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Your Guide to Conforming to Labeling Updates post-Brexit


December 18, 2020

Your Guide to Conforming to Labeling Updates post-Brexit

These are the changes to be made on your packaging artworks

“Label redesign is not as simple as ‘add this delete that’, there are many compliance checks to be made before sending to print.”

– Pete Martin, Regulatory Affairs Director at Ashbury

UK and EU food makers would want all the clarity on the labeling regulations to goods imported to each other’s countries. Here’s what we think will help:

Check out the revised guidelines on the basis of:

  1. Your place of market
  2. Your address
  3. EU Organic Logo
  4. EU Health & Identification marks
  5. COOL (Country of Origin Labelling)
  6. EU emblem
  7. Geographical Indication and finally our take

 

YOUR PLACE OF MARKET

IF

THEN

BUT

You’re a UK-based FBO and;

You’re reading this on or before 31st Dec 2020 and;

You’ve already shipped your products to the EU with the old labelling

You can sell them until the current stock is exhausted

 

you can’t place any new stock on this market post 1st Jan 2021
You’re a UK-based FBO placing your products within UK You can continue selling them with the old labelling until the end of the transition period i.e. 30th,Sept 2022
You’re a Northern Ireland (NI)-based FBO You can continue placing your goods in the EU market and follow EU rules There will be changes that apply to labeling post the Transition period i.e. 30th,Sept 2022
YOUR ADDRESS
IF THEN BUT
You are a UK-based FBO and;

You are going to place new products on or after 1st Jan, 2021 for sale in the EU

You can’t display your UK address under address of the FBO You can indicate your EU importer’s address

 

(Which means if several companies are importing your product, you’ll have to mention each of their respective names & address on the respective products)

 

You are a UK-based FBO placing your goods within UK You can display your UK address under address of the FBO
You are an EU-based FBO placing your goods in the UK You can’t display your EU address under address of the FBO You can indicate your UK importer’s address
You are an NI-based FBO You can display your FBO address as/is This can only continue till the end of the transition period i.e. 30th Sept, 2022 subject to NI protocol

 EU ORGANIC LOGO & OTHER LOGOS & STATEMENTS

IF THEN BUT
You’re a UK-based FBO and;

You are going to place new products on or after 1st Jan, 2021 for sale in the EU

You can’t use the EU organics logo to sell in the EU market (See fig below)
You are a UK-based FBO placing your goods within UK You can continue to use your approved UK control body logo You must change the statement of agriculture from ‘EU agriculture’ to ‘UK agriculture’ or ‘UK and non-UK agriculture’

(See fig above)

You’re an NI-based FBO You can continue to use the EU organics logo to sell to the EU market
You’re an EU-based FBO You can continue to sell in the UK markets with the EU organic logo

 EU HEALTH & IDENTIFICATION MARKS

IF THEN BUT
You are a UK-based FBO and;

You are going to place new products on or after 1st Jan, 2021 for sale in the EU

You can’t use the current ‘EC’ health and identification marks But products with the current logos shipped and placed on the market before 1st Jan, 2021 can continue to be sold till they are exhausted
You are a UK-based FBO placing your goods within the UK You can continue selling them with the current  health and identification marks until the end of the transition period i.e. 30th,Sept 2022
You’re an NI-based FBO You can continue to use your current health and identification marks to sell to the EU market
COUNTRY OF ORIGIN LABELLING (COOL)
IF THEN BUT
You’re a UK-based FBO and;

You are going to place new products on or after 1st Jan, 2021 for sale in the EU

You can’t label your products – ‘EU origin’ It must be changed to ‘non-EU origin’ instead
You’re a UK-based FBO placing your goods within the UK You can continue selling them with the current  ‘EU Origin’ label until the end of the transition period i.e. 30th,Sept 2022  
You’re an NI-based FBO You can continue to use the current  ‘EU Origin’ label to sell to the EU market  
COOL FOR DIFFERENT FOOD CATEGORIES SOLD WITHIN GB AND NI
CATEGORY UNTIL 30TH SEPT, 2022 POST 1ST OCT, 2022
MINCED MEAT GB

