UK–EU SPS Alignment: Implications for GB Authorisations

The proposed UK–EU Sanitary and Phytosanitary (SPS) Agreement marks a significant step in aligning UK food and feed regulation with EU standards. Beyond trade facilitation, this alignment will reshape how companies approach authorisations in Great Britain.
Since Brexit, UK legislation has diverged from EU rules only minimally. The agreement signals a move toward dynamic alignment, covering food and feed safety, food supplements, fortified foods, novel foods, nutrition claims, and broader agrifood standards including organics, marketing standards, and pesticide/biocide regulation.

Implications for industry:

• Reduced need for parallel GB submissions: EU-authorised products will automatically gain access to GB once agreement is in place (expected mid-2027)
• EFSA-standard dossiers as baseline: EU-compliant data packages may increasingly satisfy GB regulatory expectations.
• Post-authorisation obligations: EU-style reporting and compliance measures may extend to GB.

Strategic considerations:

• Ensure EU dossiers are aligned with EFSA guidance.
• GB will accept EU outcomes
• Identify products that could face disruption if GB–EU alignment accelerates.

While alignment promises smoother trade and reduced duplication, short-term uncertainty remains, particularly for ongoing applications and category-specific requirements.
Companies investing in robust EU dossiers may benefit from a dual-market advantage as the UK framework converges with EU SPS legislation.
Official source: UK–EU SPS Agreement: Legislation in Scope

Botanicals and flavouring substances under review 

Botanical preparations and flavouring compounds are also attracting increased regulatory attention. A recent entry in the UK Risk Analysis Issues Register concerning preparations containing eugenol and related substances illustrates the growing focus on these categories.
Regulators are paying closer attention to issues such as:

• User exposure through inhalation
• Impurity profiles
• Toxicological justification for complex botanical mixtures

Why it matters
Companies marketing botanical-derived feed additives should ensure that their dossiers clearly address user safety and compositional characterisation, particularly where natural extracts contain multiple bioactive compounds.

Advisory Committee and Toxicology Oversight  

Recent and upcoming meetings of the Advisory Committee on Animal Feeding stuffs and the Committee on Toxicology continue to shape scientific evaluation approaches in the UK. 

In parallel, the FSA and FSS have evaluated and incorporated several EFSA technical guidance documents published since 2021 into the domestic assessment framework. Discussions reflect increased scrutiny of exposure scenarios, user safety and methodological alignment with EU standards, reinforcing the need for robust and well-structured technical justifications in new and renewal applications.

Cobalt(II) Compounds – Provisional Authorisation Consultation 

Food Standards Scotland consulted on a two-year provisional authorisation for four cobalt(II) compounds used in feed.

This development follows EFSA’s identification of consumer safety data gaps in its assessment of cobalt at EU level, indicating coordinated scientific attention across jurisdictions and suggesting that trace element additives may face enhanced data requirements, particularly regarding consumer exposure modelling and long-term safety.

Updated Guidance on Advertising Non-Medicinal Veterinary Products

Veterinary Medicines Directorate updated its guidance clarifying advertising rules for non-medicinal veterinary products.

Given the sensitivity of claims at the boundary between feed additives and veterinary medicines, companies should review product positioning and marketing language to reduce classification risk.

Precision Breeding - New Marketing Authorisation Route

The Genetic Technology (Precision Breeding) Regulations 2025 entered into force in November 2025, enabling businesses in England to apply for marketing authorisation of Precision Bred Organisms (PBOs) for food and feed use.

Applicants must first obtain confirmation and a marketing notice from Defra before submitting an application to the FSA.

Although the regulations apply to England, the UK Internal Market Act 2020 permits authorised products to circulate in Wales and Scotland. The introduction of this new pathway represents a structural development in the UK regulatory landscape and provides a defined route for gene-edited food and feed products, while maintaining case-by-case safety assessment requirements.

