The Food Standards Agency (FSA) and Food Standards Scotland recently co-hosted a Regulating Cultivated Foods: CCP Sandbox Insights event with Mills & Reeve at our London office, alongside the Alternative Proteins Association and The Good Food Institute Europe.
The session provided valuable insight into the evolving regulatory landscape for cultivated foods and the practical steps businesses can take when preparing novel food applications. Regulators, organisations and companies throughout the novel food and feed sector attended.
Supporting innovation through regulation
A consistent theme throughout the event was the FSA's commitment to supporting innovation while maintaining robust food safety standards. The Sandbox programme was established to help address the scientific and regulatory questions associated with cultivated foods, improve understanding of how existing legislation applies, and help businesses submit stronger applications.
Speakers highlighted the growing importance of food innovation in addressing challenges, such as climate change, resource pressures and food system resilience, while emphasising the need for a clear and predictable regulatory framework to support investment and commercialisation.
New guidance and practical developments
The FSA provided updates on a range of guidance published through the Sandbox programme, including work on hygiene requirements, microbiological safety, product identity, production processes and novel food taste trials.
Particular attention was given to the guidance on novel food taste trials, which aims to provide greater clarity for businesses looking to undertake research and development activities involving unauthorised novel foods. The FSA reiterated the importance of ensuring that trials remain genuine R&D exercises and encouraged early engagement with local authorities when planning such activities.
The event also explored how existing hygiene and traceability requirements apply to cultivated products and provided further insight into expectations around safety assessments and application dossiers.
What makes a strong application?
One of the most useful discussions focused on what regulators are looking for in a successful CCP application.
The FSA emphasised three key questions that every application should answer:
What is the novel food?
How is it made?
Why is it safe?
Speakers encouraged applicants to provide a clear narrative alongside supporting data, ensuring regulators can understand both the product itself and the rationale behind the evidence submitted. Common causes of delay were identified as incomplete data, failure to follow published guidance, unclear explanations and information that no longer reflects the current production process.
Looking ahead
The future UK-EU regulatory relationship was discussed, with speakers acknowledging ongoing uncertainty around sanitary and phytosanitary (SPS) negotiations. However, the message from the FSA was that the scientific work undertaken through the Sandbox programme should remain valuable regardless of the eventual outcome, as much of the guidance has been developed in line with existing European approaches.
The Sandbox programme has now been extended until March, allowing further guidance to be published and giving businesses additional opportunities to engage through the FSA's Business Support Service.
For businesses developing cultivated food products, the key takeaway was clear: engage early, make use of the available guidance and support, and ensure regulatory considerations are embedded throughout product development rather than addressed at the final stage.
If this topic is of interest, join us at our upcoming food and agribusiness breakfast briefing session on gene editing and novel foods on 21 October 2026, where Linus Pardoe from The Good Food Institute will join Mills & Reeve speakers to discuss the latest developments in novel foods, alternative proteins and the evolving regulatory landscape.
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