IN Brief:
- The FSA’s 2025/26 retail surveillance programme collected 845 products from supermarkets, independent retailers, and online sellers.
- Of 800 samples examined for compliance, 36% of products from smaller retailers were non-compliant with relevant rules or guidance.
- The findings highlight continuing risks around labelling, authenticity, substitution, ingredient limits, and supplier assurance.
The Food Standards Agency has published its 2025/26 retail surveillance survey, exposing significant compliance gaps across targeted food products sold through UK retail and online channels.
The surveillance programme collected 845 food products from national supermarkets, independent retailers, and online sellers between July and December 2025. Of those, 800 samples were examined for compliance with relevant legislation and guidance. The programme is designed to identify emerging food risks, assess compliance with food standards, and support regulatory and policy work across England, Wales, and Northern Ireland.
The most striking finding was the non-compliance rate among samples from smaller retailers. The FSA found that 36% of products tested from smaller retailers were non-compliant. Areas of concern included labelling, authenticity, Dubai-style chocolate products, glycerol levels in slush drinks, and goat meat substitution.
Although the sampling point was retail, the issues sit across the manufacturing and supply chain. Incorrect labels, undeclared ingredients, substitution, out-of-specification composition, and misleading product descriptions can begin with raw material controls, supplier documentation, recipe management, packaging artwork, finished-product testing, or distribution decisions. Retail detection is often the point at which the problem becomes visible, not necessarily where it starts.
Authenticity remains a persistent manufacturing risk because food supply chains are long, price-sensitive, and dependent on trust in specifications. Meat substitution, incorrect species declarations, adulterated ingredients, and exaggerated product claims can distort competition and create safety concerns. When ingredients are expensive or supply is tight, the incentive for substitution increases, and technical teams need stronger verification processes to protect both safety and commercial integrity.
Glycerol levels in slush drinks show a different type of risk. Ingredient use can be lawful and functional while still requiring careful control around vulnerable consumers, dosage, labelling, and category guidance. Products such as frozen drinks, supplements, confectionery, and functional snacks often sit close to the boundary between formulation innovation and safety scrutiny. Manufacturing controls must therefore cover microbiological hazards, allergen controls, compositional limits, and intended-use assumptions.
The Dubai-style chocolate category underlines the speed at which viral demand can create compliance pressure. Rapidly scaled products, imported variants, small-batch copies, and online listings can move faster than quality systems. Manufacturers and importers entering high-demand trend categories still need validated ingredient declarations, allergen controls, claims review, and traceability.
Recall activity and traceability have already become defining manufacturing pressures this year, with Q2 analysis showing how quickly incidents can expose weaknesses in batch records, supplier mapping, product specifications, and artwork control. The same discipline applies to surveillance findings. Compliance depends on the ability to demonstrate how a finished product matches its declared composition before a regulator or retailer takes a sample.
Pack integrity also remains part of the safety system. The Icesupp recall showed how a packaging defect can become a food safety issue when pack performance affects contamination risk. The FSA surveillance results widen the lens: food safety is not only about pathogens. It includes the accuracy of what is placed on the market and the evidence supporting it.
The commercial impact of non-compliance can be substantial. Product withdrawals, retailer technical reviews, enforcement action, reformulation, relabelling, testing, and customer complaints all carry cost. Smaller suppliers and importers can be particularly exposed because they may lack the technical resources of larger manufacturers while still serving complex and fast-moving channels.
The FSA’s targeted approach suggests that regulators are continuing to use surveillance to find risk rather than simply measure average compliance. Categories with known vulnerability, rapid growth, confusing labelling, or complex sourcing are likely to remain under scrutiny.
Ingredient identity, label accuracy, product composition, and supplier assurance need to be managed as active controls. A product that passes through the factory, warehouse, and retail shelf without challenge is not necessarily compliant. The evidence has to be present before the sample is taken.
