Reviewed in November 2020. Content will be updated as negotiations develop.

At present, producers across Europe (including the UK) adhere to a common set of standards in terms of labelling – this includes use of EU emblems and logos as well as compliance and conformity marking. However, from the end of the transition period, there are several changes that Irish businesses will need to be cognisant of when seeking to continue trading with UK firms.

Labelling

Food Labelling

Following the end of the EU Exit transition period on 31 December, the UK will have autonomy over its own food labelling, and products produced in the UK will no longer need to comply with EU regulatory and compliance standards. 

Food producers in Ireland will continue to use EU labelling when exporting food products to the UK, however there are additional responsibilities on Irish importers of food products when bringing in food from non-EU countries. These include: 

1) Ensuring the mandatory food information is present on labelling.

2) Ensuring that food labelling is both accurate and in accordance with the applicable EU regulations, along with any national requirements where appropriate.

3) Checking with suppliers that products fulfill all EU safety, health and environmental protection requirements before placing them on the market.

To ensure that food information and labelling requirements are correct, Irish importers will also have to verify that: 

4) The manufacturer outside the EU has taken the necessary steps to allow the product to be placed on the EU market;

5) The necessary documentation such as the EU Declaration of Conformity and the technical documentation is available upon request; and

6) Contact with the producer is possible at any time.

Moreover, any producer who wishes to export food or beverages from the UK into the EU (including Ireland) from 1 January 2021 will need to have either an EU or a Northern Ireland address on their products’ labels. There may therefore be a requirement for Irish importers to supply this information to UK based suppliers in order for trade to continue, particularly if the supplier does not have any operations within the EU. 

Food that has already been placed in the EU market prior to the end of the transition period can continue to be sold without requiring updated labels. 

Organic Production Logo

Due to continued membership of the EU, Ireland food producers will continue to use the EU Organic Logo on pre-packaged organic food. However, from 1 January 2021, businesses in Northern Ireland will no longer be able to use the EU Organic Logo unless the control body is authorised by the EU or there is an agreement between the UK and the EU whereby they recognise each other’s standards.

For more information, click  here.

CE Marking

CE Marking signifies that a product meets all necessary European health, safety and environmental protection requirements. During the transition period the UK will continue to use CE Marking. However, from 1 January 2021 onwards, a new UKCA (UK Conformity Assessed) mark will be required for goods on sale in England, Scotland or Wales. 

CE Marking will continue to be recognised in the UK as long as the UK and EU regulations remain aligned. However, from the beginning of 2022 only products with UKCA marking will be accepted in GB. 

Detailed guidance in relation to the use of UKCA marking can be found  here

Guidelines for trading in Northern Ireland are slightly different, given Northern Ireland’s continued membership of the EU Single Market for Goods. Goods in Northern Ireland will need to display evidence of conformity with EU regulations, and will therefore continue to require EU CE Marking. 

For more information, click  here.

Declarations of Conformity

The EU Declaration of Conformity is a legal requirement for manufacturers aiming to sell their products in the EU. By signing this document, a manufacturer is certifying that their products meet all EU standards. With Northern Ireland continuing to form part of the EU Single Market for Goods post transition period, an EU Declaration of Conformity will be required for any products manufactured in Northern Ireland which are sold in Northern Ireland, Ireland or the rest of the EU. 

The UK Declaration of Conformity is a document which must be drawn up for most products lawfully bearing a UKCA marking.

The information required on the Declaration of Conformity is likely to be largely the same as what is currently required on an EU Declaration of Conformity, however there is scope for variances depending on the application legislation. This Declaration will be required for gods bearing a UKCA mark, and should be available to market surveillance authorities should they request it. 

On 1 January 2021, the UK standards will be the same in substance and with the same reference as the standards used in the EU. However, they will use the prefix ‘BS’ to indicate that they are standards adopted by the British Standards Institution as the UK’s national standards body. 

For more information, click  here.

More information on Labelling requirements post transition period can be found  here and information for specific types of products in the EU can be found  here

The main changes and considerations for Irish firms will be when selling to the GB. Guidance can be found  here

Information for GB firms importing to Ireland can be found  here.