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Food Labelling – an update

Food Label Print publication

11/06/2021

Food business operators (FBO) can continue to use an EU, GB or Northern Ireland (NI) address for the FBO on pre-packed food sold in Great Britain (England, Scotland and Wales) until 30 September 2022.  From 1 October 2022, any pre-packaged food sold in Great Britain requires a UK FBO or UK based importer’s name and address.  In due course, non-UK businesses will need to consider putting in place arrangements with a UK based importer or setting up a UK business to fulfil this function.

From 1 January 2021 it has been the case that all pre-packed food placed on the EU market from the UK must have an EU or NI address for the FBO or an EU or NI importer to ensure compliance with EU Regulation 1169/2011 on food information to consumers (FIC).  In order to ensure compliance, GB food businesses need to have arrangements with an EU based importer (either externally or part of its corporate structure) or set up an EU/NI based entity to carry out this role.

EU Emblem

The EU emblem cannot be used on goods produced in Great Britain without authorisation.

Health and identity marks

Health and identity marks set out the place of origin and approval number of the registered FBO. Government has extended the date for implementation of this change from 1 January 2021 to 30 September 2022 for goods in the GB market. Goods sold in NI and/or the EU have, however, been required to apply the new marks since 1 January 2021.

Country of origin

It is mandatory to label products such as meat, fish, seafood, eggs, honey, etc. with their country of origin where they are sold to the final consumer or mass caterers. Where failing to provide a country of origin may mislead consumers, an FBO must label products with the country of origin. Countries of origin might also be used as a marketing tool (e.g. Made in GB).

Where the country of origin of the primary ingredient differs from the declared/implied country of origin, an FBO must include the country of origin of the primary ingredient of the product (e.g. where one of the ingredients of a “best of British fish” originates from France, an FBO must state where the primary ingredient came from. Since 1 January 2021, food from GB and sold in the EU must not be labelled as ‘origin EU’ unless it is either from or sold in Northern Ireland. Food from and sold in GB can be labelled as ‘origin EU’ until 30 September 2022.

Organics

The UK-EU Trade and Cooperation Agreement provides for an equivalence agreement between the UK and EU, i.e. products certified as organic in one market will be recognised as organic in the other. The EU accepts the placing on the EU market of an agreed list of products that meet UK laws and are accompanied by a certificate of inspection issued by a recognised UK control body, and vice versa. Organic products may bear the EU’s organic logo, any UK organic logo or both logos. If an FBO includes the EU organic logo for GB exports to the EU, it must include the EU statement of agricultural origin (‘EU’ or ‘Non-EU Agriculture’). There is no need for the GB statement of agricultural origin.

For the GB market from 30 September 2022, the following statements of agriculture are mandatory:

  • ‘UK Agriculture’ – where 98% of the ingredients are produced in the UK
  • ‘UK or non-UK Agriculture’ – where the product is produced with ingredients grown in and outside the UK
  • ‘Non-UK Agriculture’ – where 98% of the ingredients are produced outside the UK

Protected geographical food and drink names (GI)

All product registered in the UK must use the rules specified for the new UK GI logos. Businesses have until 1 January 2024 to change the EU GI logo to the new UK logo for products registered under the EU scheme before 1 Jan 2021.

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