Risk management confidence in the food, beverage and agriculture sector has fallen 27 percentage points in two years - from 89% of respondents feeling somewhat or completely in control of their risks in 2023, to 75% in 2024, to 62% in 2026. Willis, a WTW business, published the Global Food, Beverage and Agriculture Risk Report 2026 on July 9, drawing on responses from 450 senior risk decision-makers at leading food and beverage companies worldwide, surveyed in February and March 2026. The decline is not evenly distributed across risk categories - and its sharpest driver is a litigation trajectory that existing product liability wordings were not designed to address.
Food safety and health ranked as a top risk for 45% of respondents, up from 29% in 2024. The regulatory and litigation environment driving that anxiety has evolved materially. A December 2025 lawsuit filed by the San Francisco City Attorney against major food manufacturers marks a structural departure from earlier approaches to ultra-processed food litigation. Rather than proving direct causation between specific products and diseases - the standard around which product liability policies are structured - it draws on unfair competition claims and public nuisance theories developed in tobacco and opioid litigation. The removal of the individual causation requirement is the commercially significant shift: product liability wordings designed around demonstrable individual harm may not respond as expected to public cost recovery theories that bypass that requirement entirely.
Reinsurers have taken note. Swiss Re's sigma insights 05/2026, published in March 2026, describes ultra-processed foods as a potential long-tail liability risk with characteristics like other sectors where liability costs expanded materially over time, warning that a successful case in one jurisdiction could encourage follow-on litigation across multiple markets. For underwriters pricing product liability and recall coverage in the food and beverage sector, the San Francisco case is not a local curiosity - it is a potential template.
Regulatory action is accelerating alongside litigation. The US Food and Drug Administration is preparing a formal definition of ultra-processed foods encompassing additives, emulsifiers and preservatives. US Health and Human Services Secretary Robert F. Kennedy Jr. said in June 2026 that the proposed definition was under White House review and expected to be published within months. A formal regulatory definition would give future plaintiffs a cleaner basis for establishing which products fall within the contested category - tightening the connection between regulatory classification and litigation exposure.
Supply chain risk was cited as a concern by 44% of respondents, up from 40% in 2024, with geopolitical instability, trade tensions and disruption risks as the primary drivers. Some 83% of firms now report having formal business continuity plans, up from 78%. An Oxford Analytica and Willis client survey found 61% of respondents identified rising trade barriers as the geopolitical trend most challenging to manage - a figure that maps directly onto business interruption and contingent business interruption exposures for food sector clients with cross-border supply dependencies.
Simon Lusher, Willis' global food, beverage and agriculture leader, said the pace of change was at the heart of the confidence decline. "Food and beverage companies around the world are navigating a risk landscape that is becoming more complex and less predictable by the year," he said. "Our latest survey shows that many leaders feel less in control of these risks, reflecting how quickly the environment is evolving."
Despite regulatory headwinds in some jurisdictions, ESG risk management remains a stated priority for 84% of respondents over the next two years. The finding is notable for its resilience: physical climate risk - not regulatory mandate - appears to be driving sector leaders' focus, with growers and producers beginning to feel the direct operational impact of increasing droughts, floods, water stress and land degradation. A sector that is simultaneously managing food safety litigation risk, supply chain disruption and physical climate exposure is one where the convergence of those pressures, rather than any single risk in isolation, is what the confidence data is measuring.
