Food safety has long been governed by physical controls: temperature checks, contamination thresholds, hygiene inspections. In 2021, the European Union took the harder step of legislating culture itself. Regulation (EU) 2021/382 made food safety culture a binding requirement for food business operators across all member states, defining it through five components: commitment, leadership, awareness, communication, and sufficient resources. A European Commission survey conducted in 2025 and published in June 2026 found that while progress has been made, 22 of 27 member states reported significant challenges in implementing official controls. For food business operators and competent authorities in Ireland and across Europe, the survey does not describe a slow start. It describes a structural gap that carries real regulatory and public health consequences.

The core difficulty is not indifference. It is measurement. Member states consistently report that food safety culture components are inherently subjective, making it difficult to develop assessment criteria that can be applied objectively and consistently across inspectors, sectors, and establishment sizes. Only one member state, Austria, currently uses culture-specific audits. The majority have instead absorbed culture requirements into existing HACCP and food safety management system controls, a pragmatic approach that risks reducing culture to a documentation exercise rather than a genuine behavioural standard. Three member states have not made any of their official control staff aware of the culture provisions at all, five years after the regulation came into force.

Ireland's position is worth noting positively. The Food Safety Authority of Ireland has published dedicated guidance and online learning modules for food business operators, and the country was cited in the Commission survey as an example of incorporating culture assessment within official controls. That foundation now needs to be built upon rather than treated as sufficient. Three practical steps would accelerate progress across the sector. First, competent authorities should adopt the self-assessment tools already developed in Spain and the Netherlands, adapting them to Irish sector conditions and making them freely available to small and medium food businesses where the compliance burden is greatest. Second, food business operators should move beyond treating culture as an audit checklist and integrate its five components into induction, ongoing training, and management review cycles, with measurable indicators rather than narrative descriptions. Third, industry bodies and competent authorities should jointly develop sector-specific culture benchmarks for high-risk categories, particularly food of animal origin, where the Commission survey found the highest rates of noncompliance.

The subjective nature of culture is a genuine challenge, but it is not a reason for inaction. Consumer trust in food systems depends on the behaviours behind the controls, not only the controls themselves. Member states that treat culture as an administrative add-on rather than a measurable management commitment will find that gap reflected in their noncompliance rates.

(The views expressed by the writer are his/her own and do not necessarily reflect the views or positions of BusinessRiver.)