The Age of Reckoning for Food Supply Chain

This is an article from my LinkedIn newsletter “Food in the Spotlight

This issue is fully dedicated to a simplified abstract of my final keynote at BRCGS Connect 2025, addressing today’s global challenges for our industry (but not only!).

You will also find video snippets of the live talk, reflections about the role of modern lawyers, and news from our social feeds.

Intro

We’re going to take a quick journey through the many factors currently impacting and shaping global supply chains. We live in turbulent times and must face a new reality, adapting to the dramatic changes we’ve witnessed in recent years.

So, why me? … why not? You Brits got that one.

Because in our companies, we deal with product compliance — especially labeling and food safety — every single day. However, we also have the privilege of observing different needs and positions across the supply chain. We assist retailers, manufacturers, and online players from very diverse countries, so we have a clear perception of the main issues.

Another reason I feel I can offer valuable insights is that one of my not-so-hidden missions since founding my business in 2012 has been to communicate a simple concept to food executives and board members: compliance is not a cost, it’s a leveraged investment in your company’s future. Compliance not only protects against major damages and backlashes — especially if you’re exposed to public scrutiny — but it can also help you gain competitive advantages.

Let’s talk about sustainability. As we already discussed, yes, sustainability comes at a cost. Consumers want it, but they are not so willing/able to pay for it. Any investment comes with an initial cost, but some of them are smart investments in your positioning and can anticipate future trends.

Global Trends in the Food System

Let’s look at some other global trends. We’ve seen a series of major shocks impacting supply chains. The first of these, in what we might call the post-COVID era, was COVID itself.

COVID-19 revealed vulnerabilities in our supply chains but also showed how remarkably resilient they are. We absorbed the shock well. However, subsequent shocks related to raw material prices, inflation, wars, and trade disruptions have put even more pressure on supply chains than COVID-19 did.

We also saw dramatic shifts in consumer behavior during the early stages of the pandemic. But we’ve learned that consumers are conservative. As soon as the crisis ends, they tend to revert to old habits. The massive investments in food delivery and online services were a response to this shift, but many of those ventures didn’t end well. After COVID-19, companies faced layoffs and cutbacks because consumer behavior in part normalized.

The main issue today is that prices of raw materials and production inputs, which began rising during COVID-19, continue to do so, driven by multiple factors we’ll explore today.

The reality we must face is that we had a sequence of shocks that put our supply chains under major strain, and they are not likely to end today.

Policy Shifts

Let’s start with the EU. The so-called “Green Deal” has been quietly buried. The EU Commission is still trying to achieve something, particularly in areas like environmental labeling and green claims, and a new Packaging Waste Regulation was just published.

But bold goals like cutting pesticide use drastically, increasing organic production, etc.? Most of such goals are no longer feasible in today’s economic conditions.

The Green Deal’s main flaw was a single one: the lack of a real economic assessment of the transition impact. I well remember what the European Commission said on the Green Deal webpage when it was launched: “We don’t care about costs, inaction will cost more”. Yes, but… who pays? That’s always the question during massive transitions. If you do not have an answer, you sound like Alice in Wonderland.

And we’re now repeating the same mistake after the U.S. elections, trying to relaunch European competitiveness and catching up on AI with funds that are laughable compared to the investment we see in the U.S.

From a regulatory perspective, on a global scale, another trend is clear: growing attention to food high in fat, sugar, and salt (HFSS). We’re seeing more and more nutrient profiling, front-of-pack labeling initiatives, and HFSS ads to children restrictions.

Another interesting factor? The rise of GLP-1 drugs — originally developed to treat diabetes — but impacting appetite and hunger signals acting on the related receptors. Drugs like Ozempic and Wegovy are increasingly cited in financial reports as potential threats to the food industry, especially for fast food and companies indulgent on HFSS foods.

Do I believe they’re an existential threat? Probably not. I don’t foresee a dystopian future where we’re all slim and fit thanks to government-subsidized GLP-1 drugs, and nobody ever eats chocolate again. That would be very sad, wouldn’t it? It could make sense from an economic perspective because it will cut both the price of the medication and the huge bill paid by health systems for obesity-related issues. But what about the rebound effects when you stop taking your pills? Can we possibly live under treatment? I do not think that’s something we will see.

Still, it’s a factor worth monitoring.

