Kuwait’s Food Import Control System Lacks Risk-Based Prevention

A comprehensive assessment of Kuwait’s food import control system reveals a significant gap between its robust legal infrastructure and its operational reliance on enforcement rather than preventive risk management. Published in the journal Food Safety and Risk, the study evaluates the country’s framework against the Food and Agriculture Organization and World Health Organization Risk-Based Imported Food Control Manual from 2015. The research indicates that while Kuwait has established strong legislative and administrative foundations, critical loopholes remain in risk-based food classification, pre-border responses, and inter-agency coordination. This descriptive qualitative study provides the first complete testing of the FAO/WHO model in a Gulf state, offering a detailed map of where the system succeeds and where it falls short in protecting public health in a nation that imports more than 90% of its food consumption.

The study was conducted by researchers Noof N Al-Daihani, Dina S AlKandari, and Sharifa H AlKandari to address the specific challenges facing Kuwait, one of the least agricultural countries in the world. With less than 9% of its land deemed arable and a hyper-arid climate, Kuwait relies heavily on international food sources to satisfy its dietary requirements. The population has more than doubled over the past two decades, rising from approximately 2.04 million in 2000 to 4.27 million in 2020, which intensifies the pressure on the food supply chain. In this context, the regulation of food safety is not merely a matter of public health but a cornerstone of national food security, requiring a system that can efficiently manage the high volume of imported goods while ensuring they meet strict safety standards.

To evaluate the system, the researchers employed a qualitative descriptive methodology guided by the FAO/WHO checklist. The assessment focused on three fundamental elements: the imported food control procedures, the legal and institutional framework, and the supporting services and infrastructure. The study incorporated a documentary analysis of relevant legislation, including Law No. 112/2013 and Ministerial Resolutions from 2017, alongside semi-structured interviews with 15 key officials from the Public Authority for Food and Nutrition (PAFN). These informants included four senior regulators, five food safety technical officers, and six field inspectors, providing a stratified sample that captured perspectives from strategic oversight to frontline border enforcement. The interviews were conducted between August and November 2022 in Arabic, ensuring that the data reflected the practical realities of the regulatory environment.

The quantitative analysis involved grading the checklist responses on a scale, with the average ratings of the informants used to calculate percentage compliance scores. This mixed-methods approach allowed the researchers to contextualize the numerical compliance estimates with rich qualitative data from the interviews and official documents. The results revealed a paradoxical situation: while the country has made significant strides in legal framework and administrative infrastructure, the system has not fully transitioned to a preventive, risk-based control model. The average compliance across the three evaluated domains stood at 68% based on documentary analysis and 62% based on aggregated informant ratings. This discrepancy highlights that while the structural factors are fairly developed, the operational integration and risk orientation remain underdeveloped, creating a bottleneck in the effective implementation of food safety regulations.

One of the most significant gaps identified in the study is the absence of formal risk-based categorization for imported foods. The findings show that risk-based classification has the greatest gap in implementation, with 40% of criteria not applied and 60% fully applied, leaving no room for partial categorization. Interviews corroborated that risk profiling is not systematically entrenched, with field inspectors and technical officers resorting to fixed, traditional sampling plans rather than evidence-based risk profiles. This reliance on legacy procedures means that the system spends equal amounts of inspection resources regardless of the hazard level or likelihood of non-compliance. Such an approach compromises both efficiency and the protection of public health, as it fails to prioritize high-risk commodities or origins, which is essential for creating efficient and proportional controls in a high-import environment.

Furthermore, the study found that pre-border controls are completely absent from Kuwait’s current system, with 0% application in both documentary and informant measures. There are no systematic methods for engaging with the competent authorities of exporting countries, nor are there equivalence evaluations or advanced certifications for high-risk origins. This reactive stance pushes all risk mitigation to the border or post-border phase, placing unsustainable strain on port inspectors and increasing the likelihood that non-compliant consignments enter the marketplace. Modern import systems typically require upstream preventive measures based on commodity and country-of-origin risk profiles, but Kuwait’s current approach contrasts sharply with these international best practices. The lack of pre-border verification or equivalence agreements with exporting nations represents a total absence of upstream preventive verification, limiting the system’s ability to prevent hazards before they reach the country.

