Food Safety Compliance For UK Food Manufacturers

Food manufacturers in the UK are facing increasing pressure to ensure regulator and food safety compliance. In addition, manufacturers are dealing with evolving regulations, heightened consumer scrutiny, and post-Brexit complexity. So whether your food business is supplying national retailers or operating a regional production facility, meeting legal and audit requirements is crucial to business continuity and market access and success.

In this article, we outline how food businesses can build and maintain robust food safety compliance in line with UK law and global certification standards like BRCGS and ISO 22000. We’ll also give our tips for best practices for manufacturers of all sizes.

Contents:

UK food businesses are legally required to ensure that the food they produce is safe and accurately labelled. The foundation of compliance lies in a number of key regulations for the industry, including The Food Safety Act 1990, General Food Law, as well as EU retained laws post-Brexit, including Regulation (EC) No 852/2004 on food hygiene.

Some of the requirements for these types of regulations include:

• Implementing safeguards to prevent cross-contamination
• Ensuring all ingredients are accurately declared on packaging
• Withdrawing or recalling unsafe food products immediately
• Ensuring all surfaces in contact with food are easy to clean and disinfect
• Regular testing of water used in food production
• Preventing animals and pests from entering production areas

The above list is a summary of example requirements. For specific requirements for each of the regulations referred to above, please refer to their own documentation.

We recommend that businesses familiarise themselves with the relevant regulations. By understanding how these legal obligations translate into day-to-day practices, UK food manufacturers can take a proactive approach to compliance and reduce the risk of enforcement action.

The core of all food safety compliance in the UK is a properly implemented Hazard Analysis and Critical Control Point (HACCP) plan. This is also a legal requirement for businesses and must be tailored to each site’s risk and operations.

Hazard Analysis and Critical Control Points (HACCP) is a systematic approach to identifying, evaluating, and controlling food safety hazards throughout your production process. In the UK it is a legal requirement for all food businesses, regardless of size, to implement a HACCP based food safety management system.

HACCP focuses on seven key principles:

1. Conduct a Hazard Analysis
   Identify any biological, chemical, or physical hazards that could occur at each stage of production, from raw ingredient intake through to finished product dispatch.
   For example: Listeria contamination in chilled ready meals or metal fragments from poorly maintained machinery.
2. Determine Critical Control Points (CCPs)
   Pinpoint the specific steps in the process where a hazard can be prevented, eliminated, or reduced to a safe level.
   For example: Cooking temperatures to kill pathogens, or filtration to remove foreign particles.
3. Establish Critical Limits
   Set the minimum and maximum value that must be met to ensure safety at each CCP.
   For example: Minimum core temperature of 75 degrees celsius for cooked poultry.
4. Implement Monitoring Procedures
   Put in place systems to monitor CCPs and ensure they remain within critical limits.
   For example: Using automated sensors to continuously track cooling times or pH levels.
5. Establish Corrective Actions
   Define what action to take when monitoring indicates a CCP has been breached.
   For example: Reprocessing a batch or initiating a product hold for further inspection.
6. Establish Verification Procedures
   Regularly review and verify that the HACCP plan is working effectively.
   For example: Internal audits, microbiological testing, or third-party inspections.
7. Maintain Documentation and Records
   Keep accurate records to demonstrate compliance and enable traceability.
   For example: Temperature logs, training records, and corrective action reports.

HACCP is focussed on building a robust food safety culture in your business, a culture that proactively reduces risk, protects the consumer and enhances your brand’s reputation. It can be scaled to your business size too: small businesses can use simplified templates or guidance provided by the Food Standards Agency (FSA); larger, multi-site operations can use a digital HACCP system that can streamline monitoring, alerts, and record-keeping.

There a number of benefits of HACCP for UK food manufacturers:

• It helps you pass regulatory inspections and third-party audits
• It minimises the risk of costly product recalls and foodborne illness outbreaks
• It enhances transparency and accountability across teams
• It boosts customer and retailer confidence in your products
• It provides structured documentation for due diligence in the event of a complaint or legal challenge

Many food manufacturers may choose to go beyond legal compliance, and seek voluntary food safety certifications to meet certain retailer requirements and/or improve operational rigour.

It’s important you choose the appropriate food safety certificate for your business, as each has their own standards you need to comply with and different certificates might be expected by suppliers and customers in certain sectors.

Below we’ve broken down the three leading certifications that UK food manufacturers are adopting, with details on who they’re best suited for and their benefits:

Choosing the right framework depends on your supply chain, retailer expectations, and in-house capabilities. When selecting a certification to apply for, make sure you consider the following:

• Customer and market expectations – are customers or clients requesting a specific standard
• Operational complexity and scale – larger operations may benefit from FSSC 22000 or BRCGS
• Existing management systems – ISO 22000 may integrate better if you’re already ISO certified
• Future growth and trade ambitions – choose a strategy that aligns with your export strategy

An effective food safety management system isn’t just a case of reports and paperwork, it’s built around a culture of food safety that is embedded into your daily operations.

We’ve put together a step-by-step guide below on building and maintaining an effective food safety management system that aligns with UK regulations and global standards:

You need to first identify the relevant legal and certification standards that apply to your business, think:

• UK Food Safety Act 1990 and other associated hygiene regulations
• Requirements for third-party certifications like BRCGS, FSSC 22000 or ISO 22000
• Sector specific guidelines (e.g. for dairy and meat)

We recommend: Consulting your local authority or a qualified food safety consultant to verify which requirements apply to your site and products.

