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Webinar: the role of agri-tech in strengthening the UK’s food system

GK Strategy invites you to a webinar panel discussion on:
The National Food Strategy: the role of agri-tech in strengthening the UK’s food system

Keynote speakers:

Steve Brine
Strategic Adviser at GK Strategy and former health minister and chair of health and social care select committee

Honor May Elridge
US and UK farming policy expert and former senior legislative advisor at the Food Standards Agency

Wednesday 22 October from 15:00 to 16:00

This event will held on Zoom.

Please RSVP by emailing event@gkstrategy.com for joining details.

Steve Brine is a Strategic Adviser at GK Strategy. He was Member of Parliament for Winchester from 2010-2024 and served in government as a Whip, public health minister and chaired the influential Health and Social Care Select Committee. Steve’s main interests include primary care, public health, NHS leadership and prevention of ill health as well as HIV, health tech and cancer. He also co-hosts the successful ‘Prevention is the new cure’ podcast and lives in Hampshire. He now works in the private sector as a health advisor and speaker and is a charity trustee.

Honor May Elridge is a policy and advisory expert in food and environment impact, working to advise NGOs and businesses in the agriculture and food retail sectors. Her expertise spans international trade, climate-resilient agriculture, and food system transformation — always with an eye on equity and long-term viability. Honor was previously the Senior Legislative Advisor to the Food Standards Agency, working on how innovation can be delivered through regulation. She is currently working on two books on the future of food. She is also known for her wry appreciation of the avocado, having written her first book on the fruit that has, somewhat unfairly, borne the brunt of intergenerational debate. Once spotlighted as the unlikely culprit behind millennials’ housing woes, the avocado now serves as a symbol of Honor’s approach to food and farming policy: humble, misunderstood, and full of potential.

Trump Administration deregulatory push yields industry wish list for rule rollbacks

By Erin Caddell, Anchor Advisors LLC – A GK Strategy partner firm

Amidst the mile-a-minute pace of activity in the Trump Administration’s first six months, the Office of Management and Budget (OMB)’s April 11th posting of Federal Register document 2025-06316, “Request for Information: Deregulation” did not exactly make for scintillating tabloid reading. Yet the effort initiated by OMB’s memo is likely to spark substantial regulatory activity by a number of federal agencies starting this fall and into the remainder of Trump’s current term that will be highly impactful across a range of industries in the U.S.

OMB’s request for information (RFI) was prepared in response to an Executive Order signed by President Trump on April 9th to repeal “[u]nlawful, unnecessary and onerous regulations”. The order notes that the U.S. Supreme Court has issued a number of rulings in recent years limiting the power of federal agencies, and asks commenters to identify regulations now inconsistent with these decisions.

Companies and their trade associations were only too happy to respond to OMB’s request. The RFI received nearly 8,500 comments during the 30-day window (though some were from individuals calling for caution against moving too quickly to deregulate). OMB and federal agencies will likely begin the process of repealing or amending certain rules cited in the comments starting this fall. Importantly, the executive order notes that agencies may attempt to rescind the rules in question without the traditional notice-and-comment period required for formal rulemaking, which can add months if not years to the process. The order cites a provision in the Administrative Procedures Act (APA) providing a “good cause” exemption to traditional rulemaking requirements if the original rule is “impracticable, unnecessary or contrary to the public interest.” Any attempts to circumvent the rulemaking process would be met immediately by legal challenges (interestingly, the Mortgage Bankers Association, an influential trade association, argued that agencies should continue to utilize the notice-and-comment process, as abandoning this function could rob industry with a key means of providing input). But even if ultimately overturned, companies would have to make accommodations to assume a proposed repeal could become effective, particularly if intermediate courts support the Administration.

So what does Corporate America hope to deregulate? Anchor reviewed a representative sample of comment letters submitted by trade associations representing a range of industries. We summarize in the table below recommendations from six of these comments. Taken together, the missives describe their authors’ frustrations with the blizzard of rulemaking under the Biden Administration and cite hundreds of regulations they believe should be repealed or revised in the name of spurring economic growth and reducing the administrative burden.