Continue to use EU and non-EU label until the end of the transition period i.e. 30th Sept, 2022

NI

Continue to use EU and non-EU label

GB

It must be changed to UK and non-UK

 

FRUITS & VEGETABLES GB

Continue to use a mix of EU and non-EU origin’

 

NI

Continue to use EU and non-EU label

GB

Changes to ‘a mix of UK and non-UK origin’

OLIVE OIL GB and NI

 

Continue to use EU and non-EU label

 

 

GB

 

The label must contain one of the following:

Each country of origin must be listed on the label

The statement ‘blend of olive oils from more than one country’ (or similar wording)

The name of the trading bloc to which a regional trade agreement applies, for example ‘blend of olive oils of European Union origin’

 

NI

Continue to use EU and non-EU label when no country of origin list is provided.

 

HONEY GB and NI:

 

From 1st Jan 2021: If you are not labelling with a list of origins and choose alternative wording, this statement must reflect the GB is no longer a part of the EU.

For a honey blend from EU member states = ‘Blend of EU honeys’

For a blend from countries outside the EU such as GB = ‘Blend of non-EU honeys’

For a blend from EU member states and non-EU member States such as GB = ‘Blend of EU and non-EU honeys

 

GB and NI:

 

You must use ‘blend of honeys from more than one country’ (or similar wording) if you decide not to list each country of origin.

BEEF AND VEAL GB and NI

Until 30th Sept, 2022: you can continue to use origin ‘non-EU’

 

 

GB

If the animal that beef or veal came from was born, reared or slaughtered outside of the UK, the label must state ‘Origin: non-UK

 

‘Live import into the EC’ must be replaced with ‘beef from a live import into the UK’ where the country of origin of the animal is not known.

 

NI

Continue to refer to ‘origin non-EU’ if the full individual country information is not available

 

 

EGGS GB and NI:

 

Eggs that do not meet EU egg trade regulations must be labelled as ‘Non-EC standard’.

GB:

 

Eggs that do not meet UK domestic egg trade regulations must be re-labelled as ‘Non-UK standard’

 

NI

Eggs that do not meet EU egg trade regulations must be labelled as ‘Non-EC standard’.

 

 

EU EMBLEM
IF THEN BUT
You are a UK-based FBO and;

You’re  placing your goods in EU and/or

You’re placing your goods within GB

You can’t use the EU emblem unless you’ve been authorised by EU to do so
GEOGRAPHICAL INDICATION LOGOS (except wines & spirits)
Ashbury’s guidance document could’nt have explained this better:

Place of sale: GB    =    Requires UK GI registration and logo; optional EU registration and use of logo (if protected in the EU).

Place of sale: EU    =    Requires EU GI registration and logo.

Place of sale: NI    =   Requires EU GI registration and logo, optional use of UK registration and logo.

Existing UK (including NI) products = Remain protected under current EU law and new UK law.

New GB produced products = Registration must be secured in the UK first, before registration under EU law.

New NI produced products = Do not have to secure EU registration before UK registration for sale in GB

Producers or retailers of GB food, drink and agricultural GI products registered before 1 January 2021, will have until 1 January 2024 to change packaging and marketing materials to display the new UK GI logos.

The UK logo will be mandatory for GB products registered from 1 January 2021 onwards.

 

The future holds more changes made in labelling legislations by the UK government. We think the most challenging aspect for UK exporters to the EU and vice versa lie in removing their FBO address and including their importer’s addresses. Significant work can also be seen in terms of harmonizing logos, symbols and statements across relevant SKUs.

Keeping track of these revised rules can be overwhelming. What will help is an automated packaging artwork management system – that includes a handy checklist to ensure compliance, proofing tools to validate your artworks and a workflow that helps you launch faster while pushing out artworks right-first-time.

Contact our team to know how.

