EU General Food Law, US FSMA, UK food safety legislation, China GB standards, and APAC frameworks each impose different labelling, documentation, and import requirements. TGC's specialist food compliance team handles multi-market labelling reviews, FSVP support, contaminant monitoring, allergen compliance, and regulatory audits so your products reach market legally and stay there.
EU food safety notifications
in 2024 - an 8% increase
on
the prior year record
Food and beverage compliance is one of the most fragmented regulatory environments in global trade. The EU, UK, US, China, and APAC countries each maintain distinct food safety frameworks, labelling requirements, contaminant limits, and import documentation demands - and the pace of regulatory change across all of them is accelerating.
In 2024, the EU's Alert and Cooperation Network received 9,460 food and feed safety notifications - an 8% increase on 2023, with RASFF alerts alone rising by 12% to 5,250. In the US, labelling errors alone were responsible for more than 45% of all food recalls in 2024. In China, two new national food labelling standards (GB 7718-2025 and GB 28050-2025) came into force in March 2025, with mandatory compliance from March 2027. The UK introduced its HFSS advertising restrictions on 5 January 2026. The regulatory picture is not static - it is changing faster than most food businesses can track.
TGC provides specialist food and beverage compliance support for manufacturers, importers, exporters, and brand owners operating across multiple markets. We combine deep regulatory knowledge with practical product experience - covering everything from pre-launch labelling review and import documentation through to contaminant monitoring, allergen compliance, FSMA FSVP, and regulatory audit support.
We provide Label Reviews for multi-market labelling compliance, Expedited Compliance Audits for urgent gap assessments, and Full Product Compliance management for food businesses entering multiple markets simultaneously.
2025 and 2026 are among the most active regulatory years for food exporters in recent memory. Key changes are active or approaching across all major markets.
EU Regulation (EU) 2023/915 is actively updated — DON and T-2/HT-2 limits were revised in 2024; nickel limits for cereals phase in through July 2026. A product compliant when ordered may not be compliant when it ships.
Products exceeding the UK Nutrient Profile Model threshold cannot be promoted through paid digital or broadcast channels. Scotland bans HFSS products from checkouts, aisle ends, and store entrances from 1 October 2026.
US importers must maintain FSVP records for foreign suppliers — inadequate documentation can trigger order suspension with no direct FDA action against the exporter. Traceability record-keeping for FTL foods must be in place by 20 July 2028.
Mandatory allergen declaration is an entirely new requirement. Businesses with long packaging production cycles need to begin the label transition now — non-compliant stock cannot reach Chinese retailers after the enforcement date.
The regulatory deadlines food manufacturers, importers, and exporters need to be tracking now. Missing them risks border rejections, recalls, advertising bans, or loss of market access.
9,460 EU food and feed safety notifications in 2024. 45% of US recalls driven by labelling errors. A $1.92 billion direct cost burden. The enforcement environment has hardened across every major market.
EU food & feed safety notifications in 2024 — RASFF alerts up 12%, border rejections roughly one third of the total
of US food recalls in 2024 caused by labelling errors alone — the single largest driver of recall events
direct cost of food recall incidents in the US and Canada in 2024 — over 300 incidents, the highest in six years
A structured overview of the core compliance obligations in each major market — covering labelling, allergens, import verification, and the key 2026–2027 changes.
| Requirement | EU | UK | US (FSMA / FDA) | China (GB standards) |
|---|---|---|---|---|
| Labelling framework | Regulation (EU) 1169/2011 (FIC); consolidated April 2025 | UK FIC — equivalent to EU 1169/2011, retained post-Brexit | 21 CFR Part 101; Nutrition Facts panel required | GB 7718-2025 and GB 28050-2025; mandatory from 16 March 2027 |
| Allergen requirements | 14 allergens — must be emphasised within the ingredients list | Same 14 allergens; PAL standardisation review expected late 2026 | 9 allergens; sesame added January 2023 (FASTER Act) | Mandatory allergen declaration — new requirement under GB 7718-2025 from March 2027 |
| Import verification | Border Inspection Posts; CHED documentation for animal-origin products | UK Border Control Posts; IPAFFS pre-notification system | FSMA FSVP — US importers must verify foreign supplier compliance | GACC registration required; overseas food producers must be listed |
| Key 2026–2027 change | Nickel limits in cereals — July 2026; RASFF enforcement continuing to increase | HFSS ad ban — Jan 2026; Scotland in-store restrictions — Oct 2026 | Produce Safety Rule (small farms) — Apr 2026; FSMA 204 deadline — Jul 2028 | GB 7718-2025 and GB 28050-2025 mandatory — 16 Mar 2027; allergen declaration new |
Our food compliance work spans the full product lifecycle - from pre-launch labelling review and import documentation through to contaminant monitoring, FSMA traceability support, and multi-market regulatory programme management.
