While many commentators have raised concerns about the availability of fertiliser and CO2 (used in abattoirs and in food packaging), the reality is that these items are not currently in short supply in the UK. And even in the event of prolonged disruption in the Middle East, the effect on supply is more about cost than availability. These products can be obtained from sources which do not use the Strait of Hormuz for shipping, though prices may, of course, be higher.
It is important that the mainstream media and those using alternative media, such as influencers, do not create the fear of food shortages in the UK. Fear can lead to panic buying and hoarding, which, in turn, can become a self-fulfilling prophecy that benefits no one.
Absorbing shock: We’ve done it before
The truth is, the UK has a highly resourceful and adaptable food sector. We know from recent – and very real – experience that food businesses are resilient in the face of external shocks and pressures and pivot quickly to keep food in our shops and on our plates.
During the pandemic, food businesses faced many challenges, including staff shortages, customer shortages, ingredient shortages, and packaging shortages, to name a few. The country, by and large, remained adequately fed. Indeed, certain areas of the food sector, those able to quickly adapt to home delivery and take-away services (helped by platform technologies), did more than just survive; they positively thrived. Early adoption of new routes to market set many successful food businesses apart during the pandemic. Some businesses remodelled their entire supply chain.
For instance, one food business, which previously had a supplier deliver flour to all three of their franchises individually, changed to a bulk order due to supply issues with the flour. The problem was where to store the flour, as none of the individual franchises had the space. Adapting to this, the business had the bulk of its flour orders delivered to a central depot and then shipped them in batches to its franchises from there. These kinds of changes helped not only to meet the immediate challenge of the pandemic but also improve efficiency and reduce future costs.
Similarly, during the early stages of the war in Ukraine, supplies of sunflower oil were seriously disrupted. Still, UK manufacturers quickly adapted their recipes and reformulated to use other vegetable and cooking oils.
Recent history shows us that we shouldn’t be unduly fearful when external shocks reach beyond distant shores and impact us here in the UK. Our food businesses are amazingly adaptable, and we can and should be rightly proud of how they respond when the chips are down.
How the Government can support the sector
What is, however, very important is the way in which government and regulatory bodies respond to geopolitical challenges and that they do their bit to help the food sector through tough times. While it is very difficult (sometimes impossible) to temporarily ‘dial down’ food safety requirements, the same is not true of, for example, food labelling.
Food labels and packaging are often printed long in advance, and a last-minute substitution of an ingredient in a recipe should not, provided customers are adequately informed in other ways, result in censure for a food business. Prominent point of sale signs (physical or online) which simply and clearly inform consumers of the substituted ingredient should be welcomed in circumstances of unavoidable and serious disruption. Certain substitutions (allergenic ingredients being a case in point) are different and should be excluded from these kinds of easements, but the point is, I think, clear.
Equally, keeping fuel costs as low as possible is critical, given that most food in the UK is transported around the country by lorry. These are things which the government can and should help with when needed.
We should also remember that the food sector works hard with its charity partners to redistribute surplus food to food banks and similar organisations, and that doing so involves as much transport and logistical effort as the primary distribution of food. Costs matter.
Key takeaway
From a regulatory and legal perspective, one lesson for all in the food manufacturing sector is to be willing to think creatively about compliance and to not be hesitant in seeking advice and guidance on alternative compliance strategies when external shocks affect day-to-day operations.
So, as we stare into the face of yet another year of potential disruption and challenges, let’s remember, celebrate, and support those working hard in the food sector to keep us fed and keep a range of nutritious, reasonably priced foods on the shelves.
About the author
Chris McGarvey is the director of regulatory & compliance at law firm Walker Morris.



