Food Science and TechnologyVolume 35, Issue 2 p. 18-20 Brexit Views Free Access Post Brexit trade with the US First published: 15 June 2021 https://doi.org/10.1002/fsat.3502_4.x AboutSectionsPDF ToolsExport citationAdd to favoritesTrack citation ShareShare Give accessShare full text accessShare full-text accessPlease review our Terms and Conditions of Use and check box below to share full-text version of article.I have read and accept the Wiley Online Library Terms and Conditions of UseShareable LinkUse the link below to share a full-text version of this article with your friends and colleagues. Learn more.Copy URL Share a linkShare onEmailFacebookTwitterLinked InRedditWechat Grace McNally, Kelsey Kanyuck and Lindsey Bagley, IFT British section committee members, discuss the potential impact of safety regulations and misinformation on a post Brexit trade deal between the UK and the US. The article was inspired by a panel discussion on US-UK food trade issues hosted by the IFT (Institute of Food Technologists) British section in February 2021. In the wake of Brexit, the UK has an opportunity to reach trade deals with other countries, such as the US. The EU has established a common community for free flow of goods based on the same legislation, regulations and industry practices. Trade with countries outside this community will need to take account of these issues so that mutual compliance is achieved. Food safety is paramount and will be the most important factor to consider when negotiating any potential trade deal between the UK and the US. Whilst the approach to food safety between the two countries is different, ultimately the end goal is the same – safe food for consumers. Another hurdle to any potential trade deal will be the differences in food legislation and regulation relating to food production standards. This article explores some of the differences in approach and regulations between the US and the UK. Food safety Unfortunately, the key message of ‘safe food’ has been lost amongst media headlines that raise consumer concerns. News media have brought particular attention to chlorine washed chicken, hormone treated meat, artificial colours, flavourings and additives to name but a few. Misinformation and lack of general understanding of these issues has raised concerns and fear amongst consumers, anger amongst farmers and growers and has posed challenges for decision makers and governing bodies. The safety of food practices allowed in the UK has become a topic of debate. Will any move away from EU regulations governed by EFSA (European Food Safety Authority) have a negative impact on standards and practices in the UK, such as animal welfare, environmental protection and food safety? This is a question that can only be addressed on a case-by-case basis. Regulations In general, the EU takes a prerequisite approach to practices, standards and regulations (Table 1). They are put in place at an early stage to avoid problems rather than at a later stage when they arise. US regulations have their roots in English Common Law, which loosely permits behaviour unless explicitly forbidden. The UK began to diverge from this principle when it signed the treaty of Rome and joined EEC in 1958. European law is based on Napoleonic law, which prohibits behaviour unless explicitly permitted and is generally coupled with the precautionary principle. These approaches are key to the differences in regulation between the two regions. Table 1. Key differences in approach to food safety and regulation between the UK and the US Approach to Food Safety United Kingdom United States Process Product Prerequisite Retrospective Hazard Risk Chlorine washing One of the most highly discussed topics of UK/US trade concerns the acceptance of chlorine rinsed chicken by the UK consumer. The science behind this practice, which is used in the US but is currently banned in poultry production in the UK, is often not well understood. What is chlorine washing? Chlorine washing is a process of removing bacteria from the surface of foods, such as chicken and salad products. By passing products through chlorinated water, harmful bacteria such as Campylobacter and Salmonella are killed thereby reducing the risk of foodborne illness. Chlorine is used at low levels (less than 30ppm) and fresh-water rinsing is used post chlorine washing to remove any residual chlorine. Chlorine washing of salads is permitted and widely used in both the US and the UK1. Is chlorine-washed chicken safe? No risk assessment by any regulatory body has shown concern for the safety of chlorine-washed chicken. In fact, EFSA, which banned its use in the EU, said exposure to chlorine residues is of ‘no safety concern’. US position In the US, the practice of chlorine washing has been used as a retrospective approach to chicken processing. Rinsing at the end of the process removes the risk of Campylobacter and focuses on a safe end product rather than potentially removing the hazard early on in the process. In practice, the US National Chicken Council reports that less than 10% of chicken processing plants in the US actually use this process. UK position In the UK, chlorine rinsing has been banned