Brexit Means Food Labelling Regulations In The UK And Across Europe Are Going To Change Very Soon...
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One thing we know for certain is that whatever version of an agreement is reached, be it no deal or a deal, Brexit will happen on 31st December 2020 at 11pm.
The outbreak of Covid-19
Has majorly disrupted much of the world, and the Brexit negotiations were no different. Negotiations resumed on 28 September, but many key issues remain to be resolved.
For Consumer Packaged Goods (CPG) and Food & Beverage businesses, a swathe of changes will come into effect from 1st Jan 2021. Be it country of origin, use of EU logos, or specifications regarding operator’s name and address, one thing is for certain – the time to act is now.
This year has understandably diverted many businesses attention to business critical Covid responses. The industry has had to adapt and so for some organisations, they may now find themselves better equipped to face disruption events.
Challenges for producers
So, what are the key challenges facing businesses wanting to comply with post-Brexit labelling standards?
The very short timescales for change will be a major concern for many organisations. Manufacturers and producers will need to consider existing stock levels, and particularly should seek to determine when those stocks can be placed ‘on the market’ before the end of transition to understand when relabelling will be required.
The lack of clarity on border checks also throws more uncertainty into the mix for manufacturers.
It’s hard to say if any other substantive changes will come into effect, noting the current climate around Covid-19 and the other priorities of the government in the coming months and years.
Health habits which can increase the risk of Coronavirus, such as consumption of high-sugar foods leading to obesity, are garnering more scrutiny. The latest report from the government shows mixed results and marginal progress which could mean an intensified effort or even further regulation.
Exporting in 2021
The process of exporting goods to the EU will be changing. All business looking to export goods from Great Britain to the EU need to complete a set of actions prior to 1st January 2020.
Guidance on moving goods into, out of and through Northern Ireland will be added to the government website (GOV.UK) in the coming weeks. But, for all the most up to date information on what your organisation needs to prepare after Brexit follow this link for a checklist of actions.
Key changes: Getting Brexit right
Firstly, all manufacturers should check with their EU importer how the EU’s labelling requirements will affect your product.
For goods sold within the UK, the guidance is subject to agreement within Parliament therefore making local authorities in within the UK responsible for enforcing labelling changes.
For example, food of animal origin and food of non-animal origin placed on the EU market before 1 January 2021 can continue to circulate within the EU market without labelling changes. All food placed on the EU market after this date must meet EU rules.
Below are the key areas for consideration on labelling changes when exporting to the EU and being sold in Great Britain and Northern Ireland, as described by the UK Government:
Food business operator (FBO) address
EU: Pre-packaged food and caseins must have an EU or Northern Ireland (NI) address for the FBO, or an address of the EU or NI importer on the packaging or food label.
GB & NI: Producers 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
EU / GB & NI: 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’)
Country of origin labels
Food from NI can continue to use ‘origin EU’.
Food from GB must not be labelled as origin ‘EU’ from 1 January 2021.
Read more about country of origin food labelling.
GB & NI:
Food from and sold in NI can continue to use ‘origin EU’ from 1 January 2021.
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’.
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.
New opportunities post Brexit
“When one door closes, another opens” – isn’t that the phrase?
For businesses with the appetite and sufficient resources, seeking other overseas markets is now more realistic than before. Exporting to markets outside the EU is being actively encouraged by the UK government.
The Department for International Trade (DIT) Exporting is GREAT campaign aims to spark a movement around the UK of companies selling their products and services overseas.
The recent news of the UK and Japan free trade agreement in September serves as a reminder that a number of buoyant markets remain virtually untapped to UK producers. UK businesses will benefit from tariff-free trade on 99% of exports to Japan.
From the agreement UK manufacturers, food and drink producers and the tech sector are all set to benefit from the measures in the UK-Japan deal:
New protection for more iconic UK goods including English sparkling wine, Yorkshire Wensleydale and Welsh lamb. This would lead to improved recognition of key UK brands in the Japanese market.
Strong tariff reductions for UK pork, beef, salmon and a range of other agricultural exports. UK producers will continue to benefit from access to the low tariffs for key food and drink products covered by quotas, such as Stilton cheese, tea extracts and bread mixes.