On Tuesday 22nd March BFFF attended an FSA led Food Industry Liaison Group meeting which was called at short notice to discuss the Ukraine crisis and food supply chain disruptions particularly the supply of sunflower oil and a derogation to use refined rapeseed oil as a substitute.
Following this meeting the FSA issued a letter to enforcement authorities in England, Wales and Northern Ireland which acknowledges the current supply chain disruption and in these exceptional circumstances encourages enforcement officials to adopt an approach to enforcement that is reasonable, proportionate, risk based and considered on a case-by-case basis.
The FSA have also communicated its views on the food safety risk of substituting sunflower oil with refined rapeseed oil, particularly to people with a food allergy, which they consider to be very low (Rapid risk assessment on the risk of allergic reactions in UK consumers if sunflower oil is substituted with refined rapeseed oil | Food Standards Agency).
We were reminded that a fundamental principle of this pragmatic and proportionate enforcement approach is that consumer safety must be protected, and retaining consumer trust remains an absolute priority for government.
Defra and FSA are encouraging businesses to work closely with their enforcement authorities and, where appropriate, Primary Authorities on these issues.
They are aware that businesses could encounter supply chain difficulties such that they may need to explore replacing sunflower oil with vegetable oil other than refined rapeseed oil. In such circumstances enforcement authorities have been requested to contact the FSA to seek further advice as safety risks will need to be considered on a case-by-case basis.
A similar approach is being taken in Scotland and Food Standards Scotland (FSS) is working closely with the FSA.
The FSA and FSS have issued a joint News Release today. However, this is to help inform consumers about these issues and no formal industry guidance has been issued as yet.