as a practice in chicken production since 1997. The EU regulation takes the approach that relying on chlorine rinsing at the end of the process could risk poorer hygiene standards earlier on in chicken handling. Animal husbandry practices were established to negate the need for this process. Current processing permitted in the UK includes cold air and water to decontaminate poultry carcases. According to the RSPCA2, the ‘farm to fork’ principle ensures high standards of hygiene across all stages of production rather than a disinfection step using chlorine at the end. Animal Welfare The UK has a process and precautionary based approach to producing safe poultry (Table 2). Animal welfare and hygiene standards throughout the process ensure that the use of chlorine rinsing is not needed. Maintaining high animal welfare standards is very much top of mind for the UK consumer. Table 2. Differences in approach to animal welfare between the UK and the US United Kingdom United States Legislation EU: Council Directive 98/58/EC3 lays down general rules concerning protection of farmed animals No federal legislation to control animal welfare. USDA: Animal Welfare Act of 1996 excludes farm animals UK: National legislation addresses welfare of farmed animals e.g. The Welfare of Farmed Animals (England) Regulations 20004 Voluntary practices Red tractor certified standards, Leaf and Soil Association Organic are adopted and nationally recognised by consumers. Animal Welfare Guidelines from National Chicken Council mostly universally adopted by producers voluntarily Labelling Under current EU rules, chlorine-rinsing is considered a processing aid and therefore is not declared on pack. Similarly in the US, chicken rinsed with chlorine is not labelled. It is unclear if US chlorine-washed chicken imported into the UK would be identifiable. Food additives Food additives have also been brought into the debate about a potential trade deal. Although there are differences between UK and US regulatory systems, in both countries only approved additives can be used in foods and the approval process is based on scientific testing. The ancient chemist Paracelsus first explained that ‘the dose makes the poison’. Just because a chemical is present, does not mean that it is harmful at the amount present. Even for common chemicals, such as water or salt, too much could kill you. The regulation of additives follows a similar principle, where compounds can only be used below specified levels. Many functional ingredients including colours, flavours and high potency sweeteners are regulated by three criteria: specific chemical identity, the product in, and level at which they may be used. However, in addition to safety, environment, sustainability and transparency are top priorities for UK consumers in evaluating food additives. For US consumers, price is much more of a concern. Regulation of flavours Before joining the EU, the UK had a negative list of flavouring substances banning those that were found to have adverse health effects. The EU approach uses a positive list (the Union list). Everything, including compounds found in nature, has to be approved before being used in flavourings. The US approach is a ‘relaxed’ positive list. The US Flavor and Extract Manufacturers Association (FEMA) has a list of compounds generally recognised as safe (GRAS). A big difference between the EU Union List and the FEMA GRAS list is that the Union List is owned and controlled by the legislature. The FEMA GRAS List is owned by the US flavour Industry. The FDA has handed over the control, management and policing of the list of flavouring substances to the industry experts, with audits by FDA to ensure they comply with safety and Federal Law. The definitions of what constitutes ‘natural’ flavourings is widely different with the EU being narrow and highly proscriptive and the US being flexible and open to interpretation. The rest of the world tends to follow the US approach and IOFI (International Organisation of the Flavour Industry) is aiming to produce a global understanding and common regulations on flavourings. The UK will have a choice to make. Regulation of colours The US allows the use of seven artificial colours in foods under the FD&C (Federal Food, Drug and Cosmetic) Act. Three of these require special labelling in the UK following a study by the University of Southampton suggesting a link with hyperactivity in children. Referred to as the ‘Southampton Six’, they are: 1 Tartrazine (FD&C Yellow No. 5), 2 Allura Red (FD&C Red No. 40), 3 Ponceau 4R (not permitted in the US), 4 Sunset Yellow (FD&C Yellow No. 6), 5 Carmoisine (not permitted in the US) and 6 Quinoline Yellow (not permitted in the US). Subsequent to this study, the European Parliament adopted new labelling regulations for foods containing any of these food colours, which must now be labelled not only by name or number, but also with the words ‘may have an adverse effect on activity and attention in children’. Three of these six are not permitted in the US. Recently, ingredient suppliers have made natural colours and colouring foods widely available. These have a more significant cost in use but are in line with