Update on Working Group 6 Food Safety and Net zero carbon (NZC)

Update on Working Group 6 Food Safety and Net zero carbon (NZC)

Last updated: 16 June 2022

Update on Working Group 6 Food Safety and Net zero carbon (NZC) 

Paper by Claire Nicholson, Jonathan Wastling and Paul A. Nunn

For further information contact Paul A. Nunn at


1. This paper outlines progress of the Working Group 6 review on Food Safety and Net Zero Carbon (NZC).

1.1 The Science Council is asked to:

  • Note current progress (delivery of the interim report and targeted expert interviews)
  • Discuss proposals for next steps to gather additional information for the final report.


2. The UK set a legal target in June 2019 to achieve NZC emissions by 2050.  The government recently set a new legally binding target to cut the country's greenhouse gas emissions by 78% by 2035 compared to 1990 levels. 

2.1 This means any carbon emissions are balanced by schemes to offset an equivalent amount of greenhouse gases from the atmosphere, such as planting trees or using technology like carbon capture and storage.  It does not include the carbon footprint of imported products.  These are important qualifiers as it doesn’t mean an end to UK carbon emissions, or the carbon footprint driven by UK’s consumption of imported products.  

2.2 At the 9th Science Council open meeting, the Council agreed in its closed session an initial work plan to deliver a review of the food safety implications of moving to net zero carbon; the Terms of reference were finalised on 27 October 2021.

3. Phase 1 and 2 of the review is now complete, with last year’s expert survey and workshop completed, written up and to be published as part of the interim report. 

3.1 As previously stated, the survey took a wide view asking experts to identify all decarbonisation changes that might affect the food system.  The workshop focused on changes that impact primary production (and primary processing) to provide a manageable scope (although inevitably discussion occasionally veered to other parts of the food system, and this was recorded)

3.2 The interim report was sent to the FSA Executive Management Team (EMT) on 9 June for discussion and feedback.  It will then be published on Science Council website during Net Zero week (2-8 July 2022). 

3.3 A summary of the themes that emerged from the activities discussed and current FSA activity in these areas can be found in Annex 1.

3.4 Some of the themes highlighted by the workshop were thought to need further investigation so four interviews were carried out over March 2022 with industry and academic experts focusing on aquaculture, livestock management, animal feed and farm management.

3.5 Claire Nicholson (WG6 chair), Jonathan Wastling (deputy WG6 chair) and Peter Gregory interviewed these experts and their insights will help inform the final report for this review.

3.6 To help identify possible gaps or areas of cross departmental interest and cooperation in the activities shown in the Annex, a small workshop with representatives of other HMG departments (Defra, GO-Science, BEIS, DFT and HSE) was held on 16 June 2022.   Claire Nicholson will provide a short verbal readout of that workshop at the 11th Science Council open meeting.

3.7 The current planned next steps for Phase 3 will involve establishing the key questions that need to be answered around our understanding of the risks associated with these changes and look to agree a multifaceted evidence review that suits each question.

3.8 However, we would now like to open up discussion amongst members as to whether they agree with this approach and if they can suggest supplementary or alternative methods to deliver the final recommendations from the Science Council.


4. Science Council members are invited to:  

  • Note current progress (delivery of the interim report and targeted expert interviews)
  • Discuss proposals for next steps to gather additional information for the final report.

Annex: Table of main Net Zero Carbon (NZC) themes and issues/activities, FSA action in each theme and next steps


NZC Issues/Activities

Potential Risk(s)/Benefits

Existing information/FSA activity

Regenerative Farming

This is conservation and rehabilitation approach to food and farming systems.  It is not a specific practice itself but uses a variety of sustainable agriculture techniques in combination.