Select Industry Association Responses to OMB Deregulation Request for Input (RFI)

Organization	Rule cited	Agency(s)	Year	Commenter’s rationale
Mortgage Bankers Association (MBA)	Adoption of energy efficiency standards for new construction of HUD- and USDA-financed housing	HUD, USDA	2024	Will drive up costs for new single-family and multi-family construction; 30 states still operating under prior standard enacted in 2009; shortage of inspectors trained on new standard.
National Multifamily Housing Council/National Apartment Association	Floodplain management and protection of wetlands	HUD	2024	Imposes substantial compliance costs on homeowners without robust data on actual risk reduction benefits nationwide.
Information Technology and Innovation Foundation	Rule requiring minimum of two crew members on most US freight and passenger train journeys.	Federal Railroad Administration	2024	Lacks foundation in safety data; is driven by labor-union pressures; automated braking systems and other technological advances intended to mitigate accidents caused by human error.
American Petroleum Institute (API)	National Ambient Air Quality Standards (NAAQS) for Particulate Matter	EPA	2024	In 2024, EPA mandated a lowering of maximum air particulate matter – a measure of air quality – of no more than 9.0 micrograms per cubic meter vs. 12.0 previously. API argues no new scientific evidence had emerged to warrant such a reduction. API argues the new standard will limit economic growth. The group supports revising, not repealing the rule.
Small Business Low Risk Coalition (group of manufacturing/industrial trade associations)	Multi-sector general permit rules for stormwater discharge from industrial facilities	EPA	2021	Argues 2021 version of standard was issued in overly hasty fashion relative to the 2015 version, which received lengthy multiagency review. The group argues that the 2021 permit rules added costly, unnecessary analytical monitoring requirements for many industries.
American Hospital Association (AHA)	Remove telehealth originating and geographic site restrictions within the Medicare program.	CMS	Various	Currently, Medicare patients in urban or suburban areas do not have the same access to telehealth services covered by Medicare as those in rural areas; in other cases patients must be in a clinical setting to receive telehealth services, which defeats their purpose.

Source: Regulations.gov

What does this mean for investors and companies? The OMB request for information and its many industry responses are a sign that deregulation – obscured thus far by the trade war, the immigration crackdown and the many controversies that follow the current Administration – will nonetheless be a key theme for Trump’s second term. The fall Unified Regulatory Agenda, a document published by presidential Administrations twice a year that details each federal agency’s priorities for the coming 12 months, will provide clues as to how the Administration has translated OMB’s fact-finding mission into agency priorities.

Given the inclination of Trump, Vought and those around them in the Administration, OMB is likely to push ahead with many of the deregulatory recommendations put forth in the comment letters. Opponents will attempt to counter these efforts through the courts, with their allies in Congress, and by attempting to influence public opinion. But as with many other aspects of the Trump Administration, critics will face the challenge of fighting many battles at once.

History also shows that deregulation can be a double-edged sword for the private sector. The Global Financial Crisis of 2007-08, which followed a long period of loosened of the U.S. financial services industry, is the most striking recent example. But more recent cases like the collapse of Silicon Valley Bank in spring 2023 demonstrate the dangers of lighter-touch regulation. In that case, rule changes reducing capital and liquidity requirements for banks of Silicon Valley’s size encouraged the firm to increase its risk profile, making the firm highly vulnerable to a rise in short-term interest rates. Companies must do more on their own to protect their businesses, customers and employees at times when the pendulum swings toward deregulation. Ethics committees, ombudsmen and similar compliance measures (Anchor and its partners can help with this!) can serve companies well at times like this when animal spirits are running high – on Wall Street as well as in Washington, D.C.

Milking it! Extending the sugar tax for public health and economic gain

This week the government launched a consultation on its plans to tighten the sugar levy. This follows last year’s review of the effectiveness of the SDIL to date. Chancellor Rachel Reeves strongly hinted that the government was considering broadening the scope of the levy at October’s autumn budget and the consultation document does just that.

