The recent publication of the latest Joint Research Centre (JRC) report, EU food system monitoring framework Extending the framework towards governance and resilience 2026, broadens the perspective on the factors that may influence the application and evolution of European food legislation. If we add to this the reports of the cyberattack that affected the refrigeration systems of hundreds of French supermarkets in October, forcing the withdrawal of food products whose condition could not be guaranteed, we can see that the application of food legislation also depends on technological, environmental and economic factors capable of compromising the conditions under which food is produced, stored and marketed. This broader perspective is reflected in the new EU food system monitoring framework developed by the JRC, which incorporates indicators on governance and resilience alongside the traditional dimensions of the food system.
Food legislation continues to be based on consumer protection
The starting point remains unchanged. European Union food legislation is structured around a high level of protection of human life and health, supported by risk analysis, operator responsibility and official controls. Regulation (EC) No 178/2002 provides the foundation for this system and establishes principles that remain fully valid.
What is changing is the context in which these principles must be applied. The digitalisation of processes, pressure on resources such as water, dependence on certain inputs, changes in production systems or disruptions to supply chains may ultimately have consequences for food safety. The value of the JRC’s approach lies precisely in helping to monitor these conditions before they lead to problems requiring a regulatory response.
From regulatory compliance to the ability to anticipate
For food companies, this approach does not mean replacing existing legal obligations or automatically extending their scope. Food safety continues to rely on compliance with applicable requirements, internal controls, traceability and the management of hazards associated with each activity. However, the evolving environment raises the question of whether the systems in place remain adequate when production, storage or supply conditions change.
The refrigeration incident in France is particularly illustrative. From the perspective of food legislation, what matters is not only the IT-related origin of the incident, but also its effects on an essential condition for ensuring the safety of certain foods: maintaining the required temperature. When this condition can no longer be guaranteed, the operator must assess the compliance and safety of the affected products and prevent them from reaching consumers if their condition cannot be guaranteed.
Water, inputs and changes in production systems: regulatory implications
Water is another good example. Its availability and quality affect numerous production and processing activities. Water scarcity may encourage the use of alternative sources, changes in irrigation practices or new reuse solutions. From a regulatory perspective, the key aspect will be to determine, in each case, whether these changes affect the applicable requirements and whether they introduce hazards or exposure pathways that need to be assessed and controlled.
The same logic can be applied to the substitution of raw materials, fertilisers, animal feed or other inputs. Greater diversification can improve continuity of supply, but any change must also be analysed in accordance with the relevant regulations: composition, contaminants, residues, additives, food contact materials, hygiene, traceability or consumer information. Supply resilience cannot be built independently of food safety and legal compliance.
Regulation better aligned with changes in the food system
For authorities, the value of this type of indicator lies in complementing the information already provided by alert systems, official controls, epidemiological surveillance and scientific assessment. Certain environmental, production-related or economic trends can help guide surveillance priorities or identify areas where data generation should be strengthened. However, they should not be confused with a risk assessment or, on their own, justify new regulatory requirements.
This caution is particularly important. European food legislation has specific procedures for assessing and managing risks. Incorporating information on external factors can improve the ability to anticipate risks, but decisions affecting operators and products must continue to be based on sufficient scientific evidence, respect the principle of proportionality and take existing uncertainties into account.
What this means for food companies
For companies, the main practical consequence is the need to link regulatory monitoring more closely with business and food safety management. It is not enough simply to be aware of new legislation when it is published. It is also useful to monitor the factors that may lead to regulatory changes or require adjustments to internal control plans, supplier specifications, traceability systems, production processes or the information provided to consumers.
This is particularly relevant to issues such as water availability and quality, the substitution of ingredients and suppliers, technological changes, continuity of the cold chain or the emergence of new sources of exposure. A company that identifies these changes in advance will be better positioned to assess their regulatory impact and adapt its systems before a compliance or food safety problem materialises.
Conclusion
The JRC framework is relevant to food legislation not because it changes existing obligations, but because it helps place them within an increasingly interdependent production system. Food safety will continue to depend on risk assessment, operator responsibility, internal controls and the actions of the competent authorities.
The difference lies in the ability to anticipate. Integrating technological, environmental, production-related and economic changes into regulatory monitoring can help identify earlier where it will be necessary to review controls, obtain new evidence or adapt the regulatory framework. For companies and authorities, the challenge will be to incorporate this broader perspective without confusing signs of change with demonstrated risks and without losing sight of the scientific and legal principles underpinning European food legislation.
