Food and drink regulations and traceability

Front-of-pack and HFSS labelling

High Fat, Salt and Sugar (HFSS) products face voluntary labelling schemes and mandatory promotion restrictions:

Front-of-Pack HFSS Labelling (High Fat, Salt and Sugar)

Voluntary front-of-pack nutrition labelling scheme showing colour-coded labels (red, amber, green) for fat, saturates, sugars and salt content. While voluntary, major retailers and manufacturers widely adopt this scheme. Separate mandatory regulations restrict promotion and advertising of HFSS products.

Front-of-pack nutrition labels (voluntary)

The Department of Health's voluntary front-of-pack labelling scheme shows per portion and per 100g:

Energy (kJ and kcal)
Fat
Saturates
Sugars
Salt

Each nutrient is colour-coded:

Red: High
Amber: Medium
Green: Low

HFSS promotion restrictions (mandatory from October 2022)

Products high in fat, salt or sugar (HFSS) are subject to location and promotion restrictions in larger retailers:

Cannot be displayed at checkouts, store entrances, aisle ends, or online equivalents
Cannot be promoted through volume offers (e.g., 'buy one get one free', '3 for 2')
Applies to retailers over 2,000m² floor space (around 50+ employees)

HFSS status is determined by the Nutrient Profiling Model which scores products based on energy, saturated fat, total sugar, sodium, fruit/veg/nut content, fibre, and protein.

Products exempt from HFSS restrictions

Drinks not less than 75% milk
Powdered drinks that become <1% fat when made up
Products specifically formulated for babies and young children

Front-of-pack labelling decision: Decide whether to adopt voluntary colour-coded labelling
Nutrient calculation: Calculate nutrient values per 100g and per portion if adopting labelling
Colour coding determination: Determine colour coding using Department of Health thresholds
HFSS product identification: Identify HFSS products if you are a retailer over 2,000m² or online equivalent
Store layout compliance: Review store layout to ensure HFSS products are not in restricted locations
Promotion restrictions: Ensure promotions do not include volume offers on HFSS products
Staff training: Train staff on HFSS regulations and location requirements
Product reformulation: Consider reformulation to reduce HFSS classification for new product development

HFSS regulations and front-of-pack labelling

Food traceability and recall obligations

All food businesses must maintain 'one step back, one step forward' traceability and respond to food safety incidents:

General Food Law - Traceability and Recall

EU Regulation 178/2002 (retained in UK law) requires food businesses to maintain traceability of food, feed, and ingredients 'one step back, one step forward'. Businesses must be able to identify suppliers and customers, and must withdraw or recall unsafe food from the market.

Traceability requirement: 'one step back, one step forward'

You must be able to identify:

One step back: Your suppliers (who you bought from)
One step forward: Your customers (who you sold to)

This does not apply to final consumers (individual customers in shops or restaurants).

Information to record

For suppliers:

Name and address of supplier
Description of product (including batch/lot number if available)
Quantity received
Date of delivery

For customers (business-to-business only):

Name and address of customer
Description of product sold
Quantity supplied
Date of dispatch

How long to keep records

Perishable products (short shelf life): Until use-by date plus 6 months
Long-life products: 5 years from date of supply

Food recall procedure

If you discover food is unsafe or does not comply with food safety requirements, you must:

Withdraw product: Remove from sale and distribution immediately
Notify FSA: Submit incident report if product has reached consumers
Recall product: Contact customers and request return if serious risk
Issue allergy alert: If undeclared allergen present, publish alert via FSA
Cooperate with authorities: Provide information and take corrective action

Allergy alerts

If a product contains an undeclared allergen or incorrect allergen information, this usually requires a product recall and publication of an allergy alert on the FSA website.

Traceability system: Implement system recording supplier details for all ingredients
Batch number recording: Record batch/lot numbers from suppliers on delivery
B2B customer records: Maintain records of business customer details and deliveries for B2B sales
Record retention: Ensure records are kept for minimum retention periods (6 months to 5 years)
Batch code linking: Link internal batch codes to supplier batch numbers for rapid tracing
Incident response plan: Create food incident response plan including recall procedures
Safety issue response: Immediately stop supply and notify FSA if product safety issue identified
Allergen alert preparation: Prepare to issue allergy alert via FSA system for allergen issues
FSA contact details: Keep FSA incident notification contact details accessible

Food alerts and product recalls

Alcohol duty compliance

Alcoholic drink producers must understand and comply with duty rates and payment obligations:

Alcoholic Liquor Duties - Excise Duty and Approval

Producers and wholesalers of alcoholic products must register with HMRC, account for alcohol duty, and comply with duty payment and warehousing requirements. Duty rates vary by product type and strength. Producers receive Small Producer Relief on beer and spirits.