The government’s proposals include reducing the minimum sugar content level at which the levy applies from 5g to 4g; removing the exemption for milk-based drinks; and removing the exemption for milk substitute drinks. This means milkshakes, pre-made coffees and many of your favourite fizzy drinks will be reformulated or face becoming taxable.

Initial analysis suggests that over 90% of milk-based products will be affected. Initially exempt because milk is a source of calcium for children, the government’s revised position is that any potential health benefits are outweighed by the negative impact of consuming high levels of sugar.

Although the contents of this consultation come as no surprise to those who have been closely following policymaking in this space, it does set the mood music for the upcoming national food strategy and signals a government unafraid to be heavy-handed when it comes to public health. Although the SDIL is widely considered to be a successful and effective policy intervention, the UK’s sugar consumption remains significantly above recommended levels, especially among children. By lowering the sugar thresholds and widening the scope of products, more soft drink producers will be forced to reformulate products or see their production costs increase. However businesses decide to act in response to changing regulations, the government hopes the result is a significant reduction in the nation’s consumption of sugar.

Obesity costs the NHS around £6.5 billion a year. NHS data shows a deeply concerning trend of rising childhood obesity. Almost 10% of children are now living with obesity by the time they start school and 24% of children have tooth decay by aged five thanks to excess sugar consumption. With obesity taking effect earlier in life, the associated costs for the NHS are set to soar to £9.7 billion by 2050. This is especially bad news for a government grappling with a challenging economic environment and acute pressures on public spending. But for Labour, it feels all the more personal because in the most deprived areas the prevalence of obesity can be almost 15% higher than in the least deprived ones – something that the last government’s food strategy picked up on. Tackling health inequality is a huge part of the government’s commitment to ensuring all children and young people have the same opportunities and start in life.

For industry, there is a fine balance to strike. Full resistance to public health reforms designed to improve the health of our children would leave a bad taste in consumers’ mouths. Developing and maintaining an open, constructive dialogue with government, including showcasing innovative reformulations, will be a far more effective approach. Framed in this way, industry will be able to better make the case that a proportionate approach to SDIL and wider public health reforms will deliver positive health and economic change.

Now is the time to engage. Those who can successfully demonstrate alignment with the government’s public health goals will be well-positioned for future discussions about the developing national food strategy, which will set the strategic direction of travel for the rest of this parliament and beyond. One thing is for sure, this is unlikely to be the last government intervention in the name of improving the nation’s health.

The consultation runs until 21 July. If you’d like to discuss contributing to it or the wider HFSS policy environment, please contact Lauren on lauren.atkins@gkstrategy.com.

What does the future hold for crypto regulation?

Positioning the UK as a leader in the global market

UK policymakers and regulators have expressed their intention to encourage growth, innovation and competition in the digital assets industry. However, the government also wants to protect consumers and maintain market integrity. This is a balance that policymakers and regulators in other jurisdictions have found difficult to strike. The previous Conservative government wanted to make the UK a global hub for cryptoasset technology and investment – a goal shared by Keir Starmer.

Accelerating the timeline for reform

In 2018, HM Treasury (HMT) and the Financial Conduct Authority (FCA) began coordinating a phased regulatory approach, initially focusing on stablecoins before introducing new regulations for the wider cryptoassets industry.

Since the 2024 general election, the FCA’s approach has shifted slightly. The government has indicated its support for most of the reforms set out prior to the general election. However, Starmer is less focused on stablecoins than his predecessor and is likely to accelerate the timeline for the regulation of the wider cryptoasset industry, rather than adopt the phased approach.

The government is aware that other international hubs have also taken significant steps in regulating digital assets. The EU’s Markets in Crypto-Assets Regulation (MiCA) became fully applicable in December 2024 and has introduced a comprehensive regulatory regime for the European bloc’s digital asset market. Given the EU continues to work on secondary legislation to supplement MiCA and also requires crypto firms to align with other EU rules on governance and data-sharing, the EU’s new regime is likely to significantly increase the regulatory burden on firms. The second Trump administration has already signalled that it will take a much more lenient approach in the US compared to the Biden administration. Trump has issued an executive order directing agencies within his administration to create a regulatory framework that supports the cryptoassets industry and limits unnecessary government intervention.

