Brexit Labelling Updates – What labelling changes must EU and UK food businesses consider since Brexit?
At Label Craft Ireland we keep our customers up to date with changes in legislation and guidance on labelling changes.
- Food Business Operator (FBO) Address
Currently, it is mandatory to provide an address of the responsible FBO on pre-packaged product labels; the FBO needs to be established in the EU (as per regulation (EU) No 1169/2011). As the UK is no longer be part of the EU, a UK address will no longer be suitable for UK origin products being sold in EU member states. Likewise, an EU address will not be applicable for EU origin products for sale in the UK market.
The label of pre-packaged foods must include an address for the FBO in the intended market. If the UK based FBO is not established in the EU, the name and address of the EU importer must be indicated and vice versa. This is the main labelling change that affects all food businesses exporting goods to the EU or UK. It is also a change which has sparked many questions within the industry around the acceptability of addresses.
Place of sale: GB = Requires address of a UK (including NI) established FBO/distributor(s)
Place of sale: EU or NI = Requires address of an EU or NI established FBO/distributor(s)
- For goods sold in Great Britain (GB – England, Wales, Scotland), an EU, GB or NI address may continue to be used until 30 September 2022; From 1 October 2022, a UK address must be used.
- For goods sold in the EU, an EU address is required on pack since 1 January 2021.
- EU Organic Logo
Unless there is an equivalency agreement (recognising each other’s standards), since 1 January 2021 organic food or feed may not be sold in the EU labelled as organic. The EU organics logo cannot be used on label for products produced in GB; NI can continue to use the logo for the products they sell into the EU market. In contrast, all EU organic food and feed products will continue to be accepted into the GB market.
For products produced and sold in GB, since Brexit you can continue to use your approved UK control body logo; you must change the statement of agriculture to ‘UK agriculture’ or ‘UK and non-UK agriculture’.
For continued market access, Label Craft recommend speaking to your UK control body to identify if they are authorised by the EU to certify UK organic produce for export to the EU market after 31 Dec 2020.
Place of sale: UK = Remove EU organics logo, use existing UK control bodies logo, change statement to ‘UK agriculture’ or ‘non-UK agriculture’.
Place of sale: EU = GB producers cannot currently sell products marketed as organic into the EU. NI producers can continue to sell into the EU market using the EU organics logo.
- EU Health and Identification Marks
From 1 Jan 2021 (and not before), the current ‘EC’ health and identification marks will be replaced for UK products of animal origin (POAO). Products placed on the market prior to the end of transition can remain on the market it was placed post-transition; If a product is placed on the GB market before transition end with current marks, it must reach an end-consumer within the UK market; it cannot be moved to the EU market after transition unless it is relabelled accordingly. If placed on the NI market it can reach the end consumer in either the UK or EU markets.
A period of adjustment until September 30, 2022 is available to UK food businesses for POAO placed on the market in Great Britain. It is not applicable to POAO produced in Great Britain and Northern Ireland for placing on the EU or non-EU markets. For these markets’ products placed after 1 January 2021 will require re-labelling.
New UK health identification marks have been issued and incorporate ‘GB’ and in some cases ‘UK’ in place of the ‘EC’. The Food Standards Agency have issued guidance on the use of the new logos.
- Country of Origin Labelling (CoOL)
From 1 Jan 2021 food produced in GB and sold in the EU must not be labelled as ‘EU origin’. Food produced and sold in NI can continue to use ‘origin EU’.
Food produced and sold in GB can continue to be labelled with ‘EU origin’ until 30 September 2022. After this date the label must change to reflect GB origin.
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