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The impact of Brexit on food labelling

27th August 2019

Martin Hyde

When the UK leaves the EU on the 31 October 2019, UK businesses will need to make amendments to labelling of food products to reflect the fact that the UK will no longer be classified as part of the EU. This will impact imported, exported and UK sourced food products.

DEFRA have released specific guidance on food labelling which can be found below, as well as directing businesses to the EU’s Food Law Guidance.

https://www.gov.uk/guidance/food-labelling-changes-after-brexit

https://ec.europa.eu/info/sites/info/files/eu_food_law_en.pdf

Timeline

Although these changes will need to be actioned as soon as possible after Brexit, DEFRA have confirmed that “The UK government will have a 21-month transition period where possible for labelling changes for goods produced, imported or placed on the UK market after exit day”. However, some changes will need to take place immediately after “Exit Day” on 31 October 2019.

Immediate changes

The below changes will need to have been made by businesses exporting food to the EU from exit day.

  • Food Business Operator (FBO) Address: Pre-packaged food exported to the EU from the UK must include an EU address for the FBO
  • EU Organic Logo: The EU Organic Logo cannot be used on ANY UK organic food (or feed) after exit day unless the EU recognises the UK control body from which you have received certification as fit for the EU market. If no equivalency deal is met with the EU, UK sourced organic food or feed CANNOT be exported to the EU.

  • EU Emblem: The EU Emblem cannot be used on any goods produced in the UK without authorisation from the EU.

  • EU Health and Identification Marks: For products of animal origin (POAO) exported from the UK to the EU, the current EU oval mark must be replaced with the new UK health mark as below:

  • Country of origin label: After exit day, UK food should not be labelled with an origin of “EU”. This is especially relevant from April 2020, after which the country / place of origin of the primary ingredient of a food must be stated on labels.

Long-term changes

There are additional changes which are relevant if you are producing or placing goods on the UK market following Brexit. A 21-month transition period has been confirmed by DEFRA which would be expected to end around July 2021.

The EU health and identification marks may continue to be used during the transitional period; however, all businesses will eventually have to move to the new UK system.

FBO address will need to be a UK address for all products placed on the UK market; DEFRA have advised using the importer’s address where the FBO is not in the UK.

Country of origin

Following the EU exit, food can continue to be labelled with its specific country of origin but MUST NOT be labelled as EU origin unless it is from an EU member state. Food with a UK origin must not be labelled as EU origin.

Mixed product origin

Where a product has mixed origin such as minced meat, made with UK and EU meat, the product should be labelled as “a mix of UK and non-UK origin”. The same would apply for fruit, vegetables, blended honey and oils.

Beef and veal born, reared or slaughtered outside of the UK must state its origin as “Non-UK”.

Eggs from non-EU countries which do not meet UK egg trade standards should be marked as “Non-UK standard”; previously this would be marked as “Non-EC standard”.

Geographical indication (GI)

Products produced under geographic indication protection must be labelled with a UK GI label. DEFRA have confirmed that the UK will set up its own GI labelling system in the case of a no deal Brexit.

Should you have any labelling queries please do not hesitate to get in touch and we will be happy to advise – packaging@complydirect.com