The UK has published its first food safety guidance for cell-cultivated food products (“CCPs”). So far, the UK authorities have addressed two issues:
- First, the guidance confirms that the authorities will treat CCPs produced using animal cells as products of animal origin. Producers of CCPs from animal cells must therefore follow the existing hygiene and safety rules for products of animal origin.
- Second, the guidance explains how the authorities will assess allergenicity and nutritional quality for all CCPs — whether based on animal or plant cells — during the mandatory CCP approval process.
The UK authorities (the Food Standards Agency (“FSA”) and Food Standards Scotland (“FSS”)) plan to release further guidance on other key areas — which may include labelling and regulatory approval — in 2026.
What is a cell-cultivated product?
FSA guidance explains that CCPS are foods “made by taking cells from plants or animals, which are then grown into food.” The FSA states that CCPs could include, for example, “a chicken fillet made from chicken cells;” a beef burger made from cells from a cow;” or “muscle cells from an animal such as a chicken, mixed with plant-based ingredients to create a fillet.”
FSA guidance explains further how CCPs are produced. First, the producer takes a sample of stem cells from a live animal. Second, the producer places those cells in a “bioreactor” — a large tank containing the nutrients that the cell needs to multiply. Third, the producer manipulates the bioreactor so that the stem cells differentiate into muscle, fat and connective tissue. Finally, the producer harvests the cultivated cells to produce CCPs.
How are cell-cultivated products regulated?
The FSA notes that, given “the methods that are used to create cell-cultivated products,” most will be regulated as novel foods. This means that before a producer can place a CCP on the market, it must submit an application to the FSA for a novel food authorization under the UK Novel Food Regulations. The application must include detailed evidence demonstrating that the CCP does not pose a safety risk to human health.
The UK government launched a regulatory sandbox in February 2025 to fast-track the development and safety assessment of CCPs. The sandbox allows the FSA to collaborate with eight CCP companies with the aim of completing a full safety assessment of CCPs within two years. The FSA is also sharing expertise with regulators in other countries where CCPs are available, including Singapore and Australia.
CCPs are products of animal origin
The guidance confirms that CCPs derived from animal cells will be regulated by the FSA as products of animal origin (“POAO”) under UK food law, and particularly the UK Food Hygiene Regulations 852/2004 and Meat Hygiene Regulations 853/2004. This position is aligned with the European Commission’s working position on animal cell CCPs.
In contrast, the FSA states that CCPs derived from animal cells do not satisfy the legal definition of “meat” because CCPs are not an “edible part” of any animal listed in Annex 1 to the Meat Hygiene Regulations 853/2004. The FSA also notes that many requirements related to the production of meat (e.g., slaughter hygiene, animal welfare) cannot be applied to CCPs as those requirements concern practices that involve the presence of animals. The FSA notes that it will give further consideration to hygiene requirements in future guidance to be produced through the regulatory sandbox programme.
The guidance also sets out in detail how producers of CCPs can create and adhere to a Hazard Analysis and Critical Control Point (“HACCP”) plan, to ensure that CCPs meet food safety and hygiene requirements.
What does the guidance say about allergenicity and nutrition?
The guidance supports producers in developing scientific evidence for an application for a CCP novel food authorization.
Applicants must demonstrate that their CCP novel food is not nutritionally disadvantageous compared to any food it may replace. Applicants can include evidence of composition, bioavailability of nutrients and assessment of anticipated intake under the proposed conditions of use.
Applicants must also assess the allergenic potential of their CCP novel food, in light of both the composition of the food and the production method. Producers can manufacture CCPs using known allergens; however, producers must assess safety to ensure that the CCPs do not pose an increased risk to consumers. The application should consider genetic changes throughout the production process on the cell lines and show that genetic drift has been considered regarding allergenicity.
What’s next for CCPs?
The FSA/FSS plan to release further guidance on other key areas in 2026. The authorities have not confirmed the topics for that further guidance. However, the authorities have published summaries of workshops carried out in 2025 as part of the regulatory sandbox, and those summaries — which cover hygiene, production, labelling, toxicology and regulatory approvals — may indicate a direction of travel.