Legal & regulatory updates

Weekly collection from GOV.UK, legislation.gov.uk, EUR-Lex, CJEU, EFSA and the US Federal Register (last run 12 Nov 2026), plus a curated register with business impact, actions and deadlines.

By topic

By jurisdiction

Register maturity

Established → Evolving → Emerging

Established = binding / final. Evolving = proposal or consultation. Emerging = early signal or scientific assessment.

17 items.

United States·Curated register·1 Oct 2026

FDA food-facility registration renewal window (1 Oct – 31 Dec 2026)

Facilities required to register with FDA must renew between 1 October and 31 December 2026; unrenewed registrations expire.

Why it matters: Mandatory for any site exporting to the US.
Action: Reconcile manufacturing, packing and holding sites; verify US agent and UFI; renew and retain confirmation. — Regulatory / Supply Chain
Deadline: 31 Dec 2026 (compliance)

Established CriticalAct nowImports, trade & controlsDraft – revalidate

United Kingdom·Curated register·30 Sept 2026

England: HFSS promotional-pack transition ended

The concession for less-healthy products carrying embedded volume-price promotions (multibuy, ‘extra free’) ended after 30 September 2026. Such packs may now create retailer compliance and stock-rejection risk in England.

Why it matters: Promotional packs of in-scope hot chocolate, malted and latte powders can no longer be supplied into England.
Action: Identify affected SKUs and customers, quarantine uncertain stock and agree rework, disposal or market diversion. — Regulatory / Commercial

Established CriticalAct nowHFSS & nutrient profilingHot chocolate & cocoa powdersMalted drinksSoluble coffee, latte & frappé powdersChai & spiced tea powdersDraft – revalidate

United Kingdom·Curated register·1 Sept 2026

UK packaging EPR: H1 2026 data and RAM return due

Large producers had to submit H1 2026 packaging data and recyclability (RAM) assessments by 1 October 2026. PackUK has also published RAM 2027.

Why it matters: Multi-material laminates and composite packs are likely to attract higher modulated fees.
Action: Confirm the H1 2026 EPR/RAM submission was made and accepted; start H2 2026 data collection (due 1 April 2027). — Packaging / Regulatory
Deadline: 1 Oct 2026 (compliance)

Established CriticalAct nowPackaging, EPR, DRS & FCMFlexible laminates & sachetsHDPE tubs & bottles (with recycled content)PET bottles (blown in-house) & rPETCardboard cartonsTinplate cansDraft – revalidate

United Kingdom·Curated register·30 Sept 2026

ASA ruling (Huel): exclusive-diet implications and implied health claims

The ASA upheld complaints that complete-nutrition and wellness marketing implied an exclusive diet and made unauthorised health claims.

Why it matters: Applies to malted ‘nourishing’ and wellness positioning.
Action: Audit wellness and functional-drink marketing for implied health claims and exclusive-diet messaging. — Marketing / Regulatory

Established HighAct nowAdvertising & marketingNutrition & health claimsMalted drinksDraft – revalidate

United Kingdom·Curated register·7 Sept 2026

SDIL: lower threshold to 4.5 g/100 ml and loss of milk-drink exemption planned

The planned changes to the Soft Drinks Industry Levy would lower the threshold from 5 g to 4.5 g total sugars per 100 ml and remove the exemption for milk-based and milk-substitute drinks, with a lactose allowance. Target date 1 January 2028; subject to legislation.

Why it matters: Dilute-to-taste drinks between 4.5 and 5 g/100 ml as consumed and milk-based drinks become liable.
Action: Model SDIL exposure at 4.5 g/100 ml for squash at dilution and for milk-based RTD/prepared drinks; document the treatment of powders as prepared. — Regulatory / NPD / Finance
Deadline: 1 Jan 2028 (implementation)

Evolving HighPrepare / respondSugar levies & SDILDilute-to-taste soft drinks (squash)Malted drinksHot chocolate & cocoa powdersSugar, glucose syrup & dextroseHigh-intensity sweetenersSkimmed & whole milk powderLactoseDraft – revalidate

United Kingdom·Curated register·1 Sept 2026

GB: 16 novel-food/regulated-product applications under consultation

The FSA is consulting on 16 applications, mainly human milk oligosaccharides plus an astaxanthin oleoresin and a DHA/EPA Schizochytrium oil. Proposed uses include flavoured drinks, instant beverage mixes and beverage whiteners.

Why it matters: Opens functional positioning for instant beverage mixes and whiteners.
Action: Review applications relevant to the innovation pipeline; comment where categories, maximum levels or labelling conditions restrict intended concepts. — Regulatory / NPD
Deadline: 16 Nov 2026 (consultation)

Evolving HighPrepare / respondNovel foods & functionalSoluble coffee, latte & frappé powdersWhiteners & creamersHot chocolate & cocoa powdersWhey powder & whey permeateDraft – revalidate

United Kingdom·Curated register·1 Sept 2026

Northern Ireland: consultation on HFSS promotion and placement restrictions

The Department of Health NI and FSA in NI are consulting on restricting promotions and placement of HFSS products, including free refills.

Why it matters: Would align NI with England for promotional packs and in-store placement.
Action: Decide whether to respond on promotions, placement and free refills (foodservice/vending). — Regulatory / Commercial
Deadline: 21 Oct 2026 (consultation)

Evolving HighPrepare / respondHFSS & nutrient profilingHot chocolate & cocoa powdersMalted drinksSoluble coffee, latte & frappé powdersDilute-to-taste soft drinks (squash)Draft – revalidate

United Kingdom·Curated register·1 Sept 2026

UK Deposit Return Scheme starts 1 October 2027

Drinks in qualifying containers enter DRS from 1 October 2027; Wales also includes glass.

