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FSA Board Meeting - December 2025: Agenda and Papers
Victoria Hall, Town Hall, Reading, RG1 1QH
The agenda for this meeting includes:
- Evaluation of the Meat Charging Discount Regime: Proposals for Revised Support System
- FSA Position on the Codex Precautionary Allergen Labelling Standard including Allergen Thresholds
- National Food Crime Unit Annual Update
- Annual Communications Update
- Annual Governance Report
- Report from the Chair of the Northern Ireland Food Advisory Committee (NIFAC)
09:00 Chair's Introduction and Chair's Report
Professor Susan Jebb presents the minutes and actions from the previous FSA Board meeting in September 2025 and presents the Chair's report.
FSA 25/12/01- Minutes of 17 September 2025 Board Meeting
FSA 25/12/02 - Actions Arising
09:20 Chief Executive's Report (FSA 25/12/03)
Katie Pettifer presents the Chief Executive's report to the FSA Board.
FSA 25/12/03 - Chief Executive's Report.
09:55 Evaluation of the Meat Charging Discount Regime: Proposals for Revised Support System (FSA 25/12/04)
James Cooper introduces a paper providing an update on progress towards a revised system of support for some abattoirs through our charging model for regulation.
FSA 25/12/04 - Evaluation of the Meat Charging Discount Regime: Proposals for Revised Support System
10:35 Break
10:55 FSA Position on the Codex Precautionary Allergen Labelling Standard including Allergen Thresholds (FSA 25/12/05)
James Cooper introduces a paper setting out the latest on the Codex proposals for a global standard on Precautionary Allergen Labelling (PAL), including the use of thresholds.
11:25 National Food Crime Unit Annual Update (FSA 25/12/06)
Reginald Bevan introduces a paper detailing the activities and achievements of the National Food Crime Unit (NFCU) from the period of November 2024 to November 2025.
FSA 25/12/06- National Food Crime Unit Annual Update
11:45 Annual Communications Update (FSA 25/12/07)
Claire Forbes, Director of Communications, presents a paper providing an update on the work of the FSA’s communications team.
FSA 25/12/07 - Annual Communications Update
12:05 Annual Governance Report (FSA 25/12/08)
Timothy Riley introduces the Governance Report for 2025.
FSA 25/12/08 - Annual Governance Report
12:25 Lunch
13:10 Report from the Chair of the Northern Ireland Food Advisory Committee (NIFAC) (FSA 25/12/09)
Anthony Harbinson introduces his report as the Chair of the Northern Ireland Food Advisory Committee (NIFAC) on the activity of the Committee for the period December 2024 to November 2025.
FSA 25/12/09 - Report from the Chair of the Northern Ireland Food Advisory Committee (NIFAC)
13:25 Report of November ARAC meeting (INFO 25/12/01)
INFO 25/12/01 - Report of November ARAC meeting.
13:35 Report from the Chair of the Business Committee (INFO 25/12/02)
INFO 25/12/02 - Report from the Chair of the Business Committee.
13:45 Reports from the Chairs of the Food Advisory Committees (Oral Reports)
13:55 Any Other Business
14:00 Questions
14:10 Close
Questions to the Board
We are keen to ensure, as far as is practical, that questions are addressed in the discussion at the Board meeting. Notwithstanding discussions on the day, all questions will receive a written reply within 20 working days of the meeting.
For questions that do not relate to a paper on the agenda, please email correspondence@food.gov.uk and we will aim to respond within 20 working days. Please note these submissions and their replies will not generally be published.
Please note questions are listed below in the order in which they were received.
Question 1
From: Dr Mark J Tallon, Managing Director, Legal Products Group Ltd
Where allergens are below the ED01 level as tested for via industry standard ELISA can this support a free from claim such as Free from Soy or other tested allergen?
These 'Free from' claims are in a similar manner based on PAL and threshold testing yet there are no conditions of use as in Regulation 1924/2006 (Annex of nutrition claims). As such must be based on fact.
However, whilst the ED01 level maybe qualified by testing for the presence of an allergen it may exist in the product (below LOD). Such "free from" claims may induce a consumer with an allergen to use the product.
Given the statement at 3.7 in the codex / allergen discussion, there are no reports in the experimental literature of severe reactions from levels below ED08.
As such can business use the ED01 level be used to support a "free from X" allergen claim on a food label?
Question 2
From: Boyd Butler, IFIS Publishing Ltd
Would you consider countering mis- and disinformation about food safety by creating an App which will be freely accessible to provide consumers with accurate information based in science but translated into simple, clear language? This could be done for less than £10,000 and would be a great start to digital communications.
Question 3
From: Cefyn Jones, Founder: The Hemp Hound Agency
Paper FSA 25-12-08 outlines the Board’s commitments to transparent governance, consistent decision-making, and effective stakeholder engagement.
Paragraph 3.4 highlights that the upcoming GIAA Effectiveness Review will evaluate leadership and culture, risk management, and partnership working.
Annex 2 (ARAC Terms of Reference) and Annex 5 (Standing Orders) emphasise the importance of assurance, risk oversight, declaration of interests, and the integrity of internal processes.
In that context, could the Board clarify how these governance principles operate in practice at the level of individual stakeholder interactions in regulated products processes (including Novel Foods and Article 4 submissions)?
Specifically:
Consistency of Reasonable Adjustments:
Where reasonable adjustments have previously been granted to a stakeholder in an FSA process, is there an expectation within the Board’s governance framework that such adjustments should be applied consistently in subsequent, comparable processes?
Prior Involvement and Interests of Senior Officials:
How does the Board assure itself that senior officials who have previously been involved in related matters appropriately declare that involvement—and any external interests—before assuming oversight or sign-off responsibilities in a new decision affecting the same stakeholder?
