As part of the Brexit transition, food producers were given an extended transition period to adapt food labelling to new UK standards. Companies will need to make any required labelling changes for goods sold in Great Britain by 30 September 2022.
Under the Northern Ireland Protocol, goods sold in NI will continue to follow EU rules for food labelling.
A key change includes a requirement to include the address of a UK-based food business operator (FBO) on the packaging for all pre-packaged foods and caseins placed on the GB market. The food business operator is registered with the local authorities in the UK, is responsible for the food information on the label, and is the primary contact point for market surveillance authorities.
For companies selling into food service or into other businesses, there is a requirement to provide information to enable whoever is selling to the final consumer to have all the information to meet the requirements.
The FBO shall be the operator under whose name or business name the food is marketed or if that operator is not established in the market, the importer into the market.
In practical terms, companies selling directly into retail or food service companies may find that their customers will not want to take on this compliance responsibility. This leaves them with the option to use their own entity in the UK where available or to appoint an importer or an authorised representative in the market to assume these responsibilities.
There are changes to origin labelling which vary by product – for details check out this link for the latest guidance – https://www.gov.uk/guidance/food-labelling-country-of-origin. In many cases, the changes remove generic references to EU or Non-EU product origin and there are some changes to regional health stamps.
Brexit has presented many deadlines in recent years and companies are already suffering from deadline fatigue. While SPS and other checks into the UK market have been postponed several times, there is an expectation that these new labelling requirements will come into force as planned from 1st October 2022.
With the lead times for amendments to packaging and the potential need to establish and register a new FBO, the time to act on these requirements is now.
On 15th June 2022, we participated in a webinar with An Bord Bia and this will provide additional background and context for the changes. That webinar can be accessed here and guidance on the new food labelling requirements is also available here – https://www.gov.uk/guidance/food-labelling-giving-food-information-to-consumers
Feel free to contact us if you have additional queries.
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