Transparency data

Questions from the public for the Food Standards Agency September 2026 Board meeting

Updated 15 September 2026

Applies to England, Northern Ireland and Wales

Question 1

From Dr Mark Tallon, Managing Partner, Legal Products Group Ltd (t/a Legal Foods):

We note the FSAs proposal to advise Ministers in England and Wales to authorise the three high-purity CBD novel foods, subject to the proposed conditions of authorisation.

Question 1: Is the next batch of CBD novel foods that have positive FSA opinions now under assessment by Food Standards Scotland (FSS)?

Question 2: If yes when will these be presented to Ministers in England and Wales to authorise? If no then why not and when will they be sent to FSS for assesment?

Question 3: Have many CBD applications with positive opinions are now before FSS and providing approval will be presented to Ministers in England and Wales to authorise?

Question 4: Will all future CBD applications with positive opinions by the FSA/FSS require discussion by the FSA Board before being presented to Ministers in England and Wales to authorise?

Question 2

From Cefyn Jones, Founder, The Hemp Hound Agency:

Internal FSA briefing material stated that once an ADI was identified, each CBD application would be assessed for authorisation “based on its own evidence”, expressly linking that approach to the Agency’s statutory obligation to assess each dossier “on its own merit”.

Can the Board confirm whether 10 mg/day now operates as an inflexible maximum daily intake for CBD authorisations irrespective of applicant-specific proprietary toxicological evidence?

If it does, what legal and scientific basis permits a general 10 mg/day limit to override application-specific evidence capable of supporting a higher safe intake?
If it does not, in what circumstances can an applicant’s own evidence support authorisation at an intake above 10 mg/day?

Question 3

From Cefyn Jones, Founder, The Hemp Hound Agency:

The September Board paper states that, under the proposed UK-EU SPS Agreement, existing GB novel-food authorisations would cease to apply unless an exception is agreed, and that the EU has accepted there may be a limited number of areas in which the UK retains its own rules.

Can the Board confirm whether the FSA, or officials acting on its behalf, have received representations from any CBD novel-food applicant, consortium, trade association or other interested party seeking an exception, grandfathering arrangement or other mechanism intended to preserve existing or prospective GB CBD novel-food authorisations under the SPS Agreement?

If so, can the Board confirm whether those representations have been communicated to officials involved in the SPS negotiations, and whether any indication has been given that such an exception may be pursued?

Can the Board also confirm whether all affected CBD applicants and wider industry stakeholders have been given an equivalent opportunity to make representations on that issue?

Question 4

From Cefyn Jones, Founder, The Hemp Hound Agency:

The FSA says concerns that its CBD system could create a “cartel-like environment” are speculative. How can that be true when the Agency had already been warned that its own rules could shut competitors out and hand an advantage to a small number of companies?

Did the FSA ignore those warnings, or did it know about them and dismiss them anyway?

Question 5

From Dr Geoffrey Knott FRES, Chair & Novel Foods Lead, UK Edible Insect Association CIC:

The June minutes record the Board’s call for targeted support for SMEs and describe the FSA’s SPS role as providing independent, evidence-based advice. The Annual Science Update now confirms that the FSA is developing SPS impact assessments covering effects on businesses. The CBD paper asks the Board to progress three GB novel-food applications despite SPS uncertainty, partly to bring an existing market into compliance.

The existing UK edible-insect market also depends on three GB novel-food dossiers, yet UKEIA has been informed that these dossiers are not being progressed under the SPS-driven prioritisation approach. That outcome is difficult to reconcile with the subsequent FSA/FSS classification of edible insects as a Tier 1 emerging food technology.

UKEIA’s rapid product-level assessment found that 45 of 55 classifiable SKUs—approximately 82%—would be commercially unviable under the relevant proposed EU dossier conditions. Those conditions were examined through UKEIA’s longstanding collaboration with the Belgian Insect Industry Federation. Its house-cricket and yellow-mealworm dossiers received positive EFSA safety opinions in December 2024 and January 2025, but still had no final EU authorisation by August 2026. Preparing EU applications therefore provides neither timely certainty nor sufficient product coverage.

