Food Compliance: US vs. EU vs. UK at a Glance¶
Selling food in one market is a regulatory challenge. Selling the same food product in the United States, the European Union, and the United Kingdom — as many e-commerce brands do when they scale from domestic to international — means complying with three regulatory frameworks that share similar goals but differ significantly in their implementation. Your FDA-compliant food label is not valid in the EU. Your EU food contact packaging declaration is not accepted by the FDA. And since Brexit, the UK is a separate regulatory jurisdiction with its own rules.
This guide compares the food safety, labeling, and packaging requirements across all three markets and shows how to manage multi-market food compliance without maintaining three separate compliance programs.
Not sure which food regulations apply in which market? Use the Sustalium Global Compliance Map — select Food and toggle between the US, EU, and UK to see the regulatory differences side by side.
The Three Food Safety Regulators¶
| Aspect | United States | European Union | United Kingdom |
|---|---|---|---|
| Primary regulator | FDA (plus USDA for meat/poultry/eggs) | EFSA + Member State competent authorities | UK FSA (Food Standards Agency) |
| Governing legislation | FFDCA, FSMA (21 CFR Part 117) | Regulation (EC) 178/2002 (General Food Law) | Retained EU law + UK Food Safety Act 1990 |
| Facility registration | FDA registration, renewed every 2 years | Registration with Member State competent authority | Registration with local authority + FSA |
| Food safety plan | FSMA Preventive Controls (HACCP-based) | HACCP principles (Regulation (EC) 852/2004) | HACCP principles (retained from EU) |
| Third-party audits | Not federally mandated (retailers require SQF/BRC) | Not federally mandated (retailers require BRC/IFS) | Not mandated (retailers require BRC/IFS) |
The structural architecture is similar — all three systems are built on HACCP principles, all three require facility registration, and all three require documented food safety plans. The operational difference is in the specific documentation formats, the enforcement bodies, and the post-market surveillance mechanisms.
Food Contact Packaging: Three Markets, Three Compliance Documents¶
The area where multi-market food compliance creates the most administrative overhead is food contact packaging. A food product sold in all three markets needs three separate Declarations of Compliance for its packaging — and each one cites different regulations:
| Requirement | US | EU | UK |
|---|---|---|---|
| Declaration of Compliance | 21 CFR citation or FCN number | Regulation (EC) 1935/2004 + material-specific measures | Retained EU 1935/2004 + UK SI equivalents |
| Plastics regulation | 21 CFR Part 177 | Regulation (EU) 10/2011 | Retained EU 10/2011 + UK amendments |
| New substance clearance | FCN (proprietary) or GRAS | EFSA authorization → positive list | UK FSA authorization (separate from EFSA) |
| Migration testing | FDA guidance | EU 10/2011 simulants + SMLs | UK equivalent of EU 10/2011 |
| GMP | 21 CFR Part 110 (indirect) | Regulation (EC) 2023/2006 | Retained EU 2023/2006 |
| Packaging heavy metals | CA TPPA (19 states, 100 ppm) | EU PPWR (100 ppm sum) | UK Packaging Regulations (100 ppm sum) |
A food brand using the same packaging in all three markets must obtain three separate Declarations of Compliance from its packaging supplier — or, more commonly, must commission migration testing against all three sets of conditions and issue the DoCs itself. The underlying test data is largely the same. The regulatory citations and compliance statements are what differ.
Food Labeling: One Product, Three Labels¶
Food labeling is the most visible example of regulatory divergence. The requirements are sufficiently different that a single label rarely satisfies all three markets:
| Label Element | US | EU | UK |
|---|---|---|---|
| Product name | Statement of identity | Legal name or customary name | Legal name or customary name |
| Net quantity | US customary + metric | Metric only | Metric (may also use imperial) |
| Ingredient list | Descending order by weight, common names | Descending order by weight, with QUID for characterizing ingredients, allergen emphasis (bold) | Descending order by weight, allergen emphasis (bold), retained EU QUID rules |
| Nutrition declaration | Nutrition Facts panel (FDA format) | Per 100g/ml + per portion (voluntary), specified format | Per 100g/ml + per portion (voluntary), similar format to EU |
| Allergens | FALCPA (8 major + sesame) — "Contains:" statement | EU Regulation 1169/2011 (14 allergens) — bold in ingredient list | UK FIC (14 allergens) — bold in ingredient list |
| Manufacturer info | Name and address of manufacturer, packer, or distributor | Name and address of EU-based food business operator | Name and address of UK-based food business operator |
| Date marking | "Best if used by" or "Use by" | "Best before" or "Use by" | "Best before" or "Use by" |
| Country of origin | Not always required (required for certain products) | Required if omission would mislead | Required if omission would mislead (retained EU rules) |
| Health/nutrition claims | FDA-regulated, authorized claims | EU Regulation 1924/2006 (authorized claims register) | UK Great Britain nutrition and health claims register |
| Organic claim | USDA Organic certification | EU organic logo + certification body code | UK organic certification (separate from EU) |
The allergen labeling difference alone makes a single-label approach impractical. The US requires a "Contains:" statement listing the major allergens separately. The EU and UK require allergens to be emphasized (bold, italic, or colored) within the ingredient list and recognize a longer list of 14 allergens including celery, mustard, lupin, and mollusks — none of which are US major allergens. A product that is compliant in one market can be misbranded in another based solely on the allergen declaration format.