Overall risks:  Zoonoses (ZN), Foodborne disease (FBD)*, chemical contamination (CC), antimicrobial residue (AMR)

  1. Mixed arable/livestock 
  2. Rewilding
  3. Restoration of wetlands / peat lands to store carbon
  4. Actions for soil health (poultry litter/manure, crop rot)
  5. Reduced inputs (fertiliser and pesticides) and changing usage.
  6. Reduced plastics – link to Food Contact materials work?
  7. Anaerobic digestion
  1. Foodborne disease (e.g. E.coli) in arable.(FBD)
  2. Tuberculosis in cattle (increase/decrease?)(ZN), Bird Flu (ZN) & livestock eating wild plants.(CC)
  3. Changes to water runoff.(CC, ZN, FBD)
  4. Use of poultry litter/manure. (FBD, AMR), Biochar (CC), poor crop rotation management leading to mycotoxins (CC), livestock & crop rotations (FBD, CC), more legumes risk of spoilage in storage (CC).
  5. Reduced runoff of nutrients and pesticides.
  6. More prone to spoilage (FBD, CC)
  7. Pathogens risk if it survives process? AMR in feedstock (FBD, AMR)

New Technology Farming

This includes indoor agriculture (IA) and vertical farming -- is a technology-based approach toward food production taking place within an enclosed growing structure such as a greenhouse or plant factory to control growth conditions.


Overall risks:

Zoonoses, Foodborne Diseases, Chemical Contamination

  1. Reuse of water?
  2. How will systems age?
  3. Less human contact with crop
  4. Changes to nutritional profile of crops / plants grown in new systems?
  5. Do new entrants / micro businesses require advice / support to avoid food safety issues?
  1. On crops? (FBD & CC)
  2. Where will there be risks of e.g. biofilms forming. (FBD)
  3. Improved hygiene?  Can automated systems spot disease potential as quickly? (FBD)
  4. How will this change availability of nutrients for consumers?
  5. New kind of agriculture which combines traditional farming and industrial design, how do the balance of risks differ from either one alone? (FBD, CC, AMR)
  • Current FSA Project on consumer attitudes to urban farming.
  • Transforming UK Food Systems is funding work in this area (Future of Foods):  Transforming UK Food Systems SPF: latest round of funded projects Call 2.

Circular Agriculture

This looks to minimise inputs to food production, close nutrient loops and reduce negative discharges to the environment and valorise agri-food waste.


Overall Risks:

Zoonoses, Foodborne Diseases, Chemical Contamination

  1. Recycling food waste: animal feed
  2. Recycling food waste: composting
  1. Who regulates? Can existing systems cope with an amplification of existing risks (botulism, swine fever, foot and mouth)?(FBD)
  2. Who regulates?  What are the new risks? Can existing systems cope with an amplification of existing risks?  (FBD), Are recycled additions to compost (such as chitin as a soil conditioner) regulated under existing rule? (CC)

Changing Livestock feed

For animals feed innovations are primarily aimed at reducing the carbon footprint of soy as a feed, but also there are initiatives aimed at using food waste and introducing supplements to reduce methane.


Overall Risks:

Chemical contamination

  1. Replacement proteins (Soy replacement, food waste recycling, insect protein, etc?)
  2. Supplements in animal feed, e.g. to reduce methane
  1. Who regulates? Is the existing approvals process working?, Safety issues from the past: BSE, Swine fever, Foot & Mouth, Changed nutritional profile of meat from animals with new feeds / supplements?
  • Successor to the Advisory Committee on Animal Feed (ACAF) should be in place soon.
  • FSA will commission a review called : The Future of Animal Feed (commissioned by SIT) covering: Types of alternative proteins in animal feed; Implications for food safety and sustainability; Policy and regulatory implications
  • Led by Fellow at Queens University Belfast (ends in Sept). 
  • FSA also has underway a review of prospective novel food assessments to be ready for new products over the horizon.


Including active farming of fish and shellfish (salmon farms etc), fishing and harvesting of unfed sea/plants/animals that filter feed.


