This note went to CTA Members directly after the FSA Board Meeting in December to notify them that there is a serious delay to the NF process.
The to clarify why there has once again been no regulatory progress on the three isolated CBD Novel Foods dossiers, RP 07, Chanelle McCoy, RP427 EIHA Consortium, and RP350 Cannaray which are still awaiting Ministerial Approval sign-off which was anticipated this year.
Following recent correspondence between the CTA (Cannabis Trades Association) and Food Standards Scotland (FSS), it is now evident that the anticipated Approvals for these 3 isolated CBD product dossiers has been severely stalled once more. Food Standards Scotland (FSS) has confirmed to the CTA that it intends to launch its own CBD Consultation in early in 2026, running for 12 weeks. This consultation will not be limited to isolated CBD or Novel Foods dossiers already assessed, but will also consider wider food law issues, including food supplements and nutrition-related requirements.
FSS has also confirmed that it operates alongside the Food Standards Agency (FSA) on a United Kingdom, four-nation basis. This means that any outcome of the Scottish CBD consultation will be considered alongside the recent FSA’s (England, Wales and Northern Ireland) CBD consultation before a UK-wide position will be agreed and advanced by the FSA.
Three isolated CBD dossiers have already undergone extensive safety assessment. However, instead of moving these dossiers to UK ministerial sign-off, they are now being effectively held within a broader consultation process that extends beyond isolated CBD in its scope.
The proposed FSS CBD consultation timetable overlaps directly with the May 2026 Devolved Parliament elections in Scotland and Wales, as well as Local elections in England.
FSS acknowledged that elections may result in new devolved nation ministers taking responsibility for regulated product decisions, including CBD.
While FSS will continue to provide scientific and risk management advice regardless of political changes, authorisation decisions still require ministerial approval in the devolved nations as well as by a UK Minister of State.
With the Scottish CBD Consultation timetable, the Elections in May 2026, and possibly new Ministers being involved in the Approvals process, the CTA cannot see how a UK Minister of State can sign off ANY dossiers before Autumn/Winter 2026.
Worse still is the SPS negotiations between the UK and EU for Foods, which will now likely include CBD foods and supplements all under the EFSA, which we were hoping to avoid by getting UK sign off for the three Isolated CBD dossiers prior to the broader negotiations.
What this means for businesses relying on isolated CBD
The industry will by February 2026 have been waiting six years under the Novel Foods regime for product authorisation. This is particularly concerning for companies relying on isolated CBD, resulting in absolute zero clarity on when compliant isolated CBD products will be formally authorised in the UK.
This ongoing uncertainty across the CBD sector continues to disadvantage businesses that have acted in good faith, invested heavily in safety data, reformulation, and regulatory compliance, and limited their products specifically to isolated CBD in line with regulator expectations.
CTA position
The CTA has made it clear on behalf of the CBD sector that isolated CBD dossiers should not be repeatedly delayed by broader policy considerations that go beyond Novel Foods safety assessment requirements.
Our concerns are heightened by the possibility that supplements (including CBD supplements) might be placed under a different/amended regulatory pathway.
The CTA continues to press for:-
- A clear pathway for isolated CBD, Broad and Full spectrum CBD authorisations
- Transparency on timelines for ministerial sign-off of these isolated dossiers
- Proportionate, evidence-based decision-making for low-risk CBD consumer products
- Regulatory certainty for businesses that have complied with every single requirement placed upon them by the FSA.
If you would like to discuss how this impacts your business or contribute to CTA policy work on Novel Foods, please do make contact.






