The UK Government has this week issued updated guidance on food and drink labelling in the event of a no deal Brexit.
Although the Government said securing a deal with the EU remains its “top priority” it stressed the need to “prepare for every eventually”. This, of course, includes the increasingly likely no-deal scenario.
Food businesses with have a 21-month transition period for the most significant changes to food labels.
However, in the event of a n-deal Brexit, there are some technical changes to labels that will be required from day one.
For products placed on the UK market after 29 March 2019, these changes include:
- The EU emblem must not be used on goods produced in the UK unless a company has been authorised by the EU to do so;
- The EU organic logo must not be used on any UK organic products, unless the UK and EU reach an equivalency arrangement – where both still recognise each other’s standards – before exit day; and
- It will be inaccurate to label UK food as origin ‘EU’. Additional information such as signage in shops and online information will help clarify to the consumer the origin of the food.
Food and drink products that have already been placed on the UK market on or before 29 March 2019 can continue to be sold through until the stocks are exhausted, the Government says.
For goods placed on the UK market after 29 March 2019 where, as a result of EU Exit, the information is technically incorrect (for example UK products labelled as origin ‘EU’), the UK government will encourage enforcement officers to take a pragmatic approach to enforcement.
The EU and other non-EU countries may require wholly accurate labelling for access to their markets. In these instances, the Government said it would “recommend labels are replaced or over-stickered as required to ensure they are fully accurate”.
There will be a three-year transition period for the new UK Geographical Indication Schemes logo. The new UK logo will be available from 29 March 2019, so producers have the option to make GI labelling changes before the end of the adoption period if they wish.
However, the Government said that all changes will be subject to parliamentary process.