The shift towards pro-innovation food regulation – What’s happening and why does it matter?
Introduction
The Food Standards Agency (FSA), in collaboration with Food Standards Scotland (FSS), has recently launched its new ‘Innovation Research Programme’ (IRP), continuing the UK’s marked shift towards a pro-innovation regulatory approach in respect of food technologies and products.
The pace of innovation can quickly render regulatory frameworks outdated, and prior to 2025 it was becoming clear that this was an increasing problem for the UK’s food sector. Indeed, in 2024 the FSA highlighted how the UK’s regulatory framework for food products (inherited from the EU) was overly prescriptive in light of the rapid technological progress within the industry. As such, the FSA and FSS (the UK’s food regulators responsible for assessing whether new food products are safe for sale) were struggling to carry out their regulatory functions in a manner that sufficiently facilitated the innovative development of novel food products, arguably risking ‘hindering innovation, limiting consumer choice, and pushing UK businesses abroad’.[1] However, a series of recent developments, of which the IRP is the latest, has signalled a shift towards a regulatory framework and approach that aims to enable innovation in the food sector without compromising safety standards.
The key 2025 developments
The IRP, announced on 23 September, is a ‘rapid one-year programme to enhance the UK food regulators’ capabilities and specialist expertise in regulating innovative food technologies’, particularly precision fermentation.[2] Precision fermentation – which (through the bioengineering of microorganisms) allows for the production of specific components like proteins and fats without the need for traditional animal agriculture – represents a significant opportunity for enhancing food security and reducing environmental impacts. The IRP seeks to ensure that the appropriate regulatory capabilities and expertise are in place such that the UK is in a position to capitalise on such opportunities.
Importantly though, whilst the IRP is significant in its own right, it must be recognised that this is just one of several key recent developments across 2025 which together represent a wider shift towards a pro-innovation regulatory approach within the food sector. We explore some of these key developments below.
Firstly, in January 2025, proposals to enact two key regulatory changes were laid before Parliament: removing the requirement for certain products (including food that contains, consists of, or is produced from, genetically modified organisms (GMOs)) to be re-authorised every ten years, and allowing authorisations of all ‘regulated products’ (which includes GMOs and novel foods) to be effected by ministerial decision rather than by statutory instrument. These changes (which came into force on 1 April 2025 through the Food and Feed (Regulated Products) (Amendment, Revocation, Consequential and Transitional Provision) Regulations 2025) were introduced to streamline the authorisation process and thus help the UK’s food regulators to ‘keep pace with innovation in the food industry’.[3]
Further regulatory change occurred in May of this year, with the Genetic Technology (Precision Breeding) Regulations 2025 being enacted to implement the Genetic Technology (Precision Breeding) Act 2023 which covers precision bred organisms (PBOs): plants or animals developed using modern biotechnology but only containing altered genetic features that could also have been produced by traditional breeding processes. The 2023 Act (not without controversy) provides for a new, streamlined regulatory framework for PBOs, therefore distinguishing them from GMOs to which a stringent regulatory framework applies. This simplification of the authorisation process has the potential to significantly increase innovation in the food sector by incentivising the development of PBOs. It should be noted however that the 2025 Regulations take effect only in England (from 13 November 2025) and only implement the 2023 Act in respect of precision bred plants, with a decision on precision bred animals being deferred.
In addition to the streamlining of regulations, increases in funding for the FSA and FSS have also been crucial in enabling a pro-innovation regulatory approach, by ensuring that the regulators have sufficient expertise and resources to engage with developers of novel food products. In March 2025, the FSA announced £1.4 million in funding (from the Department for Science, Innovation and Technology’s Regulatory Innovation Office) for the launch of a new ‘innovation hub’ to develop and expand specialist expertise in regulating innovative technologies, with a particular focus on precision fermentation.[4] Also in March, the FSA announced the launch of the ‘sandbox’ programme (funded by the Government’s Engineering Biology Sandbox Fund), ‘a pioneering regulatory programme’ for cell-cultivated products (CCPs).[5] CCPs are food products, such as meat, dairy and seafood, again made without the use of traditional animal agriculture; cells are taken from animals, grown in a controlled environment and then harvested to make the final product. The sandbox programme provides a structured space for the UK food regulators and eight selected CCP businesses to engage in constructive dialogue, providing support to the CCP businesses whilst enabling the regulators to enhance their expertise on CCPs and how the regulatory process can be improved.
