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Last Updated on May 1, 2023 by Thomas Bolwell

Brexit and changes in labelling and manufacturing for UK / NI Companies 2021

How UK/ NI Food and Drink producers, manufacturers, retailers and suppliers must change labels from 1 January 2021.

The UK has left the EU, and the transition period after Brexit comes to an end this year. Below are a set of current updates, clients and customers are advised to check regulating bodies at all times for updates.

 

Exporting to the EU

 

Manufacturers should check with your EU importer how the EU’s labelling requirements will affect your products.

Food of animal origin placed on the EU market before 1 January 2021 can continue to circulate within the EU market without labelling changes.

Food of non-animal origin placed on either the UK or EU markets before 1 January 2021 can continue to circulate both in the EU and UK markets without labelling changes.

In the Withdrawal Agreement, a good is ‘placed on the market’ in the EU, when it is first supplied for distribution, consumption, or commercial use, whether free of charge or not.

All food placed on the EU market from 1 January 2021 will have to meet EU rules.

 

Food business operator (FBO) address

Pre-packaged food or caseins sold in Northern Ireland (NI) must include a NI or EU FBO address from 1 January 2021. If the FBO is not in NI or EU, include the address of your importer, based in NI or the EU.

Pre-packaged food and caseins must have an EU or NI address for the FBO or an address of the EU or NI importer on the packaging or food label.

From 1 October 2022, pre-packaged food or caseins sold in GB must include a UK address for the FBO. If the FBO is not in the UK, include the address of your importer, based in the UK.

EU organic logo

You must not use the EU organics logo from 1 January 2021 unless:

  • your UK control body is authorised by the EU to certify UK goods for export to the EU
  • the UK and the EU agree to recognise each other’s standards (called ‘equivalency’)

Contact your control body (Local list provided by link) to stay up to date.

If the UK does not reach an equivalency deal with the EU, you cannot export organic food to the EU and label it as organic. You can still export the food using non-organic labelling if it meets all other marketing standards and you remove or cover any organic labelling.

Read more about trading and labelling organic food from 1 January 2021.

EU emblem

You must not use the EU emblem on goods produced in Great Britain (England, Scotland and Wales) from 1 January 2021 unless you have been authorised by the EU to do so.

 

EU health and identification marks

Read the Food Standards Agency’s guidance on the new health and identification marks.

 

Country of origin labels

Food from GB must not be labelled as ‘origin EU’ from 1 January 2021.

Food from NI can continue to use ‘origin EU’. You should label food from NI as ‘UK(NI)’ or ‘United Kingdom (Northern Ireland)’ where EU law requires member state from 1 January 2021.

Read more in this link  about country of origin food labelling.

 

Goods sold in Great Britain (GB) and Northern Ireland (NI)

 

This guidance is subject to agreement with devolved administrations and Parliamentary process.

Customer will need to make any required labelling changes for goods sold in GB by 30 September 2022.

Local authorities in GB will be responsible for enforcement of labelling changes.

Your label can contain other information if you need to comply with labelling requirements for another market.

Under the Northern Ireland Protocol, goods sold in NI will continue to follow EU rules for food labelling. There will be changes to labelling that apply from the end of the transition period.

However, the UK Government recognises that businesses will need time to adapt to these new labelling rules.

The UK government is working with the Department of Agriculture, the Environment and Rural Affairs (DAERA) and district councils in NI on an enforcement approach of new labelling requirements on the NI market that takes these challenges into account.

In line with previous rule changes for labelling, there will be a proportionate and risk-based enforcement approach for:

  • identification marks;
  • Food Business Operator (FBO) address requirements
  • ‘UK(NI)’ origin labelling requirements

This approach will be implemented in a way which supports businesses as they adapt to the requirements over time.

 

EU health and identification marks

Read the Food Standards Agency’s guidance on the new health and identification marks.

Food business operator (FBO) address

Pre-packaged food or caseins sold in NI must include a NI or EU FBO address from 1 January 2021. If the FBO is not in NI or EU, include the address of your importer, based in NI or the EU.

You can continue to use an EU, GB or NI address for the FBO on pre-packaged food or caseins sold in GB until 30 September 2022.

From 1 October 2022, pre-packaged food or caseins sold in GB must include a UK address for the FBO. If the FBO is not in the UK, include the address of your importer.

EU organic logo

You must not use the EU organic logo on any UK organic food or feed from 1 January 2021, unless either:

  • your control body is authorised by the EU to certify UK goods for export to the EU
  • the UK and the EU agree to recognise each other’s standards (called equivalency)

Contact your control body to stay up to date.

You can continue to use your approved UK organic control body logo in GB.

In GB, you must change the statement of agriculture to ‘UK agriculture’ or ‘UK and non-UK agriculture’.

Find out more about trading and labelling organic food from 1 January 2021.

 

Country of origin labels

Where EU law does not require an EU member state to be indicated, food from and sold in NI can continue to use ‘origin EU’ or ‘origin UK’.

You should label food from and sold in NI as ‘UK(NI)’ or ‘United Kingdom (Northern Ireland)’ where EU law requires member state from 1 January 2021.

You may label food from NI and sold in GB as ‘UK(NI)’, ‘United Kingdom (Northern Ireland)’ or ‘UK’.

Food from and sold in GB can be labelled as ‘origin EU’ until 30 September 2022.

From 1 October 2022, food from GB must not be labelled as ‘origin EU’.

Read more about country of origin food labelling.

Need to talk to us about labels for food or drink products? Contact sales@labelcraft.com to speak to one of our friendly team.

 

 

 

 

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