The Future of Food Regulation: What It Means for Environmental Health

As the discussions around the future of food regulation continue to gather pace, CIEH Chief Executive Officer Fran McCloskey looks back on the journey so far and sets out CIEH's current thinking on the challenges and opportunities that lie ahead...

In conversations with members across the nations, I have heard how uncertain many are about the future of food regulation and how much they want to understand what is changing, what it could mean for environmental health and, importantly, what CIEH is doing about it. I have heard questions such as: Do these proposals make sense? Will they make my job easier or harder? Will public protection be better or worse? Will qualified Environmental Health Practitioners (EHPs) still matter? These are entirely reasonable questions. There is still much that remains to be decided, and some of the most important details will emerge only through the next phase of design and development.

What I am clear about is that environmental health professionals sit at the heart of the food system. Every day, your knowledge, judgement and experience turn regulation into effective public protection. Whatever model ultimately emerges, public protection will continue to depend on competent professionals exercising sound professional judgement.

CIEH is working to influence the reforms so that they strengthen public protection, make effective use of professional expertise, and can be delivered successfully in practice.

There are opportunities to improve the current system. Better use of reliable, properly validated data could help environmental health professionals identify risk earlier and focus finite resources where they can make the greatest difference. At the same time, reform must not weaken local intelligence, independent oversight, or the ability to intervene when something goes wrong.

I have particularly valued the opportunity to bring together different parts of the profession in a way that rarely happens. Through CIEH, local authorities, businesses, Primary Authorities, assurance providers and academics have been engaging directly with one another as members of the same profession. By creating those connections, the profession can build greater understanding, identify shared priorities, and strengthen the profession's collective influence. I hope the relationships and collaboration emerging from this work will deliver benefits well beyond the Food Standards Agency’s (FSA’s) Future of Food programme itself.

At its September Board meeting, the FSA reviewed six possible approaches – or ‘frameworks’ - and agreed that two of these approaches should move into detailed design. The FSA Board discussion indicated that the frameworks were not necessarily mutually exclusive, and that elements of other frameworks might also inform the next stage.

CIEH will continue to engage actively in the next phase of the programme, applying the same focus on public protection that has guided our work to date. The proposals now moving into detailed design have the potential to bring benefits, but important questions remain about accountability, evidence, independent scrutiny, workforce implications, funding, delivery, and the role of local regulation. Our focus will be on ensuring those questions are properly explored and that any changes can demonstrate a clear public protection benefit, are practical to deliver, and make effective use of professional expertise across the system.

The Principles Guiding CIEH

For me, the most important question is whether the changes ultimately adopted will deliver better public protection and maintain confidence in the regulatory system. As the proposals develop, CIEH will continue to consider a number of important questions, including:

• Will the changes strengthen public protection and consumer confidence?
• Are accountability, independent scrutiny and enforcement responsibilities clear?
• Do they support the effective use of professional judgement, local intelligence and the ability to intervene where necessary?
• Do they make appropriate use of trusted, robust and properly validated data?
• Are they practical, deliverable and supported by the workforce, resources and infrastructure needed to make them work in practice?
• Do they appropriately reflect the different legislative, regulatory and delivery arrangements across England, Wales and Northern Ireland?

What We Have Heard So Far

To support our work, we asked a small group of members and stakeholders to consider the six original frameworks against a common set of criteria. This included members from all parts of the system and experts from our Food Advisory Panel. This was not a formal consultation, and the responses cannot be treated as representative of the whole membership. They do, however, provide valuable insight, which we shared with the FSA.

Views on the frameworks differed, but most participants found it difficult to reach an overall assessment at this stage of their development. Nonetheless, several consistent themes emerged from the feedback:

• Better use of data could help environmental health professionals and regulators identify emerging risks earlier, make better-informed decisions and deploy scarce resources where they will have the greatest impact, but only if the data is reliable, current and capable of independent validation.
• Greater consistency and better use of intelligence may be possible, but local knowledge and on-site verification remain essential.
• Third-party assurance may contribute useful evidence, but it cannot simply be assumed to be equivalent to independent official controls.
• Public protection depends on competent professionals delivering consistent, high-quality regulatory outcomes.
• The workforce, funding and technology requirements, and the implications for the three nations, the Food Hygiene Rating Scheme (FHRS) and public confidence, must be fully understood before any model is taken forward.

Competence, Consistency and Accountability

CIEH has spent decades building trusted standards of competence and professionalism. Any future system must ensure that those carrying out inspections, audits, assurance or regulatory activity are appropriately qualified, demonstrably competent, independently assured and operating to consistent standards.

