Food Safety Governance and Guardianship: The Role of the Private Sector in Addressing the EU Ethylene Oxide Incident

Sesame seeds within the European Union (EU) are classified as foods not of animal origin. Two food safety issues associated with sesame seeds have emerged in recent years, i.e., Salmonella contamination and the presence of ethylene oxide. Fumigation with ethylene oxide to reduce Salmonella in seeds and spices is not approved in the EU, so its presence in sesame seeds from India was a sentinel incident sparking multiple trans-European product recalls between 2020–2021. Following an interpretivist approach, this study utilises academic and grey sources including data from the EU Rapid Alert System for Food and Feed (RASFF) database to inform a critical appraisal of current EU foods not of animal origin legislation and associated governance structures and surveillance programs. This is of particular importance as consumers are encouraged towards plant-based diets. This study shows the importance of collaborative governance utilizing data from company testing and audits as well as official regulatory controls to define the depth and breadth of a given incident in Europe. The development of reflexive governance supported by the newest technology (e.g., blockchain) might be of value in public–private models of food safety governance. This study contributes to the literature on the adoption of risk-based food safety regulation and the associated hybrid public–private models of food safety governance where both regulators and private organizations play a vital role in assuring public health.