On 10 September 2020, Government updated its guidance on the marking, labelling and marketing standards that food business operators (FBOs) must follow to import and export food, plant seeds and manufactured goods from 1 January 2021. You can read the full guidance here.
In relation to food labelling, the guidance is split into two parts. Food that is being exported to the EU and that which is sold in the UK.
Exporting to the EU
The EU has issued guidance on labelling changes required from 1 January 2021. FBOs should check with their EU importer to find out how the EU's new labelling requirements affects their products. Food products placed on the EU market before 1 January 2021 can continue to be sold, distributed or transferred in the EU without labelling changes.
In brief, the EU emblem, EU health and identification marks and EU country of origin labels must all be removed from 1 January 2021. Use of the EU organic label is still up in the air until we know whether an equivalency deal is agreed with the EU.
Goods sold in the UK
From 1 January 2021, FBOs must use the new UK health and identification marks for products of animal origin to clearly show the UK product has been subjected to strict health and welfare checks. FBOs must include a UK address on pre-packaged food or caseins sold in the UK or, if the FBO is not in the UK, include the address of the importer.
As mentioned above, FBOs must not use the EU organic logo on any UK organic food or feed from 1 January 2021, unless either the control body is authorised by the EU to certify UK goods for export to the EU or the UK and the EU agree to recognise each other's standards.
Foods currently protected with the geographical indication (GI) logo will need to switch to using the UK GI logo which we understand will be available from 1 January 2021.
There are detailed rules in the guidance for country of origin labelling for different food products which can be read here.
FBOs should study the guidance and understand the steps that they need to take to ensure that they are ready for 1 January 2021.
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.