One Product, Many Rulebooks. Who’s Holding the Map?

Food regulation used to move in step across markets. It’s stopped. And catching up is a leadership job long before it’s a compliance one.

A chief executive who sells across the UK, Europe and the US said something to me recently that’s stuck with me.

“We used to have a regulatory strategy. Now we’ve got three, and they’ve started to contradict each other.”

Three strategies. One product range. All pulling different ways.

For most of my years in this sector, a senior leader could make a quiet assumption and get away with it. The big markets moved in roughly the same direction, at roughly the same pace. Get ahead of one and you were broadly ready for the rest. Regulation was a floor you cleared once. Not a maze you ran again at every border.

That assumption’s quietly stopped being true.

I’ve spent a lot of this year listening to leaders across food and ingredients, and the regulatory conversation has changed shape. It used to be “what are the rules.” Now it’s “which rules, in which market, on whose clock, and how do we keep all of it pointing the same way without the whole thing seizing up.”

That’s a harder question. And it lands on the leadership team long before it ever troubles the lab.

The rules stopped moving together

Line the three big markets up and the split is hard to miss.

The UK went first on promotion and placement. Location restrictions on foods high in fat, salt and sugar came in back in 2022. Volume promotion restrictions followed in late 2025.

Advertising restrictions early in 2026. It's an approach built around nutrient thresholds and around where and how you're even allowed to sell a product. There's also a Healthy Food Standard coming, set out in the government's 10 Year Health Plan. Large businesses will be made to report on how healthy their sales are, then improve the number.

The EU's running its own argument, and a lot of the heat there is on additives and on how processed a food is. Closer to judging a food by what's actually in it than by a single nutrient score.

The US is somewhere else again, and arguably shifting the ground furthest. The FDA's made reform of the Generally Recognised As Safe pathway a priority for 2026, with a proposed rule that would stop manufacturers quietly waving an ingredient through as safe without telling anyone. There's a federal push to define ultra-processed foods. And the centre of gravity is moving away from how much sugar or salt sits in a product, toward how it's made and why each ingredient is in there at all.

Then there's the part that makes the US genuinely hard to plan around. Washington has moved slowly, so the states haven't waited. California and Arizona have passed laws restricting ultra-processed foods, mostly in school meals. One legal analysis counted fifteen states that introduced ultra-processed food bills in 2025, with some, California and Pennsylvania among them, going after what a substance does rather than naming specific additives. West Virginia went bluntest of all, banning a named list of synthetic dyes outright.

A court paused the statewide version late in 2025, though the school ban still stands. Companies have pushed hard for one federal standard to sit on top of all of it. As of 2025, that push hadn't landed.

So this isn't just rules getting tougher. It's rules getting different in kind. A nutrient-threshold rule wants to know how much salt went into the recipe. A processing-based rule wants to know whether you reached for an emulsifier at all, and why. Reformulate to satisfy the first and you can be no further forward on the second. You're not clearing a higher bar.

You're clearing several, set at different heights, in different places, by people who aren't talking to each other.

Two tempting ways to get it wrong

Faced with that, most businesses drift toward one of two answers. Both feel sensible. Both quietly cost you.

The first is to build to the strictest rule and run it everywhere. One global spec, made to satisfy the toughest market in the room. It’s clean. It’s safe. It saves you running ten different recipes in ten different places. The trouble is you then carry the cost of the strictest market into every market that never asked for it. And in the lighter-touch markets, a local competitor who only has to meet the local rule can move faster and price keener. Often does.

The second is to localise the lot. A tailored answer for every market, tuned rule by rule. On paper it’s the responsive choice. In practice it breeds complexity, slows every decision to a crawl, duplicates work across teams who barely speak to one another, and quietly eats the economies of scale that made the business work in the first place.

And here’s the thing. The mistake isn’t picking one over the other. It’s sliding into one of them by accident. Standardising here because it’s less hassle. Localising there because someone shouted loudest in the meeting. The actual job is to choose, on purpose, product by product and market by market, where sameness is worth paying for and where difference earns its keep.

That’s a strategic call. Someone with real breadth and real authority has to make it.

Nobody’s holding the map

Here’s the instinct I see most, and why it falls short.

The natural move is to push all this down to local compliance. A regulatory team in each market, each one keeping its own corner tidy. Fair enough, as far as it goes. But it leaves nobody owning the part that actually matters now. The coherence across the whole thing.

The judgement about where the business holds one line and where it bends. Local teams keep you legal in their patch. They were never asked to make a portfolio call across three continents, and they’re not sitting where they could.

I’ve started thinking of it as holding the map. Someone has to be looking at the whole board at once, every market and how they interact, and deciding the business’s response to the shape of it. Not nine people each squinting at their own square.

What’s missing in a lot of teams is exactly that person. Someone near the top who treats this divergence as a strategic input, not a compliance chore. Genuinely fluent across more than one regime. Able to look at a fragmented map and call the play for the whole business.

That profile is scarce, and for a reason that makes sense. Most regulatory careers run deep in one market. Someone who can sit above several at once, hold the commercial picture next to the legal one, and turn a mess of clashing rules into a clear line, that’s a rarer animal. Most businesses haven’t even drawn the box on the org chart yet, let alone worked out who goes in it. The ones getting ahead are starting to look sideways for it, to sectors like pharma and medical nutrition, where living under several demanding regulators at once has always just been the job.

There’s a quieter version of this for the investors reading, too. A lot of growth stories lean on entering new geographies. The market size gets modelled to the decimal point. The regulatory divergence riding along with those new markets rarely does. Worth asking, of any business chasing cross-border growth, whether anyone’s actually priced the work of leading across all those rulebooks. Or whether the plan just assumes the rules travel with you.

Questions worth putting on the table

If you run, back, or sit on the board of a business selling into more than one market, a few questions are worth raising this year. Not after the next rule lands.

Do we have one regulatory strategy, or three that nobody’s reconciling?

If every market runs its own playbook and no one owns how they fit together, you haven’t got a strategy. You’ve got three, quietly competing for the same budget and the same factory time.

Where are we standardising or localising by accident rather than on purpose?

Drift is the expensive option wearing the easy option’s clothes. Every place you’ve defaulted is a place you haven’t actually decided.

Who here can look at three diverging rulebooks and make one coherent call?

If the honest answer is that the person who can do this sits a few rungs below the board, your cross-market decisions will always run slower than the markets moving against you.

The real test

Divergence isn’t a phase that tidies itself away once everyone agrees on a definition. As long as different governments answer the same questions about food differently, and on their own clocks, the map stays in pieces. Planning for it to come back together is planning for a world that’s drifting the other way.

That’s a cost. But it’s also where the opening is. Complexity that other people find too painful to manage turns into a barrier they can’t get past. The business that moves confidently across a fragmented map can go where more nervous competitors won’t, precisely because the rules there look too hard. Difficulty, handled well, is a moat.

The reformulations will get done. The labels will get changed. They usually do. The harder, more valuable question sits above all of that.

Who in your business is holding the whole map at once, and deciding, market by market, where to hold the line and where to bend?

If you can’t name that person cleanly, that’s worth more of your attention than the next rule change. Because the next rule change is coming either way. The only thing in your gift is whether someone’s ready to lead through it.

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This is part of my “Behind the Scenes” series, where I share what I’m picking up from conversations with the leaders, founders and operators shaping the future of food. If something here landed, I’d like to hear how you’re seeing it.

Mike Meyrick is Founder and CEO of Meyrick Consulting, an international executive search firm operating across the food and food ingredients sector.