Firms operating across multiple jurisdictions need to be cognisant of how the UK’s approach differs with other cryptoasset hubs to ensure compliance. The government is likely to favour an approach that places the UK somewhere between the EU and the US. While the UK’s eventual cryptoassets regime is likely to provide stronger consumer protections than a Trump-inspired US regime, it is unlikely to be as prescriptive as the EU on the categorisation of cryptoassets, the scope of regulated activities, and disclosure obligations for cryptoasset issuers.

Implementing the new regulatory regime

In November 2024, the FCA published a “Crypto Roadmap” of key dates for the development and introduction of the UK’s cryptoasset regime. The roadmap sets out a series of consultations focused on different aspects of the future regulatory regime to be held over the course of 2025 and during the first quarter of 2026, with the final rules published in 2026. This includes the completion of a consultation on the proposed creation of an information sharing platform for industry stakeholders (to be approved by HMT) to prevent market abuse and boost compliance with future regulation. The FCA also plans to consult on a governance regime in autumn 2025 including further measures to ensure crypto firms adhere to the FCA’s Consumer Duty and its Senior Managers and Certification Regime (SMCR). This would likely require individuals in senior roles at firms be approved by the FCA or the Prudential Regulatory Authority.

The cryptoassets industry is likely to benefit from Chancellor Rachel Reeves’ decision to urge regulators to accelerate efforts to support growth and innovation. As part of a wider deregulation push, Reeves tweaked the FCA’s secondary objective to make it clear that the regulator must do more to make the UK financial services markets more competitive than other countries. Although the FCA’s CEO Nikhil Rathi is concerned that deregulation could lead to ‘bad actors slipping through the net’, he has said that he is willing to consider the easing of some consumer protections to reduce the regulatory burden. This could be significant for the cryptoassets industry. Larger firms are currently better placed to comply with expected new regulatory measures, while smaller firms may not have the internal structures and resources to do so, potentially forcing them out of the market or creating opportunities for consolidation.

We’d be delighted to share our perspectives on what the government’s crypto and fintech reforms could mean for you and how you can engage with policy debates. Please contact joshua@gkstrategy.com if you would like to discuss the reforms with the GK team.

GK Podcast: Skills England and Apprenticeships Reform

GK Strategy is pleased to present the latest episode of its podcast. This episode focuses on the government’s wide-ranging reforms to the apprenticeships and skills system, and the potential impact on employers, providers and learners.

In this episode we speak to GK Strategic Adviser and former Minister for Skills and Higher Education, the Rt Hon Robert Halfon, and former advisor to the Department for Education and former Director of EDSK, Tom Richmond.

The podcast can be listened to here: GK Strategy Podcast – Episode 3.

Navigating changes to food and drink packaging: A guide for investors

Mark Field, director and founder of Prof Consulting Group, outlines what investors need to know about packaging in the food and drink sector

Setting the scene

Food and drink packaging is undergoing major transformation with innovations at each stage of the value chain. By responding to regulatory, consumer, and supply chain challenges, companies are finding new ways to reach customers and help them shop more sustainably. The role of packaging is to keep food and drink intact, safe and fresh along its journey from producer to consumer. It provides a space to communicate information to customers and to represent a brand. Carefully managed, it is a window to showcase a company’s values, but poor execution risks significant brand damage.

Shifts in the regulatory and commercial landscape

Regulation – responding to concerns about environmental pollution and climate breakdown, the regulatory landscape is shifting to place responsibility on producers for the packaging they put into the market.

