Comparing US Food Safety Standards with UK Regulatory Requirements

The UK relies heavily on food imports. In 2020, 46% of the food consumed in the UK was imported from other countries. So, for US food and beverage companies looking to expand internationally, the UK is full of opportunity. 

 

However, navigating the difference in food safety standards between the two countries can be a significant barrier to entry.

 

In this article, we’ll provide a comprehensive comparison between US and UK food safety standards, and give expert advice on how importers can meet UK safety standards and get their products on UK shelves.

Overview of US and UK Food Safety Regulations

The regulatory frameworks governing food safety in the US and UK are designed to protect the health of consumers and ensure the integrity of the food supply chain. 

 

In the US, the primary authority overseeing food safety is the Food and Drug Administration (FDA), while the US Department of Agriculture (USDA) also oversees food safety for meat, poultry, and egg products. 

 

The FDA’s Food Safety Modernization Act (FSMA) provides preventive controls to mitigate foodborne diseases and requires manufacturers to implement comprehensive food safety management systems. 

 

The FDA conducts regular food inspections for everything from food additives to hygiene practices in food production, ensuring businesses stay compliant with regulations. 

 

In the UK, food safety regulations are governed primarily by the UK Food Standards Agency (FSA), which is responsible for monitoring food hygiene and conducting assessments to prevent food contamination. The Food Safety Act 1990 remains a cornerstone of UK food law and ensures that:

 

• Businesses don’t treat food in any way (including adding or removing anything to food) that would damage the health of people consuming it.
• Food that businesses serve or sell is of the substance, nature, and quality that consumers expect.
• Food is labelled, advertised and presented in a manner that is not false or misleading.

Key Differences in Food Labelling Requirements

Food labelling is critical for consumer safety and informed decision-making. While both the US and UK aim to provide consumers with essential information, their labelling requirements differ in several key areas:

Nutritional Information 

In the US, the FDA mandates a standardised nutrition facts label that includes specific serving sizes, calorie counts, and a percentage of daily values for nutrients.

 

In the UK, the FSA mandates food must have a traffic light labelling system that visually indicates: 

 

• Fat 
• Energy (kilojoules and calories) 
• Saturates 
• Sugar 
• Salt 

Ingredient Listing

In the US, ingredients must be listed in descending order by weight, with allergens such as nuts or gluten highlighted in bold.

 

The UK has similar requirements, where ingredients must be listed in order of weight, with the main ingredient listed first. Allergens can be emphasised using a different font, style, or background colour. 

Health Claims

In the US, all health claims must be FDA-approved and specific criteria must be met to substantiate any claim made.

 

In the UK, businesses must follow specific rules when making a nutrition claim or a health claim. In the UK you cannot claim that food can treat, prevent or cure any disease or medical condition.

Date Marking 

Businesses in the US use “Best Before”, “Sell By”, and “Use By” dates. However, these are used as indicators of quality, not safety.

 

The UK also uses “Best Before” and “Use By” dates. While “Best Before” indicates quality, “Use By” dates are explicitly about safety, as foods can be dangerous if consumed after this date. 

 

In the UK, it’s illegal to sell or use foods past their “Use By” date.

Impact of Brexit on UK Food Standards

Brexit has significantly impacted UK food standards, leading to both opportunities and challenges for businesses and consumers. While the UK retained many EU regulations, the potential for divergence in standards is now a concern.

 

The UK government aims to establish a distinct regulatory environment, which could have some benefits. However, importers may face increased complexities and potential barriers, as differing standards could complicate access to both EU and UK markets. This only increases the need for expert international trade consultants for businesses trying to import goods into the UK.

Are UK Food Standards Higher Than US Standards?

The debate over whether UK food standards are higher than those in the US is based on regulatory approaches and public health priorities. 

 

The UK generally adopts a precautionary principle, resulting in stricter regulations on food additives, pesticide residues, and foodborne disease prevention. 

 

For example, the UK has banned azodicarbonamide (ADA), an additive commonly used in bread products in the US. 

 

Additionally, the UK’s Food Standards Agency places significant emphasis on food hygiene and consumer protection, often leading to higher standards in areas such as meat inspection and food labelling. 

 

Therefore, while both countries have robust food safety systems, the UK tends to impose more stringent standards.

Are UK food Standards Higher Than EU Standards?

The EU has comprehensive food safety regulations governed by the European Commission, covering everything from food production to labelling and additives. Generally, EU standards are considered rigorous, particularly in areas like genetically modified organisms (GMOs) and animal welfare. 

 

For now, it’s hard to distinguish whether UK food standards are higher than EU standards – but any future divergence could decrease the relative safety of UK standards.

How Importers Can Meet UK Standards

For businesses looking to import food products into the UK, understanding and complying with UK food standards is crucial to ensure a smooth entry into the market. Here are key steps importers can take to meet these standards:

 

Understand regulatory requirements: Familiarise yourself with the Food Safety Act 1990 and the guidelines set forth by the Food Standards Agency (FSA). This includes the specific requirements for labelling, food hygiene, and safety management systems.

 

Conduct thorough research: Stay updated on EU legislation that may still affect the UK, particularly in areas related to food additives and residues. Knowing which EU regulations the UK still follows can ensure compliance and reduce the risk of rejected shipments.

 

Training and consultation: Training and consultation offered by international trade experts like clearBorder can help you ensure you meet all food safety requirements.

 

By taking these proactive measures, importers can facilitate compliance with food safety standards, eliminate problems with customs, avoid fines and build trust with UK partners and consumers.

Future of Food Safety Standards in the UK and US

The future of food safety standards in the UK and US is poised for significant change, as both countries navigate new regulatory landscapes. 

 

Following Brexit, the UK government is exploring options that may enhance flexibility and innovation, particularly in areas such as food production and sustainability. However, this shift could complicate trade with EU countries, and divergence from EU standards could result in lower food safety standards.

 

In the US, the Food and Drug Administration (FDA) continues to emphasise preventive measures through the Food Safety Modernization Act (FSMA), pushing for increased compliance among food producers. The US is also focusing on streamlining regulations to enhance efficiency in the food supply chain. 

 

Evolving standards in both regions could lead to improved food safety outcomes. However, changing regulations may pose a challenge for businesses engaged in trade between the US and the UK. 

Ensure UK Food Safety Compliance with clearBorder

Partnering with an experienced international trade consultant makes it easier to navigate the complexities of UK food safety standards. 

 

For businesses importing food products into the UK market, clearBorder’s customs consultancy services can help ensure compliance with UK food safety standards.

 

The experts at clearBorder can provide insight into food safety laws, labelling, and hygiene standards, ensuring your food products meet the necessary guidelines in the UK. By leveraging the expertise of an international trade consultant, you can minimise compliance risks and get your product to market faster.

 

Don’t take chances when it comes to food standard compliance. Contact clearBorder today for seamless entry into the UK market.