Labelling in the New Age

January 1st, 2021 was the deadline for changes to UK products and their labels. We’ve had a year to get in line and hopefully you’re all set to be compliant outside of the EU. You should check with your EU importer how the EU’s labelling requirements will affect your products.

Food of animal origin placed on the EU market before 1 January 2021 can continue to circulate within the EU market without labelling changes. Food of non-animal origin placed on either the UK or EU markets before 1 January 2021 can continue to circulate both in the EU and UK markets without labelling changes.

In the Withdrawal Agreement, a good is ‘placed on the market’ in the EU, when it is first supplied for distribution, consumption, or commercial use, whether free of charge or not. All food placed on the EU market from 1 January 2021 will have to meet EU rules.

As the EU has recognised UK control bodies, you may continue to use the EU organic logo on GB organic food or feed until 31 December 2021. The EU organic logo will be optional. If used, it must meet the EU organic labelling requirements and statement of agricultural origin.

If you use the EU organic logo for exports to the EU, you’ll need to include both the GB statement of agriculture (‘UK or non-UK Agriculture’) and the EU statement of agriculture (‘EU or non-EU Agriculture’). You can continue to use your UK organic control body logo.

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.

Food from GB must not be labelled as ‘origin EU’ from 1 January 2021. Food from NI can continue to use ‘origin EU’. You should label food from NI as ‘UK(NI)’ or ‘United Kingdom (Northern Ireland)’ where EU law requires member state from 1 January 2021.

You must tell the consumer which EU member state or non-EU country the animal was reared in. You must label your product with the statement, ‘reared in: [EU member state or non-EU country]’.

This guidance is subject to agreement with devolved administrations and Parliamentary process. You’ll need to make any required labelling changes for goods sold in GB by 30 September 2022. Local authorities in GB will be responsible for enforcement of labelling changes.

Your label can contain other information if you need to comply with labelling requirements for another market. Under the Northern Ireland Protocol, goods sold in NI will continue to follow EU rules for food labelling. There will be changes to labelling that apply from the end of the transition period. However, the UK Government recognises that businesses will need time to adapt to these new labelling rules.

The UK Government is working with the Department of Agriculture, Environment and Rural Affairs (DAERA) and district councils in NI on an enforcement approach of new labelling requirements on the NI market that takes these challenges into account.