The U.S. and Global Regulations

Now, why is the U.S. situation so complex?

From a regulatory perspective, we are seeing mixed signals. The FDA was active early this year, issuing guidance on allergens and proposing a ban — effective 2026 — on Red Dye №3 (known in the EU as erythrosine and still allowed). But these measures are now under a regulatory freeze imposed by the Trump administration.

At the same time, the appointment of RFK Jr. to lead the U.S. health system, a person known for his radical views on food additives and public health, adds more unpredictability.

What will happen with front-of-pack labeling or the additive bans? No one knows. Will it never be in place due to Trump’s cabinet’s strong support for the industry, or will it be upheld by RFK Jr. in his attempt to MAGA (Make America Healthy Again)?

The U.S. has also withdrawn from supporting the WHO, and we don’t know what role it will play in Codex Alimentarius or other global food-standard organizations in the future. To complicate things further, the FDA and other agencies have seen massive layoffs recently.

All of this contributes to increasing misalignment between global standards and uncertainty in the markets.

Trade Wars and Raw Materials

Trade is another troubled area. Trump’s aggressive trade stance seems more like a bargaining tactic than a real strategy. Maybe tariffs will rise again… or maybe they won’t. Or they won’t so dramatically. In any case, tariffs push up inflation and raw material costs: this can backfire, and the U.S. might be forced to backtrack.

But in the meantime, threats of retaliatory tariffs are flying back and forth: China, the EU, the U.S. — it’s tit for tat. And it doesn’t matter whether the product is food, wine, chips, or tech; everyone is potentially involved, and there is no certainty where the hammer will fall.

All of this complicates import/export dynamics and increases price volatility.

Take cocoa and coffee. Their prices have skyrocketed, even by 400%. It’s hard to understand how a cup of coffee still costs the same in some cities as it did four years ago. The farming inputs, labor, energy…everything has gone up. Primary producers and manufacturers are under extreme pressure.

Strict migration policies also affect the availability of low-cost labor, essential for certain agricultural and food production jobs. If no one is willing to take those jobs, production suffers.

Fraud, Economic Pressure, and Trust

All this pressure means we’re likely to see more food safety issues and fraudulent practices. It’s inevitable. Expect more documentary fraud, certificate fraud, and corner-cutting.

If we push suppliers too hard, they’ll cheat. It’s a simple cause-and-effect relationship.

The more we increase input costs, the more incentive there is for fraud, especially for products where consumers are still willing to pay a premium.

So, maintaining trust is essential across the food industry, certification bodies, and retailers.

Otherwise, public opinion — already skeptical of many practices in the food industry — will worsen. I personally think the food industry does a great job, but perception matters more than reality in today’s world.

War, Innovation, and AI

War, sadly, has always driven investment in new technologies: nuclear energy, GPS, biotech. Name one. Decisive inputs were given to their development for military use. In wartime, countries throw away caution and invest heavily in what might give them an edge. And today,, we see too many conflicts around and an unpleasant sensation that something even more serious in scale might happen is quite pervasive. We might expect the same again: more turbulence but also more innovation.

Speaking of innovation, let’s talk about AI. Everyone’s talking about it. Where will it create the most disruption (and therefore, value)?

AI won’t replace plumbers or technicians: it can’t do manual work. However, it is already replacing low-skilled, repetitive intellectual work. If it hasn’t replaced those tasks in your company yet, it’s probably just because your boss hasn’t realized how well the tools work.

Even high-skilled specialized intellectual work is now being assisted by AI and possibly will be in part replaced. I use it myself, and 99% of the time can still make my texts clearer, shorter, and more catchy, and automate the creation of a presentation like the one you are looking at today. In the near future, we’ll likely become managers of AI systems, using them to avoid mistakes, speed up tasks, and answer emails better than we do!

Try uploading a few emails into ChatGPT. The system can detect tone, context, and even the recipient’s name, and respond appropriately. It learns fat, and even if it’s not conscious, it’s incredibly intelligent. We always tend to overlap the two concepts, but we do have no idea how to create consciousness and we cannot call “conscious” an AI tool just because can adapt the tone to the conversation or predict my behaviors: that’s why — at least for now — despite understanding the huge risks of AI (e.g. information manipulation at new levels) I do not see the machines take over and confine us in the Matrix.

AI will make smart smarter and dumb dumber.

