The FSA and Food Standards Scotland have closed their call for data on acrylamide in food, and the analysis now underway could reshape how the UK regulates this process contaminant. If you fry, roast, bake or toast starchy foods, acrylamide mitigation is already a legal obligation under retained Regulation (EU) 2017/2158. But the benchmark levels in that regulation are performance indicators, not legal maximum levels. The signal from the FSA is clear: it wants to know whether those benchmarks reflect reality and whether industry mitigation is actually working. For a Technical Manager, that means your acrylamide mitigation measures and the way you handle acrylamide in your hazard analysis are about to come under sharper scrutiny in 2026.
What's Changing
The FSA and FSS ran a formal call for data on acrylamide occurrence, with a submission deadline of 30 November 2025. The regulator is now working through the results. The stated purpose is to compare occurrence levels against the current benchmark levels, look at trends over time, and assess the impact of mitigation measures used across the sector.
The wording of the call matters. The FSA says it needs data that "reflects the true reality of acrylamide levels in order that any regulatory measures reflect the true situation on the ground and are proportional and achievable." That is regulator language for building an evidence base before changing the rules. The direction of travel, both in the UK and internationally, is a possible shift from benchmark levels toward binding maximum levels for some food categories. If that happens, a number you currently treat as a target becomes a number you must not exceed.
Acrylamide is not added to food. It forms naturally through the Maillard reaction when the amino acid asparagine and reducing sugars are heated together above 120°C. Laboratory studies show it causes cancer in animals, and the scientific consensus is that it has the potential to cause cancer in humans, which is why the FSA position is to reduce dietary exposure as a precaution. Source: Food Standards Agency, Call for data: Acrylamide in food.
Why This Matters to Your Hazard Analysis
Acrylamide is a chemical hazard, and it belongs in your hazard analysis for every product group where it can form. Codex Principle 1 requires you to identify and assess it, and the Codex decision tree should be applied to it like any other hazard, not skipped because it feels like a quality issue rather than a safety one.
There is a subtlety here that trips people up. Benchmark levels are not critical limits. You cannot set a single time-and-temperature limit that reliably keeps the product safe in the way you can with a pathogen cook step, because acrylamide risk is cumulative and the benchmark is a performance gauge, not a safety threshold. For that reason, most manufacturers manage acrylamide through documented mitigation measures as an OPRP rather than forcing it into a CCP with a critical limit they cannot validate as protective. Run the hazard through the decision tree and let it land where the logic takes it, rather than defaulting to a CCP label that you will struggle to defend at audit.
Under BRC Issue 9 Section 2, your food safety plan has to show that acrylamide has been assessed, that control measures are in place, and that those controls have been validated. This is exactly the kind of process contaminant an auditor will probe if your products are on the higher-risk list.
What You Need to Do
Start by confirming acrylamide appears in the hazard analysis for every relevant product group, whether that is potato-based products, cereal and bakery lines, or roasted coffee. If it is missing from any affected line, that is your first gap.
Then review your mitigation measures against the mandatory measures in Annex IV of the regulation. For potato products, that means raw material selection toward low reducing-sugar varieties, and storage above 6°C to avoid cold sweetening, because refrigerating raw potatoes below that point drives sugar levels up and acrylamide with them. For cereal and bakery products, it means recipe control, consideration of asparaginase where appropriate, and managing the reducing-sugar load. Across all lines, it means controlling time and temperature and working to a defined colour endpoint, because a lighter finished colour is a reliable visual proxy for lower acrylamide.
Name the responsible role and the frequency for each check. Colour endpoint checks sit with production and QA on every batch. Analytical acrylamide testing sits with Technical on a risk-based schedule. Prove your controls work through validation, using laboratory testing to confirm that your colour endpoint and time-temperature settings keep you below the benchmark, then verify with routine colour checks and periodic analysis. Validation proves the control measure works; verification confirms the system is running as intended. Do not confuse the two at audit.
Strengthening Your HACCP System
SafetyCore's structured hazard analysis forces you to assess acrylamide as a chemical hazard against defined control measures for every affected product group. You cannot leave it vague or skip it, which is exactly the discipline this contaminant needs. The Codex decision tree in SafetyCore is applied to every hazard, not just the high-scoring ones, so acrylamide gets classified properly as an OPRP or a documented mitigation measure rather than being quietly dropped because it is not a classic cook step.
Your mitigation measures, target limits, monitoring procedures and corrective actions are documented in one place, so when an auditor asks how you control acrylamide on a given line, you have a structured answer rather than a folder of separate spreadsheets. And if the FSA does move from benchmark levels to maximum levels, that regulatory change is exactly the trigger for a structured review. SafetyCore's triggered review feature means a significant change initiates a documented HACCP review against Codex Step 12 and BRC 2.14, and the immutable audit trail shows the auditor precisely when and how you responded.
Conclusion
This week, pull your acrylamide hazard analysis and check that every affected product group has documented mitigation measures and a validation basis behind them, not just a benchmark figure copied out of the regulation. The FSA is building the evidence base for tighter rules, and the manufacturers who can show controlled, validated, well-documented mitigation are the ones who will adapt without disruption when the regime changes. Treat this review as advance notice, not background noise.
If you're reviewing your HACCP system against these new requirements, SafetyCore gives you a structured way to do it. Start a free trial at safetycore.co.uk.
Reference: Food Standards Agency and Food Standards Scotland, Call for data: Acrylamide in food. Current UK law: retained Commission Regulation (EU) 2017/2158.