Regulations, Standards & Labelling

The EU-UK Trade and Cooperation Agreement, now in place, means change. It will require adapting to new trading arrangements, rules and regulations. This information will introduce labelling, sector specific regulation and useful links.  

Food Business Operator Address

Ireland and Northern Ireland: Under the Northern Ireland Protocol EU food law will continue to apply to and in Northern Ireland. Therefore, for food labelling purposes, the address of a FBO established in Northern Ireland will continue to be accepted as an EU address. For more information visit the Food Safety Authority Ireland (FSAI), click here. 

Ireland and GB: Irish businesses involved in the importation of food from GB should speak to their GB suppliers to make sure that all packaging is addressed correctly. Companies selling pre-packaged food to GB can continue to use an EU, GB or Northern Ireland address for the food business operator until 30 September 2022, however,  from 1 October 2022, a UK address will be required for the food business operator or importer. For more information see FSAI and GOV. UK guidance.

Northern Ireland and GB: From 1 October 2022, pre-packed food to be placed on the GB market will need a GB or Northern Ireland address. For more information from GOV.UK, click here. 

Country of Origin Labels

Ireland and Northern Ireland: Under the Northern Ireland protocol, EU Country of Origin rules are applicable for food placed on the NI market. Where EU Law requires an indication of a Member State in respect to country of origin, food businesses must ensure that where food has originated in Northern Ireland, such indications should be in the form “UK(NI)” or “United Kingdom (Northern Ireland)”. For more information visit the Food Standards Agency Ireland, click here. 

Ireland and GB: Food from GB must not be labelled as ‘origin EU’. Where EU law does not require an EU Member State to be indicated, food from and sold in NI can continue to use ‘origin EU’ or ‘origin UK’. Food from Northern Ireland which is sold in GB may be labelled ‘UK (NI)’, ‘United Kingdom (Northern Ireland)’ or ‘UK’. GB has also said that food from and sold in GB can be labelled as ‘origin EU’ until 30 September 2022.  There are particular rules for beef & veal, eggs, fruit & vegetables, honey blends, minced meat and olive oils available hereFor more information from GOV.UK click here and for more information from Food Standards Agency Ireland click here

Northern Ireland and GB: Food from GB must not be labelled as ‘origin EU’ from 1 January 2021. Food from Northern Ireland can continue to use ‘origin EU’. For more information visit the British Retail Consortium, click here.  

Organic Product Logo

The EU has agreed to recognise UK as equivalent in relation to organics. This means businesses will be able to use the EU Organic logo on all organic food until 31st December 2023. If businesses in Northern Ireland are exporting to the EU and using the EU Organic logo both the GB and EU statement of agriculture will be required. For more information from GOV.UK, click here. 

Nutrition-Related Labelling

Ireland and Northern Ireland: Under the Northern Ireland protocol,  EU legislation relating to nutrition-related labelling will apply in Northern Ireland. For more information visit GOV.UK, click here. 

Ireland and GB: The food business operator must ensure the presence and accuracy of the food information in accordance with the applicable EU food information law and any requirements of relevant national provisions. For more information visit Food Standards Agency Ireland, click here. 

Northern Ireland and GB: The Protocol on Ireland/Northern Ireland means that EU legislation relating to nutrition related labelling, composition, and standards continues to be directly applicable in Northern Ireland. Businesses should note, however, that under the Protocol the Food Standards Agency (FSA) is not able to submit (1) applications for new nutrition and health claims for Northern Ireland. Businesses seeking to submit any of the above applications or scientific dossiers in respect to authorisation for the Northern Ireland markets should forward them to the European Commission. For more information visit the Food Standards Agency, click here. 

Chemicals

Ireland and Northern Ireland: Chemicals (substances or mixtures) placed on the market in Northern Ireland must continue to comply with the EU Chemicals Classification, Labelling and Packaging Regulation. It is essential that businesses in Northern Ireland/Ireland comply with both sets of regulations. For more information from the Health and Safety Authority, click here. 

Ireland and GB: The UK REACH and the EU REACH regulations will operate independently from each other. Companies that are supplying and purchasing substances, mixtures or articles to and from Ireland and GB will need to ensure that the relevant duties are met under both pieces of legislation. For more information from the Health and Safety Executive, click here. 

Northern Ireland and GB: Northern Ireland remains within EU REACH. The UK use UK REACH, the EU REACH regulations will operate independently from each other.  For more information from the Health and Safety Executive, click here. 

Sector Specific Regulation

There will be some changes regarding industry specific regulations. These regulations changes will largely be done on a profession by profession and country by country basis, so it is essential that businesses check with the relevant professional body in the country they are wishing to undertake work in. We’ve outlined some key areas below: 

Regulations: As a result of the Trade and Continuity Agreement (TCA) between the UK and the EU there will be some changes regarding industry specific regulations now that the UK has left the EU. These regulations changes will largely be done on a profession by profession and country by country basis, so it is essential that businesses check with the relevant professional body in the country they are wishing to undertake work in. For more information from the European Commission, click here. 