Even eventual authorisation of those dossiers would leave most assessed UK products outside their proposed scopes.

Does the Board accept that, without sector-specific protection, SPS alignment creates a foreseeable risk of severe contraction of the UK edible-insect sector, including withdrawal of currently marketed products and the loss of years of regulatory and commercial investment?

If not, what evidence contradicts UKEIA’s quantified assessment? If it does, will the Board ensure that edible insects are expressly covered in the SPS impact assessments and FSA advice to Ministers, and formally recommend an exception or bespoke arrangement that protects existing GB products and preserves a workable route to authorise additional products and uses?

Question 6

From Cefyn Jones, Founder, The Hemp Hound Agency:

Given that the FSA has now formally recorded concerns from multiple respondents that its approach to CBD authorisations could distort the market or create a “cartel-like environment”, what action has the Agency taken to investigate whether those concerns reflect actual market conditions, and how has it assured itself that its authorisation process is not entrenching unfair advantages or undermining fair competition?

Question 7

From Simon Dawson, Policy Advisor, Association of Independent Meat Suppliers:

We have 3 questions:

1. Para 5.2 of the paper mentions a FSA Efficiency Programme. What are the top 3 measures from this work that will deliver most efficiency gains and when will they be implemented?

2. In relation to the FSA Efficiency Programme will the FSA share with industry the terms of reference for this Programme and its governance arrangements, including the SRO and details of external stakeholder involvement?

3. In the interests of transparency can the FSA explain why the cost of an OV in England & Wales is 25% higher than that of an OV in both Northern Ireland and Scotland? How will the FSA Board seek assurances that this difference is not due to inefficient operations by the FSA and its contractors?

Question 8

From Jason Austin, Chair, All Wales Food Safety Expert Panel:

Local authorities in Wales continue to seek clarity regarding the specific problem or problems that the FSA is seeking to address through the proposed wholesale regulatory reform. What evidence has been used to identify these issues, and how have they been assessed as requiring regulatory change?

Question 9

From Jason Austin, Chair, All Wales Food Safety Expert Panel:

Where is the evidence base supporting the need for wholesale regulatory reform in Wales, particularly given the distinct regulatory, geographical and business landscape compared with other parts of the UK?

Question 10

From Jason Austin, Chair, All Wales Food Safety Expert Panel:

What specific outcomes, objectives and success measures are associated with each of the six proposed frameworks, and how will the FSA assess whether those outcomes have been achieved?

Question 11

From Jason Austin, Chair, All Wales Food Safety Expert Panel:

The scope and definition of a “large retailer” has yet to be provided by the FSA. Which large food retailers are currently being considered for inclusion within the proposed national regulatory model? For example, will eligibility be limited to the national supermarket retailers that participated in the pilot, extended to all national supermarkets, or broadened further to include other large multi-site food businesses, such as those operating under Primary Authority partnerships?

Question 12

From Jason Austin, Chair, All Wales Food Safety Expert Panel:

Local Authorities in Wales have proposed a seventh framework for consideration, which does not appear to be reflected within the Board Paper, and have requested that it be developed in co-production and collaboration with FSA colleagues. Will the Board provide assurance that no proposals will be progressed or implemented until this seventh framework has been given full and fair consideration by the FSA?

Question 13

From Jason Austin, Chair, All Wales Food Safety Expert Panel:

At a time when the UK Government is advocating stronger local regulatory powers to tackle public protection issues on our high streets, what evidence supports the view that national regulation would deliver better outcomes than local regulation, when local intelligence and physical inspection remain an integral part of verifying compliance and implementation within food businesses?