Cell-Cultivated Products - Safety Guidance Published  

In December 2025, the FSA published the UK’s first industry guidance for cell-cultivated products under the Novel Foods framework. The guidance addresses regulatory considerations for taste trials conducted during development, confirms that cell-cultivated products are classified as products of animal origin, and outlines expectations relating to allergenicity and nutritional assessment. 

This publication provides greater clarity for developers operating within the FSA’s CCP Sandbox programme, which remains active until 2027, and signals increasing regulatory maturity in the oversight of alternative protein technologies. 

A busy pipeline for feed additives and renewal activity

The EU continues to process a large number of feed additive authorisations and renewals, reflecting both the maturity of the regulatory system and the increasing complexity of dossiers.
For many companies, the most immediate challenge is the preparation of renewal applications, which must demonstrate compliance with current scientific standards, even where the original authorisation dates back many years.

Why it matters
Renewal dossiers are no longer simple updates. Companies should expect to provide new scientific data, updated safety assessments, and modern characterisation methods.

Ongoing Discussions on Animal Food Ingredient Oversight 

Regulatory discussions in the United States continue to focus on the pathways used to evaluate and authorise animal food ingredients.

At the latest meeting of the Association of American Feed Control Officials (AAFCO), regulators and industry stakeholders discussed several initiatives that may influence future regulatory processes, including:

• Updates and guidance related to the Scientific Review of Ingredient Submissions (SRIS) pathway. Materials from the recent SRIS workshop are available online https://www.youtube.com/watch?v=Enff1CYUk3Q&t=2s
• Proposed updates and checklist development for the Comprehensive Feed Labelling Guide, which is currently undergoing revision.
• Discussions on a strategic plan to strengthen and retain animal feed regulators, including the development of training resources.
• A Medicated Feed Labelling Workshop, planned for 25 August 2026 during the AAFCO Annual Meeting.
• Continued development of the Animal Food Ingredient Consultation (AFIC) program.
• Expansion of the Animal Food GRAS Notification Inventory.

Developments Concerning the GRAS Pathway 

Policy discussions are also continuing regarding the future of the Generally Recognized as Safe (GRAS) framework, which currently allows companies to determine the safety of certain food and feed ingredients without mandatory pre-market review by the U.S. Food and Drug Administration (FDA).

Following a directive issued in March 2025 by the U.S. Secretary of Health and Human Services, Robert F. Kennedy Jr., the FDA has been tasked with developing a proposed rule aimed at eliminating the self-affirmed GRAS pathway. Under the anticipated proposal, companies would be required to notify the FDA of GRAS determinations prior to marketing new ingredients.

Although the proposed rule has not yet been released publicly, a draft was submitted in late 2025 to the White House Office of Management and Budget (OMB) for review. Until the proposal is formally published, uncertainty remains regarding the potential scope of the changes and whether transition periods or other implementation provisions will be included.

Animal Food Ingredient Consultations (AFIC)

The Animal Food Ingredient Consultation (AFIC) program, launched in October 2024, is now recognised by AAFCO as a pathway for introducing new ingredient definitions or modifications into Chapter 6 of the AAFCO Official Publication through the Ingredient Definition Committee (IDC) review process.

As of the latest update, no new AFIC submissions have been filed or completed since November 2025, according to the AFIC inventory.

Why it matters

These discussions signal potential changes to how animal food ingredients are evaluated and authorised in the United States. Companies developing new ingredients should monitor developments closely, particularly those related to GRAS determinations and evolving regulatory review pathways.

Navigating the feed and food regulatory landscape

29 - 30 September 2026
Barcelona, Spain

IFW 2026 - Insects to feed the world

9 - 12 June 2026
Turin, Italy 

The 19th Annual International Scientific Conference on Probiotics, Prebiotics, Gut Microbiota and Health - IPC2026

22 - 24 June 2026
Krakow, Poland

The 16th EAVPT Congress 2026 - International Congress of the European Association for Veterinary Pharmacology and Toxicology

28 June - 1 July 2026
 Thessaloniki, Greece