Brexit Compliance Changes January 2024

January 2024 brings a new year and, with it, some compliance changes for those placing pre-packaged food products on the GB market.

January 1 – All pre-packaged foods on the UK market require a UK address on the label

As of January 1, new regulations require all pre-packaged foods in Great Britain to include a physical UK address on their label. This address is essential for market surveillance authorities and the public to contact the Food Business Operator (FBO) or importer. It denotes the entity legally responsible for the label’s content within the market. An email, phone number, or website is insufficient; only a physical address is compliant. The new rule allows for both an EU and a UK address on the label, with the UK address being located anywhere within the UK, including Northern Ireland.

Jan 31 – changes to Sanitary and Phytosanitary (SPS) controls

Under the UK’s new Border Target Operating Model (BTOM), Sanitary and Phytosanitary (SPS) controls are being applied to imports from EU and non-EU countries. This is intended to safeguard the UK’s borders and streamline procedures. Midnight on January 31, 2024, marks a key deadline. For businesses, it’s crucial to identify the specific risk category of their products, as the requirements vary depending on the type and associated risk category of each product.

Full Customs Controls: Customs controls were somewhat relaxed during the transition phase, but from January 31, 2024, all goods moving from Ireland to GB ports will be subject to full customs controls. UK import declarations must be pre-lodged. The current 6-month delay on declarations will no longer be available.

• A UK government account is required in order to pre-lodge declarations on the GVMS (Goods Vehicle Movement Service)
• MRNs (Movement Reference Numbers) need to be entered on GVMS which then issues a GMR (Goods Movement Reference)
• Goods may not be permitted to board a ferry without the GMR issued by GVMS system

If goods require IPAFFS pre-notification, this must be complete, as the GVMS requires the IPAFFS notification number. Without this, the GVMS cannot be completed and will not issue the required GMR.

Pre-notification: Pre-notification by the GB importer is required for low-, medium-, and high-risk animal products and for medium- and high-risk plant products moving from Ireland to GB.

If products are moving via a GB landbridge, pre-notification must be made by a GB-based representative.

Export Health Certification: From January 31, 2024, it will be required for medium-risk animal and plant products moving to GB.

Transit Health Certification: required for high- and medium-risk animal products moving across the GB landbridge. Plant products do not require phytosanitary certification.

QUIGs: These requirements do not apply to QUIGs (Qualifying Northern Ireland Goods).

“Not for EU” label causing confusion

Another recent label change requirement is the “Not for EU” label. This new label has been announced as a result of the Windsor Framework, an agreement intended to simplify the process of moving food products from GB to NI. While the Windsor Framework allows for a simplification of the process for food movement from GB to NI, it also raises concerns from the EU that products might ‘leak’ from NI onto the EU market. To mitigate this concern, some products intended for the market in NI and moved under NIRMS (Northern Ireland Retail Movement Scheme) will need to be individually labelled “Not for EU”.

This causes some additional complexity for UK food producers, requiring different labelling for products intended to be shipped to NI versus the domestic GB market. To simplify this process, the UK government has signalled that it intends to roll out “Not for EU” labelling all across the UK and for a wider range of products. Some producers, getting ahead of the requirements, have already started to label products in this way in the UK market, which has caused some confusion for GB consumers. Unaware of the purpose of the labelling, some have taken to social media platforms to express concerns that this food is of a lower standard and is not fit for sale in the EU, while in reality this label is not related to food quality but rather a compliance requirement. “Not for EU” labelling will roll out in three phases from October 2023 to July 2025.

More information:

Bord Bia has taken a proactive approach to these changes through their webinars and newsletters. Their guidance on all things related to Brexit food exports can be found here: https://www.bordbia.ie/industry/trading-with-uk/

For more information on SPS changes, see the DAFM webinar: https://www.youtube.com/watch?v=pxKXldmL7Jw

“Not for EU” compliance label.

Food labelling can be a complex area, with differences in rules for B2B Vs B2C requirements and category-specific rules (dairy, meat, eggs, honey, food supplements, etc.) all having specific requirements). As a supply chain and compliance specialist consultancy, PerformanSC gives you the assurance that you are fully equipped for exporting food products to the UK market in 2024, providing you with comprehensive support for any related queries.