The United Kingdom’s departure from the European Union has triggered significant recalibrations in food safety governance, altering regulatory alignment, border protocols, and surveillance mechanisms between the two jurisdictions. Initially, the UK maintained continuity through the Retained EU Law framework, preserving standards like the General Food Law Regulation (EC) 178/2002. However, divergence has accelerated since 2022, exemplified by Great Britain permitting titanium dioxide (E171) in foods after its EU ban and authorizing gene-edited crops, a policy contrasting with the EU’s stricter GMO framework. Northern Ireland, bound by the Windsor Framework, remains aligned with EU standards, creating internal UK regulatory asymmetries.
Maximum Residue Levels (MRLs) for pesticides illustrate stark divergence. Great Britain increased MRLs for over 100 food items, including a 4,000-fold rise for chlorantraniliprole and boscalid in tea and a 25-fold increase for thiamethoxam in oats, substances banned in both regions but permitted on imports under weaker Codex Alimentarius standards. Conversely, the EU reduced MRLs for 80% of arsenic in baby food and plans further restrictions. Novel food approvals also split pathways; the EU authorized insect-based proteins and new additives like bovine milk beta-lactoglobulin, while the UK maintains distinct authorization timelines.
Institutional shifts have compounded challenges. The UK Food Standards Agency (FSA) absorbed responsibilities previously managed by EU bodies, including import/export oversight and novel food authorization. However, resource constraints and fragmented local enforcement have raised concerns about inspection capacity and supply-chain compliance. The UK’s exit from the EU’s Rapid Alert System for Food and Feed (RASFF) initially hampered risk communications, though a 2025 Sanitary and Phytosanitary (SPS) agreement aims to reduce border checks and align standards dynamically. This pact permits UK input on EU regulations during early drafting phases but grants no voting rights.
Trade friction persists despite the SPS deal. Post-Brexit veterinary certificate requirements for EU-bound meat exports caused significant delays and documentation fraud risks. Border controls deferred until 2023 now require sanitary checks on EU imports, disrupting chilled-meat trade. Labour shortages, particularly of veterinarians and seasonal agricultural workers, further strain safety enforcement and production integrity.
Table: Key Areas of UK-EU Food Safety Divergence
| Policy Domain | EU Standard | UK Standard (Great Britain |
| Titanium Dioxide | Banned (2022) | Permitted |
| Novel Foods | Insect proteins approved (2023) | Case-by-case authorization |
| Pesticide MRLs | Stricter limits (ex: arsenic in baby food) | Weaker Codex-based limits adopted |
| Gene Editing | Restricted (plants only) | Deregulated (crops/livestock) |
While the 2025 SPS agreement eases Northern Ireland trade and reduces border checks, long-term alignment remains uncertain. The Brexit Freedoms Bill’s “sunset clause” could repeal 150+ retained food laws by 2025 unless preserved. As both jurisdictions navigate this new terrain, monitoring divergence in pesticide rules, novel ingredients, and border enforcement will be critical for market access and consumer safety.