Institutional fragmentation also emerged as a critical challenge, exacerbating the technical gaps in the food control system. Although the legal framework clearly outlines the mandate of the PAFN, informants rated inter-agency coordination at only 64%, particularly regarding the division of responsibilities between the PAFN and Customs. Senior managers noted continuous overlaps and communication breakdowns between these two key entities, leading to regulatory confusion and a disconnect between policy and practice. This lack of horizontal coherence hinders the efficient transformation of legal rules into coherent and coordinated enforcement. The study suggests that enhancing institutional coherence through formal inter-agency procedures, joint risk-intelligence operating systems, and performance checks is crucial for the legal provisions to achieve their intended preventive and protective effects in a high-volume import system.

The support services and enabling infrastructure present a mixed picture, with strong physical foundations but significant resource constraints. Infrastructural elements such as laboratories, office locations, transport, and legal support scored over 80% in both documentary and informant tests, indicating a solid operational base. However, financial and human resource capabilities were significantly lower, with financial resources at 35% and human resources at 40% full application. Informants at all levels reported chronic under-staffing, high turnover, and a lack of specialized training, which directly limits the operationalization of risk-based principles. The uneven access to analytical laboratory services, with 29% of ratings indicating no use, further suggests inconsistencies in field-level performance. These resource constraints pose a direct limitation to the system’s ability to implement a genuinely preventive, risk-based approach, as sustainable food control requires not just regulation but proper budgeting, staffing, and continuous professional development.

The study highlights the necessity of specific reforms to enhance preventive, risk-based control and align Kuwait’s food import system with international standards. The researchers propose the development of a Codex-compliant risk classification matrix that is updated annually based on border inspection results and international warnings. They also recommend establishing a shared PAFN-Customs risk intelligence team to create and maintain importer and country risk profiles. Additionally, the study suggests negotiating bilateral equivalence agreements with major exporting nations for high-risk categories such as meat, dairy, and seafood, which would allow for recognition before the border and reduced border intensity. These measures aim to shift the system from a reactive compliance model to a proactive resilience strategy, ensuring long-term food security in a rapidly globalized market.

Despite the detailed findings, the study has certain limitations that must be considered when interpreting the results. The assessment is based on documentary analysis and expert determination rather than direct outcome measures such as rejection rates or import-related outbreak data. The purposive sample of 15 PAFN informants, while experienced, does not statistically represent all stakeholders in the food import chain. Furthermore, the checklist method evaluates compliance with global best practices rather than the practical utility or effectiveness of the system in real-world scenarios. Future research should include longitudinal performance measures, compliance data used by importers, and quantitative risk modeling to help validate and generalize these findings. By addressing these gaps, Kuwait can strengthen its food safety governance, protect public health, and minimize trade interruptions, ultimately becoming a significant player in regional food safety governance.

Subject of Research: Assessment of Kuwait's risk-based food import control system using the FAO/WHO manual

Article Title: Evaluating the framework, legal structures, and support functions of Kuwait’s risk-based food import control system

Article References: Al-Daihani, N. N., AlKandari, D. S., & AlKandari, S. H. (2026). Evaluating the framework, legal structures, and support functions of Kuwait’s risk-based food import control system. Food Safety and Risk, 13(1), Article 15. https://doi.org/10.1186/s40550-026-00140-6

Image Credits: AI Generated

DOI: 10.1186/s40550-026-00140-6

Keywords: food safety, Kuwait, import control, risk-based regulation, public health, food security, FAO/WHO, institutional capacity, border inspection, policy coherence, Evaluating, framework