Food exporters targeting multiple markets simultaneously face a significant regulatory coordination challenge. The EU, UK, US, and China each operate independent food safety frameworks — with different primary legislation, labelling formats, allergen lists, import verification requirements, and enforcement bodies. Overlaps exist, but they are rarely complete, and the differences are exactly where compliance failures tend to occur.
This reference table maps the core compliance obligations across all four markets. It is designed as a working document for food compliance teams, procurement managers, and regulatory affairs leads who need to understand how the frameworks interact — and where the most significant upcoming changes apply.
The highlighted row at the bottom of the table shows the key 2026–2027 changes in each jurisdiction. These are the ones requiring action now.
| Requirement | EU | United Kingdom | United States (FSMA / FDA) | China (GB standards) |
|---|---|---|---|---|
| Primary food safety law | Reg (EC) 178/2002 — General Food Law; consolidated July 2024 | Food Safety Act 1990; UK FIC (Food Information Regulations 2014); post-Brexit retained EU law | Federal Food, Drug, and Cosmetic Act; Food Safety Modernization Act (FSMA) 2011 | Food Safety Law of China 2021; GB national standards administered by SAMR and NHC |
| Labelling framework | Reg (EU) 1169/2011 (FIC); consolidated April 2025. Mandatory: ingredients, allergens, nutrition declaration, date marking, net quantity, operator name and address | UK FIC (equivalent to EU 1169/2011, retained post-Brexit). HFSS advertising restrictions in force from January 2026 | 21 CFR Part 101. Nutrition Facts panel required; FDA regulates claims. No separate front-of-pack mandate as of 2026 | GB 7718-2025 (general labelling) and GB 28050-2025 (nutrition labelling); mandatory from 16 March 2027, replacing 2011 versions |
| Allergen requirements | 14 major allergens must be emphasised (e.g. bold) within the ingredients list; no mandatory advisory labelling standard | Same 14 allergens as EU FIC; PAL (precautionary allergen labelling) standardisation under FSA review, expected late 2026 | 9 major allergens; sesame added as the 9th allergen from January 2023 under the FASTER Act 2021 | Mandatory allergen declaration newly required under GB 7718-2025 from March 2027 — this is an entirely new requirement for imported food labels |
| Import verification | Official controls under Reg (EU) 2017/625; Border Inspection Posts (BIPs); CHED documentation required for products of animal origin; TRACES.NT pre-notification system | UK Border Control Posts; IPAFFS pre-notification system for most food products of animal origin; equivalent documentary and physical check regime to EU | FSMA FSVP — US importers must verify that foreign suppliers produce food to US food safety standards; import alerts can be imposed on non-compliant sources | GACC registration required for food exporters to China; overseas food producers must be listed in the GACC overseas food enterprise registration system. SAMR and GACC oversight |
| Traceability | One-step-back, one-step-forward traceability required under Regulation 178/2002 for all food operators across the supply chain | Equivalent one-step-back, one-step-forward traceability under UK General Food Law (retained from EU Regulation 178/2002) | FSMA Rule 204 — enhanced record-keeping required for businesses handling foods on the Food Traceability List (FTL), covering Critical Tracking Events (CTEs) and Key Data Elements (KDEs); compliance deadline 20 July 2028 | Traceability requirements under the Food Safety Law of China; specific requirements apply to imported food supply chains, with records to be maintained by GACC-registered importers |
| Contaminant limits | Regulation (EU) 2023/915 — the principal contaminant framework, actively updated: mycotoxin limits revised in 2024, nickel limits phased in 2025–2026 | UK equivalent retained from EU 2023/915; contaminant limits updated independently post-Brexit by the FSA and FSS | FDA action levels and tolerance thresholds; Codex Alimentarius reference points applied to imports; specific limits vary by contaminant and food category | GB 2762 (national food contaminant standard); updated periodically by the National Health Commission (NHC); limits differ from EU in some categories |
| Key 2026–2027 change | Jul 2026: Nickel maximum levels in cereals and cereal-based foods apply; ongoing RASFF enforcement increase (9,460 notifications in 2024) | 5 Jan 2026: HFSS TV watershed and online ad ban in force. 1 Oct 2026: Scotland HFSS in-store placement restrictions. Late 2026: PAL standardisation changes expected | Apr 2026: Produce Safety Rule water requirements for small farms. 20 Jul 2028: FSMA Rule 204 Food Traceability Rule compliance deadline | 16 Mar 2027: GB 7718-2025 and GB 28050-2025 mandatory — including the new allergen declaration requirement. Businesses with long packaging production cycles should begin transition now |
How to Use This Reference
This table covers the core framework-level obligations. Product category-specific rules — such as requirements for products of animal origin, GACC overseas enterprise registration in China, or the specific documentation required for EU Border Inspection Post clearance — are not captured here and require separate assessment.
The table is most useful as a starting-point checklist: if you are preparing to export to any of these markets for the first time, or adding a market to an existing export programme, use it to identify which regulatory frameworks apply to your product and which upcoming changes require near-term action.
For product-specific guidance — particularly around labelling compliance, allergen declaration, contaminant monitoring, or import documentation — TGC can advise on the specific documentation package required for your product category in each market.
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