On 24 December 2020, the European Union and the United Kingdom reached an agreement in principle on the EU-UK Trade and Cooperation Agreement. Content on the site is being monitored to reflect this and the changes.

Under the Protocol on Ireland/Northern Ireland there are to be no tariffs or Customs controls on the island of Ireland, and goods moving between Northern Ireland and the rest of the EU will also continue to move freely. Great Britain (GB) will be outside the EU Single Market and Customs Union and there will be some changes to regulation and standards. 

This section will cover the following areas:-


  • Food Labelling (address of the Food Business Operator).
  • Country of Origin Labelling.
  • Nutrition-related Labelling.
  • Organic Product Logo.
  • Chemical Classification, Labelling and Packaging.
  • Conformity Assessment
  