Integrity of Email Filtering and FOI-Relevant Correspondence:
Given ARAC’s responsibilities for governance, assurance and risk (Annex 2), what oversight is in place to ensure that internal email filters, routing rules or mailbox management systems cannot inadvertently prevent stakeholder engagement or impede correspondence that may have FOI or governance implications?
A general clarification on these points would support stakeholders across the hemp and CBD sector in understanding how the Board monitors and enforces the governance standards set out in FSA 25-12-08.
Question 4
From: Cefyn Jones, Founder: The Hemp Hound Agency
Paper FSA 25-12-07 sets out the Agency’s communications approach, including its emphasis on mitigating mis- and disinformation (Sections 3.1–3.3), engaging stakeholders to increase advocacy and insight (Section 2.3), and ensuring proportionate messaging to different consumer and business groups.
Given this, could the Board clarify the governance principles underlying how the FSA determines:
Which stakeholder voices are included or excluded
Section 2.3 notes that communications work “convenes stakeholders to increase advocacy, influence and insight”.
What criteria does the Agency apply when deciding which stakeholders, sectors, or subject-matter experts are engaged during communications planning — and how is balance ensured where the subject area includes scientific disagreement or contested policy?
How the FSA distinguishes between misinformation and legitimate criticism
Section 3.3 refers to mitigating mis- and disinformation and collaborating with the Science Council to prepare content for topics “most at risk of being misrepresented.”
What internal checks ensure that legitimate stakeholder concerns, emerging science, or unresolved regulatory questions are not treated as misinformation or risk-tagged without appropriate scientific scrutiny?
How proportionality is applied to niche or emerging sectors
The paper highlights large-scale campaigns (slush drinks, allergens, food hygiene) but does not set out criteria for niche food sectors that experience frequent regulatory ambiguity or media distortion.
What framework ensures that communications about smaller regulated sectors are proportionate, evidence-based, and do not contribute to inadvertent commercial, reputational, or market harm?
How prior communication controversies are internally reviewed
Does the Board receive assurance that past stakeholder-facing communication decisions — especially where public or parliamentary challenge has occurred — are reviewed for lessons learned?
Clarification on these points would help small and emerging sectors understand how FSA communication policy safeguards fairness, accuracy and proportionality across diverse food industries.
Question 5
From: Peter Hewson, Veterinary Director, AIMS
AIMS notes that the paper on meat charges discounts makes clear that it does not have the support of industry but is disappointed that the reasons for that opposition get no mention. There are two principal reasons. The first is that there is general acceptance that current complex time-based system is not fit for purpose and replacement by a simple headage system, as used by most of Europe, would completely do away with the need for a discount regime. The second is that a judicial review challenging the legality of charging full cost recovery is due to be heard in the High Court on 5th and 6th of May next year, and, if successful, will have a huge impact on the Agency's proposals. Would it not be sensible to put work on the discount on hold until after the judgment is handed down and in the meantime for the FSA to work with industry to address some of the failings of the current charging system?
Question 6
From: Louis Franks, Association of Port Health Authorities
Given the NFCU’s reliance on intelligence from LAs at the border and inland when investigating and tracking illegal POAO imports, would the FSA consider promoting the use of IDB (the national intelligence database) amongst local food authorities and supporting a pilot to test it in this context? A particularly common example is illegal POAO mixed in with disposable vapes. Another example is the risk of African Swine Fever from the import of pork products from Europe and the lack of checks at the border.
To our knowledge there is no other software which enables the sharing of sanitised intelligence amongst users. All Trading Standards services in the country already make use of it. EH services are often not aware that they can access IDB, incorrectly assuming it’s a TS tool. Where it exists in a unitary council, a licence amendment (no fee) is all that’s needed to extend the software to EH.
Without such a system, each LA is operating in isolation, ‘blind’ to what’s going on in the neighbouring borough or elsewhere in the country, as details such as vehicle number plates, driver names etc. cannot be shared via email or via Hub, for example.
Question 7
From: Sandeep Kapil, AllergyAwareUK
NICE guidance on the prevention and treatment of vitamin D deficiency explicitly requires that suitable products be made available for people with specific dietary and religious needs, including Halal. This is clearly intended to improve inclusion and adherence. However, there is growing concern that some medicine and food-supplement manufacturers may be commercially exploiting this guidance by making partial or ambiguous Halal or Kosher claims that fall short of full product and process certification.
For example, promotional materials for certain licensed vitamin D medicines currently state that “the capsules contain gelatine, which is certified as Halal and Kosher”, despite Halal compliance requiring whole-product and process certification, not merely certification of one excipient. In the food supplement sector, similar Kosher claims are also appearing without transparent verification.
This is not a theoretical risk. A previous UK regulatory case concerning Adcal-D3 (ProStrakan) found that even where one component was Halal-certified, representing the product as suitable for a strict Halal diet without full certification was ruled misleading and in breach of professional codes
Prostrakan Case
. This demonstrates how easily communities can be misled where religious dietary claims are loosely applied.
Given that:
• Halal and Kosher status are legally protected food authenticity claims,
• Misrepresentation of food status is explicitly recognised as a form of food crime, and
• The public reasonably expects UK regulators to protect them from misleading religious dietary claims,
What role does the FSA see for itself, alongside MHRA and local authorities, in monitoring, regulating and enforcing the accuracy of Halal and Kosher claims across both food supplements and the wider consumer interface of medicines?
And, in light of the increasing food-crime risk around document fraud and misrepresentation, does the FSA intend to issue clearer national guidance to protect consumers and faith communities from partial or misleading dietary certification claims?"