Who must register for alcohol duty

You must register with HMRC if you:

Produce alcoholic products for sale in the UK
Import alcoholic products from outside the UK
Store duty-suspended alcohol in an excise warehouse
Operate as a registered dealer (wholesaler)

Alcohol duty rates (from 1 August 2025)

Beer:

≤3.4% ABV: £9.27 per litre of pure alcohol
>3.4% ABV: £23.39 per litre of pure alcohol
Small Producer Relief available (50% reduction for smallest producers)

Spirits:

Standard rate: £31.64 per litre of pure alcohol
Small Producer Relief available (reduced rates for craft distillers)

Wine and cider:

Wine ≤8.5% ABV: £95.04 per hectolitre
Wine 8.5-15% ABV: £297.57 per hectolitre
Cider ≤7.5% ABV: £9.67 per litre of pure alcohol

Small Producer Relief

Small breweries and distilleries producing below annual thresholds receive reduced duty rates:

Beer: Relief for producers under 5,000 hectolitres per year
Spirits: Relief for producers under 100,000 litres of pure alcohol per year

Duty payment timing

Duty is due when alcohol:

Leaves an excise warehouse
Is imported into the UK
Is produced outside duty suspension arrangements

Most producers pay duty quarterly via direct debit.

Producer registration: Register as an alcohol producer with HMRC before you start production
Premises approval: Apply for approval of production premises and processes
Small Producer Relief: Apply for Small Producer Relief status if eligible
Duty accounting system: Implement duty accounting system to track production volumes and duty liability
Quarterly returns: Submit quarterly returns declaring volumes produced and duty due
Payment arrangement: Arrange direct debit for duty payments
Production records: Maintain production records (volumes, ABV, duty calculations) for 6 years
Import declarations: Declare alcohol via Customs Declaration Service and pay duty for imports

Alcohol duty registration and rates

Packaging regulations

All packaging must meet essential requirements for composition, minimisation, and recoverability:

Packaging (Essential Requirements) Regulations

All packaging placed on the UK market must meet essential requirements for composition (limits on heavy metals), reusability and recoverability, and minimisation of weight and volume. Businesses must maintain technical documentation demonstrating compliance.

Three essential requirements

All packaging must comply with:

1. Composition and reusable/recoverable nature

Heavy metals (lead, cadmium, mercury, hexavalent chromium) must not exceed 100 ppm in total
Packaging must be capable of being reused or recovered (recycling, composting, energy recovery)

2. Minimisation

Weight and volume must be minimised while maintaining safety, hygiene, and consumer acceptance
Must not contain components or materials in excess of requirements

3. Reuse or recovery targets

Reusable packaging must withstand minimum number of journeys
Recoverable packaging must meet minimum energy or material recovery values

Technical documentation requirement

You must hold or have access to technical documentation demonstrating compliance with essential requirements. This includes:

Analysis of packaging composition (materials, weights)
Justification of weight and volume used
Certificates from material suppliers confirming heavy metal limits
Evidence of recyclability or recoverability

Who is responsible

The 'packer/filler' (business that places goods in packaging) or importer is responsible for compliance and maintaining documentation.

Packaging review: Conduct packaging review to identify weight and volume minimisation opportunities
Heavy metal compliance: Request heavy metal compliance certificates from packaging suppliers
Technical documentation: Prepare technical file documenting material specifications and justification
Recyclability consideration: Consider recyclability and recycled content when specifying new packaging
Regular design review: Review packaging designs regularly to ensure ongoing minimisation
Record maintenance: Maintain records of packaging specifications and compliance evidence
Imported goods documentation: Ensure supplier provides technical documentation for imported packaged goods

Packaging essential requirements

Waste and environmental obligations

Food businesses must comply with duty of care for waste, food waste separation from 31 March 2025, and trade effluent controls:

Environmental Protection - Waste Disposal and Trade Effluent

Food businesses must comply with waste management regulations including duty of care for waste disposal, trade effluent consents for wastewater discharge, and separation of food waste for commercial composting (larger businesses). Penalties for illegal disposal include unlimited fines and imprisonment.

Duty of care for waste

All businesses producing waste have a duty of care to:

Store waste securely to prevent escape
Only transfer waste to authorised carriers or exempt persons
Complete waste transfer notes describing the waste
Keep waste transfer records for at least 2 years

Failure to meet duty of care is a criminal offence with unlimited fines.

