Key takeaways:
- Tougher EU mycotoxin limits mean UK-grown oats could soon fall foul of Brussels’ rulebook, putting oat-based staples like oatcakes at risk.
- While current UK retail products remain safe, raw oat contamination spikes during wet seasons leave growers exposed if the UK aligns with EU standards.
- Bakery and snack makers may face tighter testing, pricier sourcing and greater supply volatility unless clear UK-EU carve-outs or transition measures are secured.
Crumbly, quaint, steeped in nostalgia and now caught in a political storm. The oatcake has become a surprisingly apt metaphor for modern Britain: proudly traditional, quietly under siege and somehow always stuck in the crossfire of the UK’s long, bitter break-up with Europe.
Almost 10 years after the Brexit vote, the fallout is still rumbling on and the latest friction point sits squarely between soggy British fields and the rulebooks of Brussels.
Under tougher European limits on naturally occurring mycotoxins, British oats may soon be deemed too ‘moldy’ for human consumption – a prospect that has turned oat farmers and biscuit makers into unlikely political actors. The root of the issue isn’t visible to the naked eye. Oats grown in damp, coastal climates are prone to fungal infection, most commonly from Fusarium langsethiae, which produces the toxins T-2 and HT-2. There are rarely visible symptoms. A field can look immaculate yet still harbor elevated levels.
And while all cereals carry some level of mycotoxin risk, oats sit at the uncomfortable intersection of structure, timing and climate. As the Starmer government edges toward regulatory realignment with the EU, growers fear the UK could mirror Europe’s stricter thresholds – a change with real teeth. The UK hasn’t yet confirmed if or when it will adopt the EU’s new limits, but officials haven’t ruled it out either, which is why growers and processors say the threat feels uncomfortably real.
On paper, the consumer risk is low. The Food Standards Agency’s 2014 surveillance found that while HT-2 and T-2 were detectable across many oat-based foods, all sat comfortably below the tolerable daily intake. Later reviews reached similar conclusions. But the EU’s position has hardened. Its latest stance – influenced by updated assessments from the European Food Safety Authority – calls for tighter limits still.
In other words: this isn’t about today’s oat safety. It’s about whether tomorrow’s rules could turn a compliant crop into a technical reject with the stroke of a pen.
The toxic truth
Mycotoxins are natural toxins produced by certain fungi under stress conditions. In oats, the main offenders are T-2 and HT-2 – part of the type-A trichothecenes group – which develop most easily when crops experience cooler temperatures, persistent moisture or delayed harvest. If you were designing the perfect fungal theme park, you’d draw a map of a British summer.
The issue has been well documented. Long-running UK monitoring has shown more than 90% of raw oat samples carry detectable T-2 or HT-2, though typically at low levels. Some raw oats, however, have tested in the several-thousand-ppb range, with outliers approaching 10,000 ppb. Scottish researchers have confirmed even organic oats can contain free and conjugated forms of these toxins. A joint Irish-UK study found roughly 16% of unprocessed oat samples exceeded current EU limits but crucially, none of the processed products did.
That distinction matters. De-hulling, milling and thermal processing remove a substantial proportion of these toxins, which is why finished oatcakes, porridge oats and breakfast biscuits consistently test below the tolerable daily intake.
The challenge is that Europe wants to narrow the safety band. EFSA lowered its recommended tolerable daily intake for HT-2 and T-2 in 2017, which shrinks the wiggle room. If limits tighten again – and the UK follows – the compliance landscape shifts dramatically, even if the underlying science is unchanged.
Why UK oats are … oat-of-luck
The UK is particularly exposed and not only because of the rain (though the rain certainly plays its part). Several structural factors push British oats into higher-risk territory:
Climate: Cool, wet and variable conditions are ideal for Fusarium development. Coastal regions are especially vulnerable but monitoring shows toxin spikes across the UK when summers turn humid.
Crop rotation: Oats grown straight after another cereal crop carry significantly higher T-2 and HT-2 loads. But switching to non-cereal breaks often means sacrificing profitability.
Tillage: Reduced tillage – a widely adopted sustainability measure – leaves more crop residue on the surface, which can harbor fungal material. Deep tillage would help but runs counter to environmental commitments.
Harvest timing: Rain delays are directly linked to higher mycotoxin levels. Given Britain’s harvest patterns, predictability is not guaranteed.
These factors aren’t easily undone. A 2015 FSA review found that imposing sweeping mitigation strategies across the supply chain would introduce “a significant economic burden with no perceived benefit” because retail products remained low risk. But that logic collapses once Brussels adjusts the threshold.