A new pilot ‘business support service’ was additionally announced in June 2025, to help guide CCP businesses through the UK market authorisation process.[6] Businesses can directly communicate with the regulators prior to submitting an application for market authorisation, enabling them to develop an early understanding of the approval process and what they need to prove within an application. The intention is that a higher standard of applications are submitted, and accordingly a greater chance of novel food products eventually entering the market.
The IRP (which, as mentioned above, was subsequently introduced in September) includes another new business support service, with a focus on precision fermentation.
Comparing the UK’s approach to that of other jurisdictions
The above-described regulatory developments have been well received by those within the novel food industry and are arguably enabling the UK to establish itself as a global leader in balancing food safety and innovation, alongside countries like Singapore (which is renowned for its pro-innovation regulatory system). Indeed, some of the UK’s recent changes mirror features of Singapore’s regulatory approach. For example, the Singapore Food Agency has successfully offered significant support to businesses throughout the market authorisation application process, something that the FSA has started to offer through its CCP sandbox programme and business support service.
Interestingly, whilst the UK has started to shift away from the prescriptive regulatory system inherited from the EU, the EU itself has implemented little change. This has resulted in notable stakeholder frustration in the region at a regulatory system perceived as being too slow, costly, and complex and therefore ultimately stifling innovation. In June 2025, 24 industry bodies collectively issued an open letter appealing to the European Food Safety Authority for regulatory reform. Potential reforms are perhaps somewhat on the horizon; a new EU life sciences strategy has recently been published, which recognises the need to better facilitate innovation in the food sector, and a public consultation has been held on a new European Biotech Act. However, tangible plans for change remain elusive at this stage.
One potential issue with this growing divergence between the UK and EU’s regulatory approaches is the ‘Common Understanding’ signed by the UK and EU on 19 May 2025. Under this agreement, which is not legally binding, the UK and EU have pledged to negotiate a Sanitary and Phytosanitary Agreement which aligns the UK and EU’s food safety rules applicable to agrifood products. It remains to be seen whether this proposed alignment could restrict the UK from further streamlining its food safety regulations in respect of novel foods (such as PBO food products, CCPs and precision-fermented products) going forwards, which could be a lingering source of concern for those considering investing in UK novel food businesses.
What all this means for stakeholders
Naturally, the recent regulatory developments in the UK will be of significant interest to those directly involved or looking to invest in businesses within the novel food industry. However, the likely acceleration of novel products coming to the market also has potential implications for stakeholders in the food sector as a whole, from the strengthening of supply chains (on account of new methods of ingredient production) to an inevitable increase in competition for producers utilising traditional methods of production. It is therefore important that businesses keep abreast of the latest regulatory developments and adopt a proactive mindset in considering the potential impacts.
Co-authored by Ollie Mather, Trainee Solicitor at CMS
[1] Written evidence from Food Standards Agency (ENB0015) for the House of Lords Science and Technology Committee’s enquiry into engineering biology (May 2024) https://committees.parliament.uk/writtenevidence/130225/pdf/
[2] Food Standards Agency, ‘FSA champions food innovation in the UK with the launch of a new Innovation Research Programme’ (September 2025) https://www.food.gov.uk/news-alerts/news/fsa-champions-food-innovation-in-the-uk-with-the-launch-of-a-new-innovation-research-programme
[3] Food Standards Agency, ‘Reforms to the market authorisation process for regulated products come into force’ (April 2025) https://www.food.gov.uk/news-alerts/news/reforms-to-the-market-authorisation-process-for-regulated-products-come-into-force
[4] Food Standards Agency, ‘FSA announces £1.4 million funding for launch of new innovation hub’ (March 2025) https://www.food.gov.uk/news-alerts/news/fsa-announces-ps14-million-funding-for-launch-of-new-innovation-hub
[5] Food Standards Agency, ‘FSA launches pioneering regulatory programme for cell-cultivated products | Food Standards Agency’ (March 2025) https://www.food.gov.uk/news-alerts/news/fsa-launches-pioneering-regulatory-programme-for-cell-cultivated-products
[6] Food Standards Agency, ‘New Support Service to guide innovative food businesses through UK market authorisation process’ (June 2025) https://www.food.gov.uk/news-alerts/news/new-support-service-to-guide-innovative-food-businesses-through-uk-market-authorisation-process
