. To assess the progress of Member States in implementing food safety culture controls in accordance with this legislation, and to elucidate the experiences of FBOs and competent authorities, the European Commission conducted a survey in 2025.

The recently published results show that, although Member States have made progress toward implementation of controls for and enforcement of the food safety requirements outlined in EU law, most countries also report challenges due to their novelty and the difficulty of rating culture objectively.

EU Guidance on Measuring Food Safety Culture

As acknowledged in the survey report, food safety culture components are subjective. However, Commission Notice 2022/C 355 defines these components (i.e., Commitment, Leadership, Awareness, Communication, and Sufficient Resources) and provides examples of tools (e.g., surveys, checklists) that may be used to develop, assess, and audit food safety culture. Commission guidance recommends food safety culture-specific audits for large businesses, while flexibilities should be allowed for small establishments where the culture may become evident through regular inspection and audit activities.

Competent Authorities Responsible for Culture Controls

The survey found that, in all Member States, the competent authorities in charge of food safety culture have been defined for retail establishments, meat processors, and establishments producing dairy, fishery products, composite products, and food of non-animal origin. However, for other establishments (e.g., egg processors, cutting plants, cold stores, game handling establishments, etc.), only 14 Member States were able to define the responsible competent authorities.

Additionally, 12 Member States have raised awareness of the food safety culture regulations among their food control staff (i.e., through training and/or guidance), while awareness-raising is still ongoing in 12 Member States, and in three countries, none of the official control staff have been made aware of the culture provision.

Spain was highlighted in the report as an example of a “good” food safety culture awareness-raising initiative. The Spanish central competent authority not only disseminated information via emails and virtual meetings, but also facilitated workshops and collaborative forums, sector-specific webinars and training sessions, explicit instructions and guidelines for incorporating culture into official controls, and participation in working groups for the development of common implementation and oversight strategies.

Tools and Guidance Used for Culture Controls

Commission Notice 2022/C 355 (or a very similar approach) is used by at least some of the competent authorities in 14 Member States. Some authorities mentioned using additional tools for food safety culture controls, such as existing procedures for measuring FBOs’ food safety management systems (FSMS) that were updated with culture requirements. Procedures for culture official controls are in place in 11 Member States. Overall, the results suggest that, in most cases, the existing procedures for routine official controls and audits have been amended to include food safety culture aspects.

Additionally, five countries use sector-specific culture guidance or national general guidance on FSC, and in three Member States, such guidance is under development. Guidance is mainly based on or in alignment with EU regulations and Commission resources.

Food Safety Culture Initiatives for Food Businesses

The competent authorities in 13 Member States have endorsed or run initiatives for food safety culture for FBOs, such as training, guidance, awareness-raising, and other actions.

The report shared examples of “good” practices in different countries, such as dedicated events and forums in Belgium and Spain, the use of public communication channels to raise awareness in Belgium and Spain, publication of articles and manuals for industry in Spain, and the development of guides to help FBOs measure their culture compliance in Spain and the Netherlands. Additionally, in Ireland, the competent authorities have published a specific webpage to advise FBOs on how to develop their FSC responsibilities, including a guidance note and online learning modules.

Culture Requirements Largely Integrated into Existing Controls

According to the survey responses, food safety culture official controls are in place in 18 Member States, although a number of countries, whether they reported conducting FSC controls or not, further explained that culture requirements are integrated into existing control mechanisms, like Hazards Analysis and Critical Control Points (HACCP) frameworks or FSMS controls. Examples of how countries implement culture controls in existing activities include interviews with managers and staff on HACCP teams, documentation checks and consideration of consumer complaints, observations of companies’ conformance with food safety requirements (e.g., good hygiene practices, good manufacturing practices, HACCP), and assessment of FBOs’ willingness to cooperate and resolve noncompliances.

Only one Member State, Austria, reported the use of culture-specific audits. A small number of Member States consider the results of third-party audits on food safety culture in the organization and implementation of official controls.

Additionally, while certain elements of food safety culture are already integrated into some competent authorities’ existing controls, there are differences in opinions between Member States regarding the practical effectiveness and justification of investment in explicit culture controls, with respondents questioning the causal link between strong culture and positive food safety outcomes, citing the challenging nature of measuring culture, and expressing that reliance on existing legislative requirements is sufficient to control culture.

Results of Food Safety Culture Controls at Food Businesses

Some of the 18 Member States that reported carrying out culture controls provided data on the outcomes. Overall, the number of controls and identified noncompliances was higher in 2023 than in 2024 or 2025. The highest number of controls was conducted at retail establishments and establishments producing food of non-animal origin, but the greatest number of violations were found in the sectors producing food of animal origin. Noncompliances often related to lack of training, lack of systemic culture implementation, and falling short on specific requirements (e.g., hygiene, traceability).

Additionally, based on the outcome of official controls, and to a limited extent, on the results of third-party audits, some competent authorities have rated the effective implementation of the food safety culture requirements at establishment level. The limited results suggest an overall better level of implementation of culture requirements in large and medium establishments, especially when international standards on culture are implemented.

Challenges in Implementing Culture Controls

The majority of Member States (22 of 27) reported challenges in implementing food safety culture official controls, mostly relating to resource constraints, the need to make procedural changes, and struggles to develop assessment criteria that can be objectively and consistently applied. Other challenges included the perception that culture is an administrative burden without tangible impact, training needs, and a lack of data collection and reporting infrastructure.

However, 14 Member States reported national-level measures to overcome culture control challenges. The survey report highlighted “good” examples of such efforts, like the incorporation of culture assessment within official controls in Ireland, a national pilot program in Belgium to develop a practical method for culture control, FBO self-assessment tools in Spain and the Netherlands, and participation by several countries in a Heads of Food Safety Agencies work group to develop a toolbox for competent authorities.