Why it matters: Check whether squash concentrates fall in scope by container size/format.
Action: Plan registration, DRS labelling, deposits and data for PET squash formats in scope. — Packaging / Commercial
Deadline: 1 Oct 2027 (implementation)

Established HighPrepare / respondPackaging, EPR, DRS & FCMDilute-to-taste soft drinks (squash)PET bottles (blown in-house) & rPETDraft – revalidate

United States·Curated register·11 Aug 2026

FDA proposes mandatory GRAS notification

FDA proposes that businesses using substances on a self-affirmed GRAS basis must notify FDA unless an exception applies.

Why it matters: Affects US exports using self-GRAS functional ingredients.
Action: Build a US ingredient legal-basis register (regulation, additive approval, ‘no questions’ letter, self-GRAS); obtain supplier dossiers; consider comments. — Regulatory / Legal / Procurement
Deadline: 9 Dec 2026 (consultation)

Evolving HighPrepare / respondAdditives, sweeteners & flavouringsHigh-intensity sweetenersGums, emulsifiers, anti-caking & phosphatesFlavourings (incl. vanilla)Draft – revalidate

United States·Curated register·7 Oct 2023

California AB 418 additive bans apply from 1 January 2027

California prohibits brominated vegetable oil, potassium bromate, propylparaben and Red No. 3 in food from 1 January 2027.

Why it matters: Check colours in factored boba and squash.
Action: Confirm US recipes (incl. boba colours) exclude the four prohibited additives. — Regulatory / NPD
Deadline: 1 Jan 2027 (implementation)

Established HighPrepare / respondAdditives, sweeteners & flavouringsBubble tea & boba (factored, Taiwan)Dilute-to-taste soft drinks (squash)Acids, preservatives, colours & vitaminsTapioca starch & boba pearls (Taiwan)Draft – revalidate

United Kingdom·Curated register·17 Sept 2026

CBD novel-food applications advanced – no authorisation yet

The FSA has advanced three high-purity CBD applications towards ministerial decision; no authorisation has yet been granted.

Why it matters: Relevant only if CBD wellness drinks are considered.
Action: Maintain current supplier and Public List controls; no new CBD products until authorisation. — Regulatory

Evolving MediumMonitorNovel foods & functionalDraft – revalidate

European Union·Curated register·17 Sept 2026

CJEU C-657/24: health claims in written advertising

A September CJEU judgment clarifies how health-claim rules apply to written commercial communications.

Why it matters: Applies to EU/IE marketing.
Action: Update EU claims-review procedure for advertising copy. — Regulatory / Marketing

Established MediumMonitorNutrition & health claimsMalted drinksDraft – revalidate

European Union·Curated register·17 Sept 2026

CJEU C-721/24: dose-related benefit statements

A September CJEU judgment addresses the link between authorised claims and the quantity of the substance consumed.

Why it matters: Fortified malted drinks carrying vitamin claims.
Action: Check vitamin/mineral claim conditions of use against serving size as prepared. — Regulatory

Established MediumMonitorNutrition & health claimsMalted drinksAcids, preservatives, colours & vitaminsDraft – revalidate

United Kingdom·Curated register·15 Sept 2026

FSA consultation on listeriosis guidance for vulnerable groups

Revised guidance on reducing the risk of vulnerable groups contracting listeriosis is out for consultation.

Why it matters: Low for dry powders; relevant to RTD and foodservice supply.
Action: Assess if supplying health and social-care settings (foodservice/vending). — Technical
Deadline: 16 Dec 2026 (consultation)

Evolving MediumMonitorFood safety & hygieneDilute-to-taste soft drinks (squash)Draft – revalidate

Codex / FAO / WHO·Curated register·12 Sept 2026

Codex CCPR57 (pesticide residues) held 7–12 September 2026

The Codex Committee on Pesticide Residues met; outcomes feed future Codex MRLs used as references in trade.

Why it matters: Indirect – informs supplier MRL compliance.
Action: Review report for MRLs on cocoa, coffee, tea and spices once published. — Technical / Procurement

Emerging MediumMonitorContaminants & residuesCocoa powderSoluble (instant) coffeeTea bags (factored)Chai spices (cinnamon, ginger, cardamom, clove, pepper)Draft – revalidate

European Union·Curated register·10 Sept 2026

EFSA re-evaluation of aspartame–acesulfame salt (E 962)

EFSA found no safety concern at reported uses but recommended specification and toxic-element limit updates.

Why it matters: Spec changes could affect sweetener suppliers.
Action: No reformulation; ask suppliers about specification changes once the Commission proposes amendments. — Regulatory / Procurement

Emerging MediumMonitorAdditives, sweeteners & flavouringsDilute-to-taste soft drinks (squash)Hot chocolate & cocoa powdersHigh-intensity sweetenersDraft – revalidate

United States·Curated register·1 Sept 2026

FDA Food Code 2026 issued

The 2026 FDA Food Code model was published; it applies only when adopted by states or local authorities.

Why it matters: Foodservice/vending only.
Action: Monitor adoption in priority states for foodservice/vending customers. — Technical

Established MediumMonitorFood safety & hygieneDraft – revalidate

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