What is UK Food Safety Compliance After Brexit?
Since the UK's departure from the European Union, UK food businesses now operate under a distinct regulatory framework separate from EU food law. UK food safety compliance is governed by retained UK legislation, including the Food Safety Act 1990, UK HACCP regulations, and workplace safety laws such as COSHH (Control of Substances Hazardous to Health), RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations), and internationally recognised standards such as ISO 45001. Understanding these requirements is essential for any food business operating in or exporting to the UK.
Why UK Food Safety Compliance Matters After Brexit
- Separate regulatory framework: UK food businesses no longer follow EU regulations directly — they must comply with UK-specific retained law and new GB-specific requirements.
- Market access: Exporting food to the UK requires compliance with UK import requirements, including UK HACCP, labelling rules, and border controls.
- Legal obligation: COSHH, RIDDOR, and food hygiene regulations carry significant penalties for non-compliance, including prosecution and business closure.
- Retailer requirements: Major UK retailers (Tesco, Sainsbury's, M&S) require BRCGS or equivalent GFSI certification, which incorporates HACCP, COSHH, and safety management.
- Employee protection: ISO 45001 and RIDDOR compliance protects workers and demonstrates due diligence in occupational health and safety.
- Certification readiness: COSHH and RIDDOR compliance is embedded in BRCGS Issue 9, ISO 45001, and other UK-recognised standards.
Key UK Food Safety Regulations After Brexit
UK HACCP Requirements
Under Regulation (EC) 852/2004 as retained in UK law, all food businesses must implement food safety management procedures based on HACCP principles. The Food Standards Agency (FSA) and Food Standards Scotland (FSS) enforce these requirements across England, Wales, Scotland, and Northern Ireland.
COSHH (Control of Substances Hazardous to Health)
COSHH regulations (SI 2002/2677) require food businesses to assess and control risks from hazardous substances used in food production — including cleaning chemicals, disinfectants, pesticides, and food additives. Key COSHH requirements include:
- COSHH risk assessment for all hazardous substances on site
- Substance inventory and Safety Data Sheets (SDS) maintained
- Exposure controls implemented (ventilation, PPE, substitution)
- Health surveillance where required
- Employee training on COSHH hazards and controls
- Regular review of COSHH assessments
RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013)
RIDDOR requires food businesses to report certain workplace incidents to the Health and Safety Executive (HSE). Reportable events include:
- Deaths and specified injuries (fractures, amputations, loss of sight)
- Over-7-day incapacitation injuries
- Occupational diseases (e.g., dermatitis, occupational asthma from food allergens)
- Dangerous occurrences (near misses with serious potential)
- Gas incidents
Reports must be submitted to the HSE via the online RIDDOR reporting portal within the required timeframes (immediate for fatalities, 10 days for over-7-day injuries).
ISO 45001 Occupational Health and Safety
ISO 45001:2018 is the international standard for OH&S management systems and is increasingly required by UK food retailers and procurement teams. It provides a systematic framework for managing workplace safety risks, incorporating COSHH and RIDDOR compliance within a broader management system.
UK vs EU Food Safety Compliance: Key Differences After Brexit
| Area | EU Requirement | UK Requirement (Post-Brexit) |
|---|---|---|
| HACCP basis | Regulation (EC) 852/2004 | Retained UK law (same basis) |
| Food labelling | EU FIC Regulation 1169/2011 | UK FIC (GB-specific rules) |
| Import controls | EU border checks | UK Border Target Operating Model |
| Organic certification | EU organic logo | UK organic logo (separate) |
| Novel foods | EU Novel Food Regulation | UK Novel Food authorisation |
| Workplace safety | EU Framework Directive | UK Health and Safety at Work Act 1974 |
UK Food Safety Compliance Implementation Steps
Step 1: HACCP Plan Review and Update
Review your existing HACCP plan against UK FSA guidance. Ensure all hazard analyses, CCPs, and monitoring procedures reflect current UK regulatory requirements and your specific products and processes.
Step 2: COSHH Assessment
Compile a complete inventory of all hazardous substances on site. Conduct COSHH risk assessments for each substance, implement appropriate controls, and ensure Safety Data Sheets are current and accessible.
Step 3: RIDDOR Compliance Setup
Establish an incident reporting procedure that identifies RIDDOR-reportable events, assigns responsibility for reporting, and maintains records of all incidents and near misses.
Step 4: ISO 45001 Implementation
Implement an OH&S management system aligned with ISO 45001, incorporating hazard identification, risk assessment, legal compliance evaluation, and continual improvement processes.
Step 5: Staff Training
Ensure all employees receive training on UK food hygiene regulations, COSHH hazards, RIDDOR reporting obligations, and emergency procedures.
Step 6: Internal Audit and Management Review
Conduct regular internal audits of your food safety and OH&S systems. Hold management reviews to evaluate performance and drive continual improvement.
Which UK Food Businesses Need COSHH, RIDDOR, and ISO 45001?
- Food manufacturers and processors → All three apply
- Restaurants, cafes, and catering companies → HACCP + COSHH + RIDDOR mandatory
- Food retailers and distributors → HACCP + COSHH + RIDDOR apply
- Businesses supplying UK supermarkets → ISO 45001 increasingly required alongside BRCGS
- EU businesses exporting to the UK → Must meet UK import requirements and equivalent standards
Get UK Compliance-Ready with Ready-Made Documentation
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