On top of that, it will soon deliver personalized consumer experiences. Whether it’s booking travel or buying groceries, we’ll rely on AI agents to cut through the noise and deliver what fits us best based on our past data and preferences. You can say to me now that you won’t do it, but you will: already today, if you have to find info about me, or you have to book your holidays, what are you doing? You go on Google, you go on Expedia, and you leave track of your preferences. Tomorrow, you will go on AI-powered tools that record, analyze, and try to anticipate your needs and provide many more insights and articulated opinions than an actual web browser.

In our industry, AI will help predict equipment failures, optimize processes, and accelerate biotech development. Think of AI helping select genetic traits for new crops using NGTs (New Genomic Techniques) in parallel with the impact foreseen in the development of medications. The potential is immense.

But this raises a critical question: How do we regulate data and ownership? We have been very good at regulating property titles since the Roman empire, but legally we are struggling to grapple with data property and to live with the idea of a cloud-based cross-border society that exchanges data and should be regulated at a global level. Any “local” effort is doomed to fail. Data and data centers travel too quickly.

This is the debate we keep postponing, but it’s central to our future.

Regulation and Legislation

Can legislation keep up with these challenges? The short answer is no.

There’s a huge regulatory gap between the current reality and the legislative process. Laws take too long to develop, and when they finally arrive, they’re already outdated.

Europe is particularly rigid, especially when it comes to the innovation and authorization of novel foods, GMOs, and NGTs. We need to cut red tape, accelerate innovation, and rethink how we regulate.

Mario Draghi said it best at a recent European summit, launching stern warnings to the Member States: “You say no to a common debt, you say no to a common market […] you say no to everything. I don’t know what we have to do now, but do something.” Otherwise, we will fall behind.

The Commission recently announced a €20 billion AI investment plan. But in the U.S., that amount is spent in a week. Again: who pays for this transition? Who funds the shift? How can we fill the gap between the US and China? I think we can’t. We have to decide who is our best ally while we try to find again our role and relevance in the global political community.

We must find smarter, more agile ways to legislate. Not by lowering our standards, but by better integrating science, experts, and stakeholder feedback in the process, privileging soft law instruments when suitable for the scope, and — maybe — even using AI to help identify gaps, analyze the data, and try to advance bolder proposals.

Final Thoughts and Recommendations

Where should businesses focus?

  • Flexibility is key. Don’t rely too heavily on one model, region, product, or supplier. In an era of continuous change, adaptability allows species to survive.
  • Efficiency can be achieved by identifying friction points and using low-cost tech or AI to address them.
  • Sustainability should start with waste reduction and upcycling: not just for producers, but retailers too. We cannot achieve environmental neutrality in one day. Fine, reducing waste and inefficiency saves money, can sometimes generate revenues, and can be marketed as good practice to consumers still looking for more sustainable practices.
  • Soft law and collaboration will be essential in policymaking. Include diverse stakeholders, and don’t rule out using AI here, too.

As for consumers and environmental protection, the short-term outlook isn’t great. I do not see a further and dramatic step forward in such conditions, especially in the EU with our very high standards.

We have to be realistic, we must keep our food systems safe and robust, and do our best despite economic constraints.

The Big Question

How can we address global challenges in an increasingly fragmented world?

The answer is simple and timeless.

From the earliest human history, we’ve formed communities and societies to solve complex problems together. Why did we move from hunter-gatherer groups living in caves to cities, communities, States, and bigger organizations? Because alone, we were not able to address complex challenges.

There’s only one solution to global problems: global cooperation.

If we keep staying divided, we don’t work together, and we isolate ourselves politically, economically, or as a supply chain or a company, we don’t stand a chance.

Maybe it sounds pessimistic. But that’s the end of my speech, for which I thank you.

Here are some video snippets from the talk, straight from our Youtube channel @foodlawyer:

And if you are still skeptical about AI potential, listen to this 100% AI-generated podcast based on my speech, slides, and abstract:

Finally, here are some posts/articles in case you missed them.

The first one is something I am particularly proud of since it is a small testament to the fact that my vision of the modern lawyer as a problem-solving, knowledge-distributor, multidisciplinary independent thinker is often much more valuable than “the old way”:

The EU Commission finally took a decisive stance against national legislation infringing the EU law (in this case “shrinkflation” Italian legislative project)

That’s all for now!

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