The detailed design should establish transparent and consistently applied requirements for qualifications, competence, assurance, and accountability. The system must be clear about who is responsible for assessing compliance, verifying information, making decisions, and taking enforcement action.

Public protection depends on clear accountability, competent professionals, consistent standards, and independent scrutiny.

Alongside the two regulatory frameworks being taken forward, the Future of Food programme includes several other workstreams, including mandating the FHRS in England, registration models, the use of data and intelligence, and wider reforms to the regulatory system. CIEH is actively engaging with the FSA’s emerging proposals in real time. Our focus is to ensure that any changes strengthen public protection while supporting and strengthening the profession.

Wider Food Work

CIEH continues to work closely with the FSA, local authorities and training providers to develop a new Level 4 Regulatory Compliance Officer apprenticeship in food. The apprenticeship is intended to create an additional route into the profession, support succession planning and workforce resilience, and help local authorities recruit and develop the skilled people needed to deliver food regulation services in the future.

CIEH has suggested to the FSA that it examines whether the current food hygiene and food standards inspection programmes remain the most effective approach for public protection and the workforce. This conversation has been informed by several factors: our work with the Royal Environmental Health Institute of Scotland (REHIS) on recognition of qualifications; feedback from some members that operating two separate inspection programmes to support similar regulatory landscapes can place pressure on scarce capacity; and the fact that some local authorities either already combine these inspections (unitary authorities) or are bringing food hygiene and food standards functions together within environmental health teams (a trend that may become more common through local government reorganisation). CIEH is not advocating a predetermined outcome. Any assessment should examine the potential benefits, risks and practical implications, draw on experience across the nations, and involve specialists from relevant disciplines before conclusions are reached.

CIEH has also asked the FSA to explore whether appropriately qualified and authorised EHPs could undertake a broader role in official controls for products of animal origin. This is a question for proper examination, and we are not hidebound by a predetermined recommendation about how responsibilities should be divided. Any potential change would require careful assessment of the legal framework, the competencies and authorisations required, workforce implications and, above all, whether it would strengthen public protection.

The UK-EU SPS agreement could have consequences extending beyond ports to food businesses and inland local authorities. We are seeking clearer information about implementation, the support that will be available to local authorities and smaller businesses, and the guidance the FSA intends to provide. CIEH will communicate with members as more information becomes available.

The FSA's future role in delivering the Government's healthier food agenda is still evolving. CIEH has been highlighting the contribution that environmental health can make through practical delivery experience, regulatory insight and evidence from locally-led interventions that have improved health outcomes.

School food standards are another area we are watching closely. Work led by the Department for Education and the FSA explored how school food standards checks could be incorporated into existing inspection activity. The pilot has led to increasing discussion about a future role for environmental health professionals in supporting school food standards. CIEH would be supportive of these ambitions in principle, although important questions remain around scope, funding, capacity, and delivery.

Working With Members

The conversations I and colleagues across CIEH have had with members are helping to ensure that the profession’s experience and expertise shape our engagement with the FSA. Those discussions have highlighted both the opportunities and the challenges within the emerging proposals, and they will continue to shape evidence-based CIEH positions as the programme develops.

Food regulation is complex, and much of this work will require further evidence, careful evaluation and continued engagement with members and stakeholders before CIEH reaches firm conclusions.

Our engagement with all this work is guided by the principle endorsed by members at the 2026 AGM: that technology, data and assurance should support professional judgement, not replace the human expertise, accountability and decision-making that underpin effective public protection.

That means continuing to make a simple but important case: public protection is best served by a properly qualified, competent and supported profession, operating within a system in which responsibilities are clear and standards are applied consistently and independent scrutiny is maintained. Confidence in the system depends on it.

There is still much that has not been decided by the FSA. As this work develops, we will continue to seek members' views, test emerging proposals against our principles and advocate for arrangements that are evidence-based, properly resourced and capable of maintaining public confidence. Where reforms can strengthen the system, we will support them. Where concerns remain, we will continue to raise them.

Finally, I would like to thank everyone who has contributed their time, experience and expertise to these discussions. The willingness of members and stakeholders from across the profession to share their perspectives has strengthened CIEH's contribution and helped bring different parts of the system together. I hope the relationships, understanding and collaboration developing through this work will not only improve the quality of the reforms, but also leave the profession better connected, more influential and better placed to shape future public protection challenges.