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.

9 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·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·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

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 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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