Practical Multi-Market Compliance Strategy¶
For a food brand selling in all three markets, the most efficient approach is:
1. Build on HACCP¶
All three markets are built on HACCP principles. A well-documented HACCP plan — hazard analysis, critical control points, critical limits, monitoring, corrective actions, verification, and record-keeping — satisfies the food safety plan requirements in all three jurisdictions. The HACCP documentation is the foundation; the market-specific regulatory filings layer on top.
2. Commission Migration Testing for All Three Markets Simultaneously¶
When you send your packaging to a testing laboratory, specify FDA, EU 10/2011, and UK conditions in the test protocol. The same laboratory can perform separate migration tests during the same session using the same specimens. The cost is higher than single-market testing but significantly lower than three separate testing programs — and the data supports all three Declarations of Compliance.
3. Design Labels for the Strictest Market, Then Adapt¶
Design your label to the EU standard first — it is generally the most prescriptive — then adapt for US and UK differences. The EU label requires the most detailed nutrition declaration, the largest allergen list, and the most specific format requirements. A label built to the EU standard can be adapted to US and UK requirements by adjusting the nutrition panel format, modifying the allergen declaration, and changing the regulatory contact information. Starting from the EU label as a baseline saves redesign cycles compared to starting from the US label and backfilling EU requirements.
4. Appoint Market Representatives¶
Each market requires a local responsible entity:
- US: The manufacturer, packer, or distributor whose name appears on the label is the Responsible Person. For imported products, this is typically the US importer.
- EU: An EU-based Responsible Person or importer must be identified on the label and in the relevant Member State registrations.
- UK: A UK-based food business operator must be identified on the label. For imported products, this is typically the UK importer.
These are three separate entities (or three roles served by different offices of the same organization). The address on your label changes depending on which market the product is sold in — even if the product itself is identical.
How Sustalium Simplifies Multi-Market Food Compliance¶
Running three separate regulatory programs for the same product — FDA for the US, EFSA and Member State competent authorities for the EU, FSA for the UK — triples the compliance overhead without improving food safety. The data is largely the same; the documentation formats and regulatory filings are what differ.
Sustalium's multi-market food compliance platform addresses this directly:
- Unified packaging compliance — Manage FDA, EU, and UK food contact Declarations of Compliance from the same material data and migration test reports, with correct regulatory citations for each jurisdiction
- Multi-market label management — Structure your ingredient, nutrition, and allergen data once and generate market-specific labels for the US, EU, and UK
- Representative and registration tracking — Link your US importer, EU Responsible Person, and UK food business operator to your compliance profiles and track registration renewals across jurisdictions
- Audit-ready documentation across markets — When an FDA investigator, an EU competent authority, or a UK FSA officer requests food safety documentation, produce it in the format that regulator expects
One Product, Three Markets, One Compliance Platform
Selling food across the US, EU, and UK should not mean running three separate compliance departments. Manage your multi-market food compliance from a single platform.
With Sustalium, build your multi-market food compliance dossier for just €10 per document.
Frequently Asked Questions¶
Can I sell the same food product in the US, EU, and UK with one label?
No. The allergen declaration format alone is incompatible between markets. The US requires a "Contains:" statement. The EU and UK require allergens emphasized in the ingredient list and recognize a different allergen list (14 vs. 9). A single label that satisfies all three is not practically achievable without legible-overload compromises that satisfy none of them well.
Do I need three separate HACCP plans?
No. The HACCP principles are universal. One well-documented HACCP plan satisfies the food safety plan requirement in all three jurisdictions. The regulatory filings that reference the HACCP plan — the FDA facility registration, the EU Member State registration, the UK FSA registration — are separate, but the underlying HACCP documentation is the same.
What happens if I only register in one market and ship to all three?
CBP in the US, Member State customs authorities in the EU, and UK Border Force all check food imports for proper regulatory registration. Shipments to an unregistered market can be detained, refused entry, and destroyed at the importer's expense. There is no mutual recognition of food facility registration between the US, EU, and UK.
Is the UK's post-Brexit food regulation identical to the EU's?
Substantially similar but diverging. The UK retained all applicable EU food law at the point of Brexit, and the FSA has continued to operate on the retained framework. However, the UK is no longer part of the EU's RASFF (Rapid Alert System for Food and Feed), has its own UK nutrition and health claims register, and the FSA — not EFSA — is the relevant scientific authority for food safety assessments. The UK and EU frameworks are currently aligned but are separate legal systems that can and will diverge over time.
Last updated: July 23, 2026