We review labels against EU Regulation 1169/2011, UK FIC, US 21 CFR Part 101, China GB 7718-2025/GB 28050-2025, and APAC requirements — covering allergen declarations, nutrition labelling, date marking, claims compliance, and operator information simultaneously across all target markets.
We provide documentation support for US importers' FSVP obligations — supplier verification protocols, hazard analysis records, and corrective action documentation. For businesses subject to FSMA directly, we advise on Food Safety Plan development and FSMA Rule 204 traceability implementation ahead of the July 2028 deadline.
We advise on CHED requirements, Border Inspection Post procedures, and documentation for products of animal, plant, and composite origin. We monitor RASFF notification trends by product category and country of origin, helping clients identify supply chain risks before a border rejection occurs.
We monitor updates to Regulation (EU) 2023/915 — including mycotoxin revisions, phased nickel limits, and pesticide MRL changes — and advise which updates affect your product categories, what testing evidence is required, and how to manage supply chain transitions before new limits apply.
We advise on GB 7718-2025 and GB 28050-2025 compliance — including mandatory allergen declaration and updated nutrition labelling formats. We also support GACC overseas facility registration and Chinese-language label preparation ahead of the March 2027 mandatory compliance date.
When a border rejection, RASFF notification, or customer request demands fast action, TGC's expedited audit delivers a rapid, prioritised assessment of your food compliance status across target markets — gaps identified, immediate actions recommended, and a clear remediation roadmap within days.
The compliance situations we encounter most frequently — often after a costly market disruption that proactive regulatory monitoring would have prevented.
Labels approved for one market rejected in another — costing print runs and delaying launch
EU, UK, US, and China allergen requirements all differ — and a single formulation change can trigger recalls across multiple markets simultaneously
A product compliant when ordered may exceed new mycotoxin or nickel limits by the time it ships — discovered only at the border
US importers suspend orders when FSVP records are inadequate — no direct FDA action against the exporter required
Long packaging print runs leave businesses with non-compliant stock when GB 7718-2025 enforcement begins March 2027
Misapplying the UK Nutrient Profile Model to portion sizes or product formats creates advertising compliance risk across digital and broadcast channels
Answers to the questions we hear most often from food manufacturers, importers, and exporters navigating multi-market regulatory requirements.
The US Food Safety Modernization Act (FSMA), signed on 4 January 2011, represents the most comprehensive reform of US food safety law since 1938. For foreign food exporters, the principal mechanism is the Foreign Supplier Verification Programme (FSVP), which places obligations on US importers to verify that foreign suppliers produce food in a manner that meets US food safety standards. As a foreign exporter, your obligation is indirect - your US importer must maintain adequate FSVP records for your products, and failing to support that verification can result in the importer suspending orders.
FSMA Rule 204 (Food Traceability Rule) requires businesses that manufacture, process, pack, or hold certain high-risk foods on the Food Traceability List to implement enhanced record-keeping covering Critical Tracking Events and Key Data Elements. The FDA extended the compliance deadline to 20 July 2028. The Produce Safety Rule also imposes water quality requirements for produce operations - applying to large farms from April 2025 and small and very small farms from April 2026. Source: US FDA, FSMA overview.
EU Regulation (EU) 1169/2011 on the provision of food information to consumers (the FIC Regulation), consolidated in April 2025, sets the mandatory information requirements for all food sold to end consumers in the EU. Mandatory information includes: the name of the food; an ingredients list (in descending order of weight); allergen information - all 14 major allergens must be emphasised within the ingredients list through formatting such as bold text or underlining; a nutrition declaration (per 100g or 100ml); date of minimum durability (best before) or use-by date; any special storage conditions; instructions for use where needed; net quantity; the name, trade name, or address of the food business operator; and country of origin or place of provenance where required.