consumer aspirations. They originate from a wide range of sources like vegetables, fruits, plants, minerals and other edible natural sources. Products formulated with natural colours are sought by both US and UK consumers. Regulation of high potency sweeteners High potency sweeteners (HPS) are calorie free sweeteners. In the EU, these are again restricted by category, type and level. Also the use of HPS in any food must fulfil the requirement of having either ‘reduced energy’ and/or ‘no added sugar’. The US has not specified maximum levels for several of the sweeteners (termed General Purpose Sweetener, GPS) because the safe level is considered well above the amount that would be needed. The complexity of the differences between the regulations in the two regions is illustrated in the Table 3 with reference to soft drinks in EU. Table 3. Regulations governing high potency sweeteners in the US and EU Sweetener USA UK (EU) Permitted sweetener? Max. concentration in soft drinks[1] (mg/l) Acesulfame-K GPS[2], FE[3] Yes 350 Advantame GPS, FE Yes 6 Aspartame GPS Yes 600 Aspartame-acesulfame salt GPS[4] Wherever aspartame & acesulfame-K are allowed together 350 Cyclamate & Na, Ca salts Not permitted Yes 250 expressed as acid form Lo Han Guo aka Monk fruit GRAS[5] notifications Not permitted – Neohesperidin dihydrochalcone GRAS notification FEMA[6] GRAS Yes 30 Neotame GPS, FE Yes 20 Saccharin & Na, K, Ca salts (& NH3 in USA Permitted only for specific applications[7] Yes 80 expressed as acid form Steviol glycosides Many GRAS notifications Specified glycosides only[8] 80 expressed as steviol equivalent[9] Sucralose GPS Yes 300 Thaumatin GRAS notifications FEMA GRAS Very limited applications Permitted as FE at 0.5 mg/l Notes: 1) Soft drinks are the main application of HPS, hence this category is shown to illustrate the UK's range of use levels. 2) GPS = General Purpose Sweetener (can be used in all foods and beverages except meat and poultry products to a maximum concentration determined by good manufacturing practice). 3) FE = Flavour Enhancer 4) FDA regards the salt as covered by the regulations on the component sweeteners. 5) GRAS = Generally Recognised As Safe 6) FEMA = Flavor Extract Manufacturers Association 7) Saccharin is not a GPS. Permitted in beverages, juice drinks, sugar substitutes and processed foods, subject to various maximum concentrations. The maximum allowed in soft drinks is 12mg/fluid ounce, equal to 406mg/l, expressed as acid form of saccharin. 8) Dulcoside A, Rebaudiosides A,B,C,D,E,F,M, Rubusoside, Steviolbioside, Stevioside 9) Actual concentration for each glycoside depends on its molecular mass. For example, for rebaudioside A, 80mg steviol equivalent is provided by 242mg of reb A. Conclusions These examples have highlighted significant differences in food regulations between the US and the UK (EU). Differences reflect each country's general approach to food safety and its regulation. Fundamentally both systems are similar and designed to ensure that all foods are safe. In fact, regulations are really the bare minimum, and many companies go beyond what is required by law (e.g. organic and Red Tractor). Differences in these practices and regulations will require review to ensure that trade overcomes the barriers. Although any trade will require some changes in formulation and labelling, the safety of the food is not in question. The Conference Board of Canada in its 2014 review of food safety performance in 17 countries, ranked the UK 4th and the US 6th5. There is no indication that one of these regulatory systems is safer than the other and, in fact, the world's food supply is safer than it has ever been! Highlighting the minor differences in national approaches to food safety could diminish general confidence in imported foods, when in reality the regulatory systems in both countries are very safe and are achieving the same goal. Grace McNally, Kelsey Kanyuck and Lindsey Bagley are members of the IFT British section committee This article was inspired by the panel discussion ‘USA-UK trade deal issues: differences in food production practices’ hosted by the IFT British section on February 21st, 2021. The panellists Helen Munday, Jack Bobo, and Kantha Shelke are acknowledged for contributing key themes to this article. A full recording of the event can be found on their YouTube channel (IFT British Section) at: youtu.be/lBty8bOVWyo With additional thanks to Professor David Baines, Mr Richard Bowles and Dr John Fry for their inputs. References 1https://cot.food.gov.uk/sites/default/files/cot/cotstatementwashaids200614.pdf Google Scholar 2https://www.rspcaassured.org.uk/news-and-updates/posts/what-is-chlorinated-chicken/ Google Scholar 3https://op.europa.eu/en/publication-detail/-/publication/5b04f403-0abf-4356-aa53-6dc867b07bcb/language-en Google Scholar 4 The Welfare of Farmed Animals (England) Regulations 2000 (https://www.legislation.gov.uk/uksi/2000/1870/contents/made) Google Scholar 5https://www.researchgate.net/publication/269630719_2014_World_Ranking_Food_Safety_Performance Google Scholar Volume35, Issue2June 2021Pages 18-20 ReferencesRelatedInformation
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