Overall Risks:
Zoonoses, Foodborne Diseases, Radiation(RD), Chemical Contamination, Food Intolerance (FI)

  1. Fish farming moving away from fishmeal and oil as protein and fat source (respectively) for feed (more source of omega-3).
  2. Animal products/by products as a feed ingredient?
  3. Cultivating Seaweed/molluscs/etc
  1. Industry moved to plant protein concentrates, by-products of other processes.  Fish meal is a potential source of salmonella, but this is managed through the feed production process and selection of suppliers.[FBD]  Moving from fish meal and oil to other sources for feed reduces risk of heavy metal and POP contamination (CC).
  2. Outside UK increasingly animal by-products used in feed. (ZN).  Antibiotics may be used on land animals who go into feed, but risk reduced if a suitable withdrawal period is allowed before slaughter.(AMR)
  3. Unfed aquaculture use static locations and feed on nutrients in water. Particularly prone to accumulate pollutants, if they are also in the water.[CC, RD]  So location is very important.
  • Chris McCabe (Marine Habitats Adviser) at Defra has approached all CSAs to get an overview of marine-relevant work across HMG in order to better coordinate activities going forwards.
  • English Aquaculture strategy from Seafish/Defra last year, looks at broader opportunities.  And Scottish aquaculture strategy (2017).

Dietary Changes

Towards More Plant-Based Eating and Alternative Proteins for both perceived health and sustainability reasons.


Overall Risks:

Zoonoses, Foodborne Diseases, Allergies, Nutrition (NUT), AMR

  1. Novel proteins not previously consumed in the UK
  2. Existing vegetable proteins being used more frequently for vegan products e.g. pea proteins
  3. Cultured proteins, e.g, lab grown meat, milk replicas
  4. Possible safety / nutritional implications for ultra-processed meat alternatives
  5. Effect on nutritional profile of UK diet (where foods are grown in new places and new feed)?
  1. Unknown potential for pathogens (FBD) or allergenicity/intolerance (FI).
  2. Unknown potential for allergenicity/ intolerance (FI).
  3. Unknown potential for allergenicity/ intolerance (FI), controlled growth conditions (AMR).
  4. Using ‘halo’ effect of vegan/green products in high fat high sugar (HFHS) foods that are high in fat, carbohydrates and salt.(NUT)
  5. Changes to feed for animals could change their nutritional profile, and changing inputs to crops and where they are grown can influence their nutritional profile (both micro and macronutrients).  This could change the nutrition of the UK diet.(NUT)
  • New proteins or new methods of producing existing proteins should be assessed first by the ACNFP before going on the market.
  • FSA Strategic Insight Team commissioned a review “The Opportunities and Challenges Presented by Alternative Proteins for Human Consumption”.   It will identify key alternative proteins, their market readiness and potential food risks. Ending in March ‘22.
  • FSA conducted a consumer poll on alternative proteins in Dec 2021.
  • The ACSS climate change and consumer behaviour (CCCB) review is a working group considering alt proteins as one of four consumer behaviour changes.
  • FSA commissioned a literature review on sustainability due to deliver by the end of April ‘22. It will look at how sustainability is defined in academic literature for food and how that compares to the consumer and industry understanding and how it affects buying decisions.
  • FSA ‘Nudge’ research on how to encourage sustainable choices.
  • In FSA Food and You 2 tracker, Wave 4 added a new module which explored sustainable dietary and shopping choices (changes and reasons why).
  • Psychologies package of research including 2 literature reviews on High Fat Salt and Sugar as well as Meat and dairy consumptions and primary research on meat/dairy consumption – they also looked at changes in people’s diets, what are the drivers for any changes.
  • FSA Wider Consumer Interests programme conducted qualitative and quantitative research to explore consumers’ concerns and priorities when it comes to food (including sustainable choices).
  • FSA might also be able to look at economic data they have on sales of vegan products.