There is no mandatory EU-wide front-of-pack nutrition labelling system as of 2026. Some member states operate voluntary schemes such as Nutri-Score. The European Commission has been evaluating a harmonised approach under the Farm to Fork Strategy, but no binding proposal has been adopted. Source: Regulation (EU) 1169/2011, consolidated April 2025.
RASFF (Rapid Alert System for Food and Feed) is the EU's primary tool for sharing information about serious food and feed safety risks across member states. When a risk is identified - at a border inspection point, by a market surveillance authority, or following a consumer complaint - the identifying authority raises a notification through the system, which is immediately distributed to all EU member states and certain non-EU participating countries. In 2024, the broader Alert and Cooperation Network (ACN) received 9,460 notifications, with RASFF-specific alerts rising 12% to 5,250. Source: EU Commission ACN Annual Report, 2024.
For importers and exporters, a RASFF alert means a border rejection (consignment refused entry and returned or destroyed), a product withdrawal from the EU market, or enhanced controls on future shipments from the same source. A notification is public - visible in the RASFF public window - and can trigger commercial disruption beyond the immediate shipment. The most effective risk reduction strategy is proactive compliance: verified contaminant testing against current EU limits, accurate allergen labelling, and documented supplier control programmes.
China published two new national food labelling standards on 27 March 2025: GB 7718-2025 (General Standard for the Labelling of Prepackaged Food) and GB 28050-2025 (General Standard for Nutrition Labelling of Prepackaged Food). Both replace the 2011 versions that had been in force for 14 years. Key changes include: mandatory allergen declaration for the first time (a significant new requirement for imported food labels); permission for digital supplementary labelling to address packaging space constraints; updated nutritional reference values in GB 28050-2025; and revised rules for ingredient list presentation.
A two-year transition period applies. Products placed on the Chinese market before 16 March 2027 may comply with either the 2011 or the 2025 standards. From 16 March 2027, compliance with the 2025 standards is mandatory. Food exporters to China with long packaging production cycles should begin the label update process now to avoid non-compliant stock reaching Chinese retailers after the enforcement date. Source: ChemLinked, March 2025.
Several significant UK food regulatory changes took effect or come into effect in 2026. From 5 January 2026, the UK introduced a TV watershed restriction (pre-21:00) and a ban on paid-for online advertising for foods classified as HFSS (high fat, salt, or sugar) under the UK Nutrient Profile Model. This is one of the most significant changes to food marketing regulations in the UK for over a decade and affects any food business advertising products in the UK through digital or broadcast channels.
From 1 October 2026, Scotland's restrictions on the in-store placement of HFSS products in prominent locations (checkouts, aisle ends, store entrances) come into force. Retailers and food suppliers operating in Scotland need to review and adjust placement agreements. The UK-EU SPS agreement also requires UK businesses to progressively align with EU food safety and labelling standards from May 2026, with sector-specific guidance expected throughout the year. Precautionary allergen labelling (PAL) standardisation changes are expected from the FSA in late 2026. Source: Osborne Clarke, UK Food Law Outlook March 2026.
Exporting food to the EU requires compliance with EU General Food Law (Regulation EC 178/2002) and the specific requirements applicable to your product category. The core documentation requirements include: food labels meeting all Regulation (EU) 1169/2011 requirements in the language of the destination member state; official health certificates or attestations for products of animal origin, required for EU border clearance under Regulation (EU) 2017/625; a Common Health Entry Document (CHED) for products requiring physical or document checks at an EU Border Inspection Post; evidence that contaminant levels comply with Regulation (EU) 2023/915 (or its product-specific annexes); and evidence of HACCP or equivalent food safety management systems.
Products of animal origin - meat, dairy, fish, eggs, and honey - have category-specific import conditions and must come from establishments listed in the relevant EU approved premises registers. Non-animal origin products from certain third countries may also require phytosanitary certificates and pesticide residue documentation. The EU's TRACES.NT system is used for pre-notification of consignments at EU border inspection posts. Requirements vary significantly by product category - TGC can advise on the specific documentation package required for your product. Source: European Commission, Official Controls.
EU · UK · US · CN · APAC
Remediation roadmap in days
Global regulatory infrastructure
Talk to a TGC specialist about your product, your target markets, and your deadlines. We will tell you exactly where the risks are and what it takes to resolve them - before they become a problem at the border or the shelf.
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