References:

https://www.gov.uk/guidance/food-and-drink-labelling-changes-from-1-january-2021

https://ashbury.global/how-to-prepare-your-labels-for-brexit/

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Your Guide to Conforming to Labeling Updates post-Brexit

These are the changes to be made on your packaging artworks

“Label redesign is not as simple as ‘add this delete that’, there are many compliance checks to be made before sending to print.”

– Pete Martin, Regulatory Affairs Director at Ashbury

UK and EU food makers would want all the clarity on the labeling regulations to goods imported to each other’s countries. Here’s what we think will help:

Check out the revised guidelines on the basis of:

  1. Your place of market
  2. Your address
  3. EU Organic Logo
  4. EU Health & Identification marks
  5. COOL (Country of Origin Labelling)
  6. EU emblem
  7. Geographical Indication and finally our take

 

YOUR PLACE OF MARKET

IF

THEN

BUT

You’re a UK-based FBO and;

You’re reading this on or before 31st Dec 2020 and;

You’ve already shipped your products to the EU with the old labelling

You can sell them until the current stock is exhausted

 

you can’t place any new stock on this market post 1st Jan 2021
You’re a UK-based FBO placing your products within UK You can continue selling them with the old labelling until the end of the transition period i.e. 30th,Sept 2022
You’re a Northern Ireland (NI)-based FBO You can continue placing your goods in the EU market and follow EU rules There will be changes that apply to labeling post the Transition period i.e. 30th,Sept 2022
YOUR ADDRESS
IF THEN BUT
You are a UK-based FBO and;

You are going to place new products on or after 1st Jan, 2021 for sale in the EU

You can’t display your UK address under address of the FBO You can indicate your EU importer’s address

 

(Which means if several companies are importing your product, you’ll have to mention each of their respective names & address on the respective products)

 

You are a UK-based FBO placing your goods within UK You can display your UK address under address of the FBO
You are an EU-based FBO placing your goods in the UK You can’t display your EU address under address of the FBO You can indicate your UK importer’s address
You are an NI-based FBO You can display your FBO address as/is This can only continue till the end of the transition period i.e. 30th Sept, 2022 subject to NI protocol

 EU ORGANIC LOGO & OTHER LOGOS & STATEMENTS

IF THEN BUT
You’re a UK-based FBO and;

You are going to place new products on or after 1st Jan, 2021 for sale in the EU

You can’t use the EU organics logo to sell in the EU market (See fig below)
You are a UK-based FBO placing your goods within UK You can continue to use your approved UK control body logo You must change the statement of agriculture from ‘EU agriculture’ to ‘UK agriculture’ or ‘UK and non-UK agriculture’

(See fig above)

You’re an NI-based FBO You can continue to use the EU organics logo to sell to the EU market
You’re an EU-based FBO You can continue to sell in the UK markets with the EU organic logo

 EU HEALTH & IDENTIFICATION MARKS

IF THEN BUT
You are a UK-based FBO and;

You are going to place new products on or after 1st Jan, 2021 for sale in the EU

You can’t use the current ‘EC’ health and identification marks But products with the current logos shipped and placed on the market before 1st Jan, 2021 can continue to be sold till they are exhausted
You are a UK-based FBO placing your goods within the UK You can continue selling them with the current  health and identification marks until the end of the transition period i.e. 30th,Sept 2022
You’re an NI-based FBO You can continue to use your current health and identification marks to sell to the EU market
COUNTRY OF ORIGIN LABELLING (COOL)
IF THEN BUT
You’re a UK-based FBO and;

You are going to place new products on or after 1st Jan, 2021 for sale in the EU

You can’t label your products – ‘EU origin’ It must be changed to ‘non-EU origin’ instead
You’re a UK-based FBO placing your goods within the UK You can continue selling them with the current  ‘EU Origin’ label until the end of the transition period i.e. 30th,Sept 2022  
You’re an NI-based FBO You can continue to use the current  ‘EU Origin’ label to sell to the EU market  
COOL FOR DIFFERENT FOOD CATEGORIES SOLD WITHIN GB AND NI
CATEGORY UNTIL 30TH SEPT, 2022 POST 1ST OCT, 2022
MINCED MEAT GB