These are basic hygiene and operational practices that must be in place before applying HACCP principles. Common prerequisite programs include:

• Cleaning and sanitation procedures
• Allergen and pest control
• Staff hygiene policies
• Supplier and raw material approval processes
• Equipment calibration and maintenance schedules

We recommend: Documenting your prerequisite programs thoroughly, they’ll be critical during audits or inspections.

Implement a documented Hazard Analysis and Critical Control Points (HACCP) plan tailored to your processes.

See our earlier rundown of what a HACCP plan involves

We recommend: Training multiple staff in HACCP to maintain resilience if key personnel are absent.

Your food safety management system should include policies, procedures, logs and training records. Documentation for the following should be structured and accessible:

• Food safety policy and objectives
• Standard Operating Procedures for each process
• Critical Control Point monitoring logs, cleaning schedules and staff training records

We recommend: Using a document control system to track revisions and maintain version control.

A food safety management system is only effective if everyone in your business understands and follows it. Make sure to provide regular training on:

• Food safety principles
• Site-specific hygiene and Critical Control Points procedures
• Allergen awareness and personal responsibility

We recommend: Reinforcing learning with short refresher courses, on-the-job training or digital learning tools.

Setting up regular monitoring for your food safety management system will help ensure it remains effective and relevant. Consider the following:

• Track performance metrics like non-conformities, Critical Control Point deviations, complaints etc.
• Conduct scheduled internal audits
• Review audit outcomes and implement corrective actions in a timely manner

We recommend: Using audit results as the foundation for continuous improvement, not just a box ticking exercise.

Audits for certificates like BRCGS are in place to ensure your food business is complying with the necessary standards relating to food safety and quality. Each year there are common non-conformances that delay certifications or cause reputational risk if they result in a loss of the certificate.

We’ve put together the below table to highlight some of the most common non-conformances or causes of audit failures, as well as practical tips on how to avoid them:

Whether you’re a small batch producer, or a multi-site manufacturer, maintaining food safety compliance can be complex but it doesn’t have to be overwhelming. Yes, the size of your operation will likely shape how you implement food safety practices, but the core principles remain the same.

Read on to learn how businesses of all sizes can improve their food safety compliance efforts…

Small Manufacturers: Focus on developing a lean but effective food safety management system with clear standard operating procedures and a basic HACCP plan that addresses your specific risks. Avoid overcomplicating documentation if it doesn’t add value.

Large manufacturers: Standardise processes across multiple sites while allowing flexibility for site-specific risks. Implement formal governance structures and centralised oversight for consistency and efficiency.

Small Manufacturers: Begin with low-cost or modular digital solutions – such as electronic checklists, electronic document storage or digital temperature logs – to replace paper-based processes gradually.

Large manufacturers: Use integrated systems (e.g. ERP, QMS) to link compliance with production, traceability and supplier management. Consider technologies like vision recognition or IoT sensors for continuous monitoring.

Small Manufacturers: Involve all team members in the compliance process. With smaller teams, it’s easier to create a shared sense of ownership over hygiene, traceability and quality practices.

Large manufacturers: Drive food safety culture from the top down. Use structured training programmes, KPIs, and internal audits to ensure food safety values are reinforced across departments and shifts.

Small Manufacturers: Assign a compliance lead, even if part-time, to monitor updates from the FSA, local authorities and regulatory bodies. Use trade associations or industry bulletins for updates.

Large manufacturers: Set up a compliance and quality team with responsibility for horizon scanning, regulatory mapping and internal training updates to ensure readiness across sites.

Small Manufacturers: Work closely with local suppliers and service providers to ensure mutual understanding of quality expectations. Transparent communication goes a long way in audit scenarios.

Large manufacturers: Establish formal supplier approval and performance tracking processes. Create open channels with certification bodies to align on audit scope and expectations.

Small Manufacturers: Tap into local government resources, food safety consultants and free guidance from the FSA. Bringing in a third party for a gap analysis can also save major time and cost down the line.

Large manufacturers: Use specialist consultants for complex areas like allergen management, new market entry compliance or digital transformation. Third-party audits and benchmarking can identify opportunities for continuous improvement.

Achieving and maintaining regulatory compliance in food manufacturing requires more than good intentions – demands the right tools, systems and guidance. Whether you’re just formalising your HACCP plan or managing multi-site certification audits, the right resources can save time, reduce errors and enhance your confidence going into inspections.

Useful tools and resources that can help strengthen your food safety efforts include:

• FSA MyHACCP
• Third-party consultants or internal FSMS specialists
• Digital systems/platforms for:
  • Recipe formulation and allergen management
  • Electronic quality records (EQMS)
  • Real-time traceability and supplier verification

When done correctly, food safety compliance can become a competitive asset for your brand, not just a box ticking exercise. It helps your business build trust with retailers, protects your brand, and equips your teams with better systems.

Whether you’re working towards BRCGS certification, refining your HACCP plan, or preparing for an upcoming audit, there’s no better time to strengthen your food compliance or food safety management strategies than right now.

Find out how a Stevens Traceability System can support your food safety compliance by contacting us and speaking to one of our experts.