Question 14

From Jason Austin, Chair, All Wales Food Safety Expert Panel:

Both the UK and Welsh Governments have recognised the importance of robust local regulation in protecting the public. Events such as the Grenfell Tower tragedy, and concerns regarding regulatory oversight in the water sector, have highlighted the consequences where regulatory arrangements fail to identify and address risks effectively. In light of this, has the FSA assessed whether increasing national regulation could inadvertently weaken public protection outcomes by distancing regulatory decision-making from local intelligence, reducing local accountability, and limiting regulators’ ability to identify and respond to emerging risks within our communities? If so, what evidence supports the conclusion that the proposed wholesale reform will enhance, rather than diminish, the effectiveness of regulatory oversight and public protection?

Question 15

From Adam Banks, Director, CF Banks Ltd t/a Bugvita:

As director of a small family farming company that has spent several years building our edible-insect business, I am concerned about products we lawfully market in GB that may fall outside EU novel-food authorisations after SPS alignment.

Our precautionary SKU-by-SKU review of 20 products against EU Union-list entries expected to apply at mid-2027, including data-protection periods due to expire by then, found 4 with a clear route to market, 7 requiring scope clarification, and 9 with no identified compliant route under a strict reading of those entries because of species, food category or use level.

Defra’s 30 July 2026 guidance states that some edible-insect products “will need to be reformulated or withdrawn from the Great British market” when Great British authorisations are withdrawn under the SPS Agreement from mid-2027. At the same time, UKEIA has been informed that GB edible-insect novel-food applications relevant to the current transitional arrangements are not expected to be progressed under the SPS-driven prioritisation approach, making resolution before alignment unlikely. The Annual Science Update confirms the FSA is assessing business impacts.

Given this, will the FSA recommend a continuity arrangement allowing existing products lawfully marketed in GB before a defined cut-off date to remain on the GB market, subject to appropriate safety safeguards, until any necessary application under the successor regulatory route is determined or otherwise concluded? Where GB applications are already pending, will the FSA also seek arrangements allowing assessment work already undertaken to be recognised or reused in the successor process rather than businesses having to start again?

If not, what alternative will the FSA recommend to avoid lawful products being withdrawn solely because the regulatory system changes before an equivalent authorisation can be obtained?

Question 16

From Nicole Harding:

Board Paper: Evaluation of Meat Charging Discount

Q1: Given more and more evidence is emerging of systemic non-compliance with animal welfare legislation, why is FSAs valuable time and resources being directed towards ways of helping privately owned, and often profitable abattoirs, save money with the meat charging discounts proposals + discount model, undermining the importance of OV oversight, especially given the associated cost and resource demand placed on FSA (and tax-payer funding) to retrospectively have to address the increasing breaches and non-compliances in abattoirs, farms and transportation of farmed animals. The Meat Charging Discount has featured on four Board agendas in the last year - would FSAs time, focus and resource be better placed on creating a model based on severe penalty charging of businesses who fail to comply with existing legalisation/framework guidelines, which would retrospectively act as significant deterrent and preventative measure of ensuring professionalism within these facilities and higher standards in animal health, care and welfare.

Question 17

From Jason Austin, Food and Health Protection Manager, Torfaen County Borough Council:

The success of the National Food Hygiene Rating Scheme is founded on the principle of independent inspection and transparent publication of results. What assurance can the Board provide that the proposed reforms will not weaken public confidence in the Scheme, reduce transparency, or create a two-tier regulatory system in which some food businesses are subject to different levels of independent scrutiny than others?

Question 18

From Nicole Harding:

FSA Board Meeting 16.9.26 - CEO Report

Item 7.2 - Resilience Report:

The CEOs Report notes “a very significant increase in animals arriving at slaughterhouses dead or suffering from heat stress during the summer months”.
Whilst it is noted the FSA does not enforce animal welfare law on farm or during transport, but FSAs presence in slaughterhouses means that the FSA are able to identify and record these issues and that the FSA have now worked closely with Defra and APHA to strengthen the protocol, with said improvements being put in place to include extended reporting during amber alerts, prioritisation of all heat stress cases, strengthened guidance for Official Veterinarians, increased industry awareness of mitigation measures, and earlier intervention with transporters.