Labelling implications


Overall Risks:


  1. Novel Proteins in pre-packed foods.
  2. Using product labelling to sell to the consumer as sustainable or green
  1. If novel proteins cause allergies this should be labelled on the packaging. (AL)
  2. If consumers use Green labelling to choose food products it should be accurate to not mislead consumers.
  • Existing Codex Alimentarius labelling standards (incl. allergens)
  • International literature review of allergen labelling (FSA/FSANZ)
  • FSA is working with Defra on eco-labelling to give consistency.  No standard to define sustainable food.  Work in field (see above) to find what consumers expect when they think sustainable food. 
  • Behavioural impact of Labelling evidence review (complete)
  • In Food and You 2 we ask respondents whether they check for information on the environmental impact of food when shopping, and if they show enough information about this.
  • In the Wider Consumer Interests project, we capture the proportion of respondents who would like the FSA to work with partners to provide an ‘eco-label’ on food products to show their environmental impact. We also capture whether consumers pay close attention to the environmental or ethical impact of the products they buy, and whether they find on-pack information about a product’s environmental impact easy to understand.





Changes to packaging

Reduced or changes to packaging and food contact materials are aimed at achieving net zero and also at achieving many sustainability objectives.


Overall risks: Allergies, Food Borne Disease, Chemical contamination

  1. Reduced traditional food packaging materials (e.g. plastic).
  2. Changes to packaging materials and food contact materials (for example in pipes).
  1. Reduced packaging may not fully protect food from cross contamination (microbiological, chemical and of allergens)(FBD, CC, AL).
  2. Alternative food packaging materials may not be as inert or strong so may split and lead to spoilage (FBD, CC), also food contact materials made from allergenic natural sources could trigger food intolerance.(AL)
  • ACSS climate change and consumer working group considering increased use of alt packaging (and food safety risks) as one of four consumer behaviour changes.
  • Wave 4 of Food and You 2 introduced a new module which explored sustainable food behaviours including whether people have started buying foods with minimal/no packaging.
  • In the Wider Consumer Interests project, consumers were asked whether they try to reduce or avoid food products that create plastic waste. Also what concerns they have about the future of food in the UK over the next 3 years, capturing their level of concern around packaging waste or plastic packaging in the food chain.
  • FSA are planning work on alternative packaging in 2022/23 under the FSA’s Emerging Challenges and Opportunities Area of Research Interest (ARI). Objectives for this project could be adapted.
  • FSA Has done a market and safety analysis of alternatives to plastic and a review of bio based food packaging.

Gene Editing / Modification


Overall Risks:


  1. Of plants or animals for feed and food
  1. Same as with any modified food or feed: is it safe to eat, is it susceptible to particular diseases etc. Also animal welfare questions.
  • ACNFP review any novel food or novel method before it can come to market so this will cover food for human consumption.
  • The successor to ACAF will hopefully do the same for animal feed.
  • Defra produced a consultation on the creation of GE organisms.
  • FSA have published research on consumers views on gene editing. However it may do further work in this area, testing communications around GE with consumers.
  • Food and You 2 has had a question added to monitor consumer awareness of GM and GE food so FSA can track this over time. This question was first added in Wave 4 (reporting in Summer 2022).

Food Shortages


Overall Risks:
Nutrition, Allergy

  1. Poor harvests or disruption due to climate  change
  2. New net zero methods turn out not to produce enough food

Both 1&2 could lead to: Increased food prices which may lead to Food Fraud (AL), Food Poverty(N).  It may also be tempting in extreme cases to relax safety standards or quality standards.


  • FSA track data on food shortages and food insecurity in our consumer tracker and Food and You 2 survey also looked at as part of the Covid package of work, including Food in a Pandemic.
  • FSA are undertaking further in-house analysis of food insecurity.
  • The Impact of Labour Shortages on Consumer Food Safety (commissioned by SIT) which aims to identify the downstream impact on the UK consumer specifically considering food safety risks and food availability. Ends in March ‘22.
  • In the Wider Consumer Interests project, FSA measured consumers’ level of concern around food shortages in the UK over the next 3 years. It also asked consumers what they would like the FSA to do in collaboration with partners with regards to price, quality and convenience, and capture the proportion of respondents who would like the FSA to work with partners to ensure access to affordable, locally produced foods. It also captures food insecurity measures.

* Includes:   Campylobacter, Listeria, Salmonella spp, C. botulinum, scrapie and E. coli