Food waste separation (from March 2025)

From 31 March 2025, all food businesses (except smallest) must separate food waste for collection and commercial composting or anaerobic digestion. You cannot:

Mix food waste with general waste
Send food waste to incineration or landfill if separation is possible

This applies to businesses and organisations that produce more than a de minimis amount of food waste.

Trade effluent consent

If your business discharges wastewater containing food waste, fats, oils, or chemicals to the sewer, you need a trade effluent consent from your water company:

Restaurants and commercial kitchens
Food manufacturers
Breweries and dairies

Discharge without consent is a criminal offence. Water companies charge for trade effluent based on volume and strength (chemical oxygen demand).

Grease traps

Many food businesses require grease traps (grease separators) to prevent fats, oils, and grease entering drainage systems. Water companies can require installation as a condition of trade effluent consent.

Waste producer registration: Register with Environment Agency as a waste producer if required
Licensed waste carrier: Contract with licensed waste carrier and obtain copy of their waste carrier licence
Waste transfer notes: Complete waste transfer notes for all waste collections
Documentation retention: Keep waste transfer documentation for at least 2 years
Food waste separation: Arrange separate food waste collection with licensed contractor from March 2025
Trade effluent consent: Apply for trade effluent consent from water company if discharging wastewater to sewer
Grease trap installation: Install and maintain grease trap if required by water company
Grease trap maintenance: Empty grease trap regularly and dispose of contents via licensed waste contractor
Drainage protection: Never discharge fats, oils or food waste directly to drains

Waste duty of care

Animal by-products regulations

Catering waste and food containing animal products must be disposed of correctly under ABP regulations:

Animal By-Products Regulations (ABP)

Businesses handling animal by-products (catering waste, meat, fish, dairy waste) must comply with controls on collection, transport, storage, and disposal. ABP is classified into three categories by risk level. Most catering waste is Category 3 and must be disposed via approved processors.

What are animal by-products?

Animal by-products (ABP) are entire bodies or parts of animals, or products of animal origin not intended for human consumption. This includes:

Catering waste (any food waste from catering premises containing or having contacted meat or fish)
Meat and fish trimmings
Dairy products no longer fit for consumption
Shells from shellfish
Animal carcases

ABP Categories

Category 1 (highest risk): TSE risk material, illegal meat, pet animals

Category 2 (medium risk): Manure, digestive tract content, condemned meat

Category 3 (lowest risk): Parts fit for human consumption but not used (catering waste, former foodstuffs)

Most food business waste is Category 3.

Key requirements

Collection: Must use approved ABP transporter
Storage: Must be stored securely in leakproof containers
Disposal: Must go to approved ABP processor (not general waste)
Records: Commercial documents must accompany all ABP movements
Separation: Category 3 ABP must be kept separate from non-ABP waste

Swill feeding ban

It is illegal to feed catering waste to livestock (pigs, poultry). This has been banned since 2001 following the foot-and-mouth disease outbreak. Severe penalties apply.

ABP identification: Identify if your business produces animal by-products (catering waste containing meat/fish)
Approved collector: Contract with an approved ABP collector (check APHA register)
Storage containers: Provide leakproof, secure containers for ABP storage
Waste separation: Store ABP separate from general waste
Commercial documents: Ensure commercial documents accompany all ABP collections
Record keeping: Keep ABP disposal records for at least 2 years
Disposal restrictions: Never dispose of ABP via general waste, compost, or feeding to animals
Butchery registration: Register as an ABP producer with APHA if operating a butchery

Animal by-products regulations

Key compliance actions

Implement traceability system recording all suppliers and business customers
Keep records for minimum retention periods (6 months to 5 years depending on product)
Prepare food incident response plan including recall procedures
Contract with approved ABP collector if handling meat or fish waste
Arrange separate food waste collection from 31 March 2025
Apply for trade effluent consent if discharging to sewer
Maintain packaging technical documentation demonstrating essential requirements compliance
Review HFSS status of products if operating large retail premises

Business Context Testing

Content Graph

Guvnor

Food and drink regulations and traceability

Front-of-pack and HFSS labelling

Food traceability and recall obligations

Alcohol duty compliance

Packaging regulations

Waste and environmental obligations

Animal by-products regulations

Key compliance actions

Compliance Assistant

🧪 Business Context Testing

◉ Content Graph

Front-of-pack and HFSS labelling

Food traceability and recall obligations

Alcohol duty compliance

Packaging regulations

Waste and environmental obligations

Animal by-products regulations

Key compliance actions

Related guides in Environmental Permits

Business Context Testing

Content Graph