We listened to today's morning agenda items for the December FSA board meeting and share our notes below:
CBD (Cannabidiol) – the FSA won’t be able to put a position to minsters until the new year, as Food Standards Scotland as not yet completed their consultation.
NLR (National Level Regulation) – approach was mentioned and there is continued support for the programme. Susan acknowledged the LAs do an incredible job supporting and providing guidance to businesses. It was said to be critical to keep and improve this, as the resourcing problem is not improving. A sub group of the board has an action to reconvene and move things forward.
Allergens - Summary of Codex PAL and Standardisation -
Main conclusion: The FSA board supports Codex PAL standardisation for clearer communication and improved consumer confidence. The next steps involve monitoring Codex implementation (expected July 2026), clarifying UK adoption, and ensuring effective communication and education.
Other Notes:
- The board re-examined evidence on allergen thresholds, consulting businesses and charities - they were largely supportive, assuming gluten is addressed.
- It was acknowledged that scientific evidence is inconclusive regarding ED05, so decisions rely on judgement and stakeholder input. However, this input was considered helpful and reassured board members that risk assessments continue to use the lowest available threshold, with no major risks identified for ED05. As concluded by the charities, individuals with extreme sensitivities remain cautious about PAL labelling and often restrict their diets accordingly.
- The FSA acknowledged PAL may not decrease, so main benefits is on accuracy and confidence that there is a standard.
- Two issues for NI: responsibility for labelling and the impact on educational guidance (Key Stage 3, ages 11–14).
- There is uncertainty among smaller manufacturers about testing for ED05.
- There is interest in further work on Owens Law (related to eating out) and voluntary application data can be reviewed in the future.
- The earliest agreement on Codex is expected in July 2026. Codex adoption is voluntary, and there is a desire to understand the UK’s adoption timeline. Different countries are implementing at different rates; the UK will monitor and share its position post-implementation.
NFCU - mention of new training with stakeholders to be better prepared for food fraud. Recent cases and the work of NFCU praised, although the board did share concerns on the punishments and need for more to deter food businesses from committing food crime.
We will monitor updates for CBD, NLR and allergens, and discuss in the next working groups. Wider work will be continuing on EU-UK alignment which was also briefly mentioned.