Continue to use EU and non-EU label until the end of the transition period i.e. 30th Sept, 2022

NI

Continue to use EU and non-EU label

GB

It must be changed to UK and non-UK

 

FRUITS & VEGETABLES GB

Continue to use a mix of EU and non-EU origin’

 

NI

Continue to use EU and non-EU label

GB

Changes to ‘a mix of UK and non-UK origin’

OLIVE OIL GB and NI

 

Continue to use EU and non-EU label

 

 

GB

 

The label must contain one of the following:

Each country of origin must be listed on the label

The statement ‘blend of olive oils from more than one country’ (or similar wording)

The name of the trading bloc to which a regional trade agreement applies, for example ‘blend of olive oils of European Union origin’

 

NI

Continue to use EU and non-EU label when no country of origin list is provided.

 

HONEY GB and NI:

 

From 1st Jan 2021: If you are not labelling with a list of origins and choose alternative wording, this statement must reflect the GB is no longer a part of the EU.

For a honey blend from EU member states = ‘Blend of EU honeys’

For a blend from countries outside the EU such as GB = ‘Blend of non-EU honeys’

For a blend from EU member states and non-EU member States such as GB = ‘Blend of EU and non-EU honeys

 

GB and NI:

 

You must use ‘blend of honeys from more than one country’ (or similar wording) if you decide not to list each country of origin.

BEEF AND VEAL GB and NI

Until 30th Sept, 2022: you can continue to use origin ‘non-EU’

 

 

GB

If the animal that beef or veal came from was born, reared or slaughtered outside of the UK, the label must state ‘Origin: non-UK

 

‘Live import into the EC’ must be replaced with ‘beef from a live import into the UK’ where the country of origin of the animal is not known.

 

NI

Continue to refer to ‘origin non-EU’ if the full individual country information is not available

 

 

EGGS GB and NI:

 

Eggs that do not meet EU egg trade regulations must be labelled as ‘Non-EC standard’.

GB:

 

Eggs that do not meet UK domestic egg trade regulations must be re-labelled as ‘Non-UK standard’

 

NI

Eggs that do not meet EU egg trade regulations must be labelled as ‘Non-EC standard’.

 

 

EU EMBLEM
IF THEN BUT
You are a UK-based FBO and;

You’re  placing your goods in EU and/or

You’re placing your goods within GB

You can’t use the EU emblem unless you’ve been authorised by EU to do so
GEOGRAPHICAL INDICATION LOGOS (except wines & spirits)
Ashbury’s guidance document could’nt have explained this better:

Place of sale: GB    =    Requires UK GI registration and logo; optional EU registration and use of logo (if protected in the EU).

Place of sale: EU    =    Requires EU GI registration and logo.

Place of sale: NI    =   Requires EU GI registration and logo, optional use of UK registration and logo.

Existing UK (including NI) products = Remain protected under current EU law and new UK law.

New GB produced products = Registration must be secured in the UK first, before registration under EU law.

New NI produced products = Do not have to secure EU registration before UK registration for sale in GB

Producers or retailers of GB food, drink and agricultural GI products registered before 1 January 2021, will have until 1 January 2024 to change packaging and marketing materials to display the new UK GI logos.

The UK logo will be mandatory for GB products registered from 1 January 2021 onwards.

 

The future holds more changes made in labelling legislations by the UK government. We think the most challenging aspect for UK exporters to the EU and vice versa lie in removing their FBO address and including their importer’s addresses. Significant work can also be seen in terms of harmonizing logos, symbols and statements across relevant SKUs.

Keeping track of these revised rules can be overwhelming. What will help is an automated packaging artwork management system – that includes a handy checklist to ensure compliance, proofing tools to validate your artworks and a workflow that helps you launch faster while pushing out artworks right-first-time.

Contact our team to know how.

References:

https://www.gov.uk/guidance/food-and-drink-labelling-changes-from-1-january-2021

https://ashbury.global/how-to-prepare-your-labels-for-brexit/

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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