Navigating the 2026 food landscape - four key issues

Health

Foods high in fat, salt and sugar (HFSS) and Less Healthy Foods (LHF)

The categories here will be very important due to the restriction on advertising online and before the 9pm threshold on TV. Enforcement is expected to be strict and the boundaries will be crucial. It will be interesting to see how the most creative people in the industry will react to this challenge, whereby we already see adverts in the alcohol sector taking on the challenges with personality, from Jeremy Clarkson to Ricky Gervais. Of particular interest will be the interpretation on brand advertising and where a product may be "identified".

Sugar tax

This is extended to milk-based products and thresholds raised. A major question will be if it may be extended further for example to Ultra Processed Foods (UPF) or if they will be held back by lack of a legal definition.

The area of Ultra Processed Foods (UPF) and "real food" with "clean labels" are expected to by scrutinised with food companies considering boundaries and where opportunities may lie for fortification and reformulation.

This clearly links to the making of health and nutrition claims and what this may centre on in the future. We have seen the GLP1 jabs and effect on market in America. The focus may therefore be on protein and fibre, as well as more novel claims concerning what can be said for mental health.

Environment

The Digital Markets Competition and Consumer Act (DMCC) is now in force regarding misleading claims, and we're seeing the first Competition and Markets Authority (CMA) investigation of misleading online pricing. The approach to environmental claims is an area that is expected to also receive further scrutiny in 2026.

The EU Empowering Consumer to the Green Transition Directive will be enacted March 2026 and in force September 2026. Without its twin, the Green Claims Directive, this will prohibit broad environmental claims and sustainability labels. A great deal of guidance is required and a major question is still outstanding as to whether this will cover products already on the market. The role of third-party certification bodies for products who wish to make such a claim on the EU market will be critical.

The EU Packaging and Packaging Waste Directive (PPWD) is similarly expected to impact on the UK market by providing for strict requirements that are likely to be enacted in practice by the role of extended supply chains. There will be legal requirements for the percentage of packaging recycled and recyclability, as well as where this leaves claims and the single use plastics definition. Hospitality is expected to be particularly affected.

Extended producer responsibility (EPR) will also affect food packaging in the year ahead. The first year of EPR operations, during which issues were identified around material classifications, corporate restructuring and the administration of producer obligations. Draft amendments to the EPR regulations propose technical and operational changes intended to refine how the scheme works from January 2026.

Food contact materials will also need assessment and review in particular in respect of limits on PFAS (forever chemicals), as well as BPA and mineral oil hydrocarbons expected.

Food security

Critical consideration for where the UK will stand on regulation concerns food security.

Cyber security, security of data and who owns that data is more and more important and valuable for food chain security and substantiation of claims. The push for a standard structure for provision of data will gain prominence, as well as the protection given to proprietorial data.

A consistent question remains on whether priority should provided for environmental and welfare or for production and costs - at the heart of this battle will be the approach to energy. The inheritance tax changes also mean farmers have warned tax changes could "destroy British agriculture as we know it". The response to this may mean an increase in claims around origin, provenance and welfare become more important.

A key issue for the markets and extended supply chains will also be the role of tariffs and what sectors they might affect. One area of opportunity may be where supply chains are stretched across global opportunities.

Europe and regulated products

An SPS agreement would align Great Britain's sanitary and phytosanitary standards with those of the EU, removing the need for most certificates and checks on animals, plants, and related products moving between Great Britain and the EU. Negotiations have started and are expected to last some 18 months across 2026 and into 2027.

Regulated products and novel foods are a main concern as to whether they may be "carved out" of this due to the infrastructure behind the legislation of sandboxes and investment in R&D. The new regulatory framework for precision-bred GMOs (PB-GMOs) was set up as a Brexit benefit and had previously been described as a "priority" for Defra to encourage innovation in the food sector.

Welfare

The question will be if this is to be a carve out from the SPS also. It is an area that is certainly highly contentious and a potential added premium for the food and agribusiness sector. The making of claims and substantiation of this is therefore also one that would be scrutinised.

Origin claims

This is of increasing importance, but also where this may stand for place of last substantial change in a highly evolved global chain.

This has just touched the very edges in the food and agribusiness sector, and there are likely to be a whole host of additional areas which we will endeavour to keep you updated as 2026 progresses (and beyond).