Construction: Any individual undertaking work at a construction site in Ireland is required to hold a Solas Safepass Card that illustrates that they have completed a one-day course in Health and safety. In Northern Ireland construction workers are required to hold a Construction Skills Register (CSR) card. Prior to the end of the transition period these schemes were mutually recognised meaning workers who processed a CSR card could work in Ireland and vice versa. This will continue to be the case. Should construction workers be involved in any activities which come under Schedule 5 of Safety, Health and Welfare at Work (Construction) Regulations 2013 including but not limited to Plant Machinery, Scaffolding or Roofing must be in possession of the related Construction Skills Certification Scheme (CSCS) card. It is important to be aware that the previous exemption for individuals who held an NVQ Level 2 qualification in Northern Ireland will no longer apply. More information which roles are impacted can be found here.

Engineering: In 2018 Engineers Ireland and the Engineering council signed the Access Pathways Agreement. This agreement is designed to enable the mobility of engineering professionals between the UK and Ireland allowing them to take advantage of streamlined registration and membership. The following titles will continue to be recognised across both the UK and Ireland, Chartered Engineer (CEng), Engineering technician (EngTech), Associate Engineer Ireland/ Incorporated Engineers UK and Information and Communications Technology Technicians (ICTTech). For more information from Engineering Ireland, click here. 

Public Procurement: Going forward there will be some changes regarding the Public Procurement. Prior to the end of the transition period the UK agreed to continue to follow the World Trade Organisation’s General Procurement Agreement (GPA) This agreement is in effect the default terms covering Public Procurement. As part of the Trade and Cooperation Agreement (TCA) both the UK and the EU have agreed to expand upon the terms set out in the GPA to offer a much wider level of market access. One area where businesses in both Northern Ireland/Ireland should be aware of is how tenders are advertised. Going forward any high value tenders above £122,976 in the UK will no longer be advertised on the OJEU/TED system. They will instead be advertised on the new Find A Tender System which can be accessed here. All tenders in Ireland will continue to be advertised on the OJEU/TED system as they had been previously.

CIPD: In Ireland, Human Resources is not classed as a regulated profession. Therefore, all CIPD qualifications and membership status continue to demonstrate professional competency and therefore there is no additional actions which HR professionals in the UK need to take to be able to work in Ireland vice versa. HR professionals should however check the country specific requirements for other EU countries. For more information from CIPD, click here. 

Chartered Accountancy Qualifications: Going forward chartered accountancy qualifications will remain largely unchanged on the island of Ireland. All Irish ACA qualifications will continue to be recognised in both UK and Irish law. With the continuation of the Common Travel Area people with ACA qualifications will be free to travel and practice across the UK and Ireland. Likewise, individuals who obtain Audit qualifications Northern Ireland or Ireland able to practice across the UK and Ireland. For more information from Chartered Accounts Ireland, click here.  

ISO Certifications: ISO certifications are global certifications which are recognised in 162 countries worldwide. These qualifications will continue to be recognised in both the UK and Ireland now that the transition period has ended. For more information from the British Standards Institution, click here. 

Conformity Assessments, CE Mark, UKNI Mark, UKCA Mark

For most manufactured goods, the EU conformity assessment marking is the CE mark.  The Northern Ireland Protocol states that “Northern Ireland will align with all relevant EU rules relating to the placing on the market of manufactured goods and must show that products meet those rules by using conformity markings”. 

Businesses in Ireland will be able to use CE Marking when placing goods on the market within GB until the 31st December 2021 for products whereby UK and EU rules remain the same .

Businesses in Northern Ireland will be able to continue to be placed CE marked goods onto the GB Market regardless of whether the UK and EU regulations diverge. This is due to the UK government commitment to Unfettered Access.  In Northern Ireland, EU conformity markings continue to be used to show goods meet EU rules. For most manufactured goods, this is the CE marking, but there are some other markings for specific products. Entities in Northern Ireland that use a UK conformity assessment body will also need to apply a UKNI marking – which must always be accompanied by an EU conformity marking (e.g. CE), you should check whether you need to use the UKNI marking, click here . Northern Irish manufacturers who mark goods on the basis of a supplier’s declaration of conformity (self-certification) can continue to do so.

UKCA Marking: The UKCA mark will be the conformity assessment marking for Great Britain for most goods that are currently subject to CE marking. CE marking will be accepted until 1 January 2023 for certain products. Please note: In recognising the impact of the pandemic on businesses, the government extended this deadline to 1 January 2023, rather than 1 January 2022.  The CE marking will only be valid in Great Britain for areas where GB and EU rules remain the same, even before 1 January 2022. UKCA will be needed if the product for the GB market requires UKCA marking, mandatory third-party conformity assessment and if the conformity assessment has been carried out by a UK conformity assessment body and the files haven’t been transferred to an EU recognized body. Northern Ireland business, will continue to be able to place qualifying Northern Ireland goods on the GB market with an EU conformity assessment marking (e.g. CE) after 31 December 2021, click here for more information.

In summary: 

  • From the 1st January 2023 Irish businesses will not be able to use the CE mark when placing products on the market in GB.
  • Entities in Northern Ireland that use a UK conformity assessment body will also need to apply a UKNI marking – which must always be accompanied by an EU conformity marking (e.g. CE), you should never apply the UKNI marking on its own.
  • The UK’s new conformity assessment marking – UKCA – cannot be used for goods placed on the Northern Ireland market. Businesses can put both the CE and UKCA marking on a product if it does not impede each other.

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