Enter politics. Tom Bradshaw, president of the National Farmers Union, has labeled the EU’s updated rules “a significant threat to British cereal growers”. If the UK fully aligns under the reset deal, he warns, a single wet harvest could render swathes of British oats unsellable. Exports would be the first casualty, but domestic processors might also be forced to reject British grain. That’s where porridge, biscuits and the traditional oatcake feel the pinch.
It’s an optic that invites satire – Brussels declaring Britain’s oatcakes too moldy for shelves – but the stakes are real.
What producers should brace for
For bakeries and snack producers, oats are a modern hero ingredient – high-fiber, versatile, clean label-friendly and currently in strong NPD demand. If UK oats suddenly fail to meet tightened limits, manufacturers could face ripple effects across sourcing, formulation, pricing and compliance.
Producers may need to rethink how they manage ingredients altogether. That could mean ramping up raw-material testing to catch variability earlier in the supply chain, tightening supplier agreements around moisture levels, harvest timing and rotation practices and widening their sourcing footprint to include lower-risk geographies. Some manufacturers may even look at blending oats from different origins to achieve a more stable consistency across batches.
Processing remains an advantage. Retail-ready oat products across the UK and Ireland almost universally test below the tolerable daily intake, even when raw grain samples look messy. That gives bakery and snack companies an important talking point: the risk sits in the field, not in the final food.
But it also underlines the need for engagement. If processors don’t speak up during UK-EU alignment talks, they risk inheriting compliance obligations designed for farmers, not manufacturers. Worse still, without carve-outs or transitional arrangements, oat-heavy NPD pipelines could become a regulatory headache.
And then there’s the political theater. If this all sounds faintly reminiscent of the ‘sausage wars’, that’s because it is. During the Northern Ireland Protocol disputes, the EU’s sanitary rules temporarily banned certain chilled British sausages from crossing the Irish Sea. For months, politicians bickered over literal pork products while tabloids framed it as a food-fight for sovereignty. The standoff eventually ended with a negotiated exemption but not before sausages became shorthand for post-Brexit absurdity.
Today, oats could be heading into similarly surreal territory.
What would a mycotoxin clampdown actually mean in practice?
If EU-style limits are imposed, UK bakeries and snack makers may need to:
Plan for higher ingredient volatility: UK-grown oats could fluctuate sharply year-to-year, depending on rainfall.
Budget for increased compliance testing: More frequent mycotoxin screening could become standard practice.
Reassess ‘British-grown’ claims: If domestic supply becomes unreliable, brands relying on provenance messaging may be forced to rethink pack copy.
Reformulate certain SKUs: High-oat products (oatcakes, granola clusters, oat bars) are most vulnerable if supply tightens.
Monitor EU guidance closely: HT-2 and T-2 limits may tighten again within the next review cycle.
Build contingency suppliers: Scandinavian and Baltic oats typically show lower risk but could become pricier if UK demand spikes.
If Brussels lowers its limits and the UK follows, the humble oatcake could become the next unlikely symbol of post-Brexit tension.
For manufacturers and farmers alike, this will be a genuine test of how Britain balances food safety, trade alignment and agricultural livelihoods. And in a political landscape where even sausages once became diplomatic weapons, it’s no surprise the oatcake may now be heading for its own moment in the geopolitical spotlight.
Studies:
Davide Arcella, Petra Gergelova, Matteo Lorenzo Innocenti, Hans Steinkellner. Human and animal dietary exposure to T-2 and HT-2 toxin. EFSA journal. Volume15, Issue8, August 2017, e04972. https://doi.org/10.2903/j.efsa.2017.4972
Meneely J, Greer B, Kolawole O, Elliott C. T-2 and HT-2 Toxins: Toxicity, Occurrence and Analysis: A Review. Toxins (Basel). 2023 Jul 29;15(8):481. https://doi.10.3390/toxins15080481. PMID: 37624238; PMCID: PMC10467144.
De Colli L, De Ruyck K, Abdallah MF, Finnan J, Mullins E, Kildea S, Spink J, Elliott C, Danaher M. Natural Co-Occurrence of Multiple Mycotoxins in Unprocessed Oats Grown in Ireland with Various Production Systems. Toxins (Basel). 2021 Mar 4;13(3):188. https://doi.10.3390/toxins13030188. PMID: 33806558; PMCID: PMC7998419.