Not withstanding these are commendable reactive measures now being undertaken by FSA, therefore, may I respectfully ask FSA/Board if more proactive influencing, on the data of deaths and cause, to positively further influence for proactive prevention measures to be undertaken by DEFRA/AHPA, understanding typically animals feel the effects of heat stress when their bodies exceed 25 degrees.

Question 19

From Elizabeth Gilchrist, Assistant City Protection Manager, NI Food Managers Group:

1. What specific problem(s) is the proposed national regulatory model intended to address, and what evidence is there that these problems exist in Northern Ireland?

2. What evidence is available that would support the need to extend the proposals for national regulation of large retailers to NI? Our unique regulatory landscape in terms of geography, EU governance and compliance with the FLCOP Official Control timeframes does not suggest that an extensive change to our current system is necessary.

3. What evidence is available that a national model would deliver better outcomes than the current District Council arrangements, where local intelligence in conjunction with a reactive workforce provides rapid and effective food safety regulation?

4. What assessment has been made of the impact of each proposed framework on the current role of NI District Councils, including the use of local knowledge, intelligence, physical inspection and risk-based enforcement?

5. What is the scope of businesses that will fall into the category of ‘large retailer’?

6. How will the objectives and success of each framework be measured?

Question 20

From Elizabeth Gilchrist, Chair, NI Food Managers Group:

1. What evidence demonstrates that the current local authority-led regulatory model for large businesses is failing and requires structural reform?

2. How will Frameworks 3 and 5 improve food safety, food standards and consumer protection outcomes beyond what could be achieved through investing in and strengthening the current local authority and Primary Authority led system?

3. What is the rationale behind choosing Framework 3 and 5 rather than prioritising licencing, enhanced registration and the implementation of mandatory Food Hygiene Rating display, all suggestions from LA’s across the three nations identified as being a stronger means for developing the future of food regulation?

4. How will local authorities be involved in the design, governance and ongoing evaluation of the delivery arrangements?

5. What role will local authorities retain in relation to nationally regulated businesses operating within their areas?

6. What are the proposed arrangements for sharing intelligence, inspection findings, enforcement information and incident response activity between national regulators and local authorities and how will adaptations to Information Management systems be funded?

7. How will accountability and governance arrangements operate where responsibility for regulatory oversight is divided between national and local bodies?

8. What safeguards will the FSA put in place to ensure that any redistribution of responsibilities does not inadvertently weaken local authority capability or resilience?

9. What will happen to existing Primary Authority partnerships?

10. How will success be measured and what criteria will be used to determine whether the reforms have delivered better outcomes?

11. What safeguards will ensure that any future expansion of national regulation will be subject to further consultation and stakeholder engagement?

12. What is the criteria that will be used to determine which businesses fall within the scope of a nationally regulated retail model and how will this criteria be reviewed over time?

13. How will local authority intelligence be considered where it differs from centrally held assurance data or third-party audit findings?

Question 21

From Peter Brett, Chair, London Food Coordinating Group (LFCG):

We have drafted a number of questions below, but importantly have also sent a more substantive submission which we would be pleased to discuss further.

Evidence base: What specific problem is national-level regulation intended to solve, and what published evidence shows that existing local authority arrangements are currently insufficient in relation to the regulation of the large retailers?

Business assurance data: How will business-generated assurance data be independently verified, and what safeguards will apply where that data conflicts with any local authority intelligence or direct observation?

Resources and workforce: How will the FSA ensure that local authority food service resources, expertise and capacity are not further reduced or displaced as a consequence of national-level regulation?

Primary Authority: Why were existing Primary Authority mechanisms, including the FSA’s potential role as a specified supporting regulator, considered insufficient, and what evidence justifies creating new regulatory structures?

Scope and definitions: How will “large food business” be defined, and what criteria will determine entry into, review within or removal from any national regulatory framework?