In Europe, the upcoming PPWR is part of the region’s circular economy plan to value waste and minimise its environmental impact. The new regulation updates existing rules and aims to harmonise how packaging is managed throughout EU countries, making trade smoother. PPWR will require all countries to increase the share of reusable packaging which includes deposit return schemes, targets, economic incentives and minimum percentages of reusable packaging. In addition, 70% of all packaging by weight must be recycled by 2030. For some companies this might mean investing in new packaging equipment to handle new materials, for example, in the transition from plastic to paper. For others it can mean an entirely new way of selling, such as using returnable glass jars instead of plastic pots.

Nations in the UK are considering (England) or have implemented (Wales) deposit return schemes where consumers return packaging to a retail outlet and receive money back. This requires investment into infrastructure such as reverse vending machines. Others are working with digital technology to trace their products through the recycling system starting with the home curb side collection and rewarding customers who participate.

The UK’s plastic packaging tax charges a flat rate per tonne of plastic packaging with less than 30% recycled plastic. Companies must ensure they have accurate information on the packaging they buy to submit data to a government register.

Communication on packaging sustainability must be accurate and not mislead consumers according to the upcoming EU Green Claims Directive and the UK’s existing CMA’s Green Claims Code. One of the goals is to ensure that consumers are empowered to participate in the circular economy and can make informed choices. Consumers and NGOs are alert to greenwashing and don’t hesitate to call out companies who overstep the line.

A new UN treaty to regulate the production and disposal of plastic is expected at the end of 2024. Brands are calling for a limit to the amount of virgin plastic produced and for support on recycling and reuse systems.

Consumers – people expect companies to ensure their packaging is sustainable and research shows they want to participate in the transformation. According to global surveys, recycling packaging is the most popular sustainable behaviour, practiced by 62% of people. Companies can respond to these needs with clear and accurate disposal communication and with innovation in packaging formats.

Supply chains – extracting raw materials places undue pressure on natural resources and creates pollution that worsens climate and nature breakdown. Reducing the extraction of virgin raw materials, such as oil and timber, is urgent. Food and drink companies can limit their contribution to these challenges and take the opportunity to strengthen their resilience in the face of shortages and rising costs. UK and EU packaging leaders are moving from efficiency and lightweighting towards new materials, recyclable and recycled, and reusable packaging formats. For example, alcoholic drinks companies are experimenting with infinitely recyclable aluminium instead of glass, and being lighter, the product has fewer transport emissions.

Risks and opportunities

Companies who are unable to understand or keep pace with regulatory changes face increased costs resulting from levies on non-recyclable packaging, fines for misleading green claims and increased costs of excess packaging. Evidence shows that if customers are disappointed, companies will lose sales.

However, leading companies in the sector are embracing the transformation and innovating across the value chain. For example, with smart packaging technology using freshness tags; using alternative materials to plastic such as seaweed coatings and mushroom fibre cushioning; and using more reusable and refillable packaging. Infrastructure to support circularity is also growing, with refill stations, mobile and fixed reverse vending machines, and scanning and tracking technology increasingly prevalent. Cameras and cloud-based systems can be used to enable traceability and visibility over each process involved in collecting, recycling and cleaning packaging.

Companies that can promote and support convenient sustainable living will succeed in today’s crowded market. Many value-driven brands are entering the market and winning customers on this basis.

What should investors be asking?

Investors who want to understand the sustainability of packaging used by food and drink businesses should be asking management teams the following questions:

How does the business actively prepare for upcoming regulatory change and comply with existing regulations?

Does the business follow industry codes and benchmarks?

How does the business track the competitive landscape and identify gaps and innovations that resonate with consumers?

Does the business understand how customers use and dispose of their packaging?

Does existing packaging have clear recycle/reuse instructions?

Can the business substantiate claims on packaging sustainability?

Does the business know and manage the full life cycle along the value chain from raw material production through to disposal?

Does the business communicate their sustainability status openly e.g. on website linked to a QR code on packaging?

How does the business collaborate with stakeholders in all markets to ensure their packaging is reused/recycled correctly?

Prof Consulting Group helps to lead business to success in the UK and Australian food industry with its team of industry-leading experts and extensive range of services. For more information or to discuss how Prof. Consulting Group can support your business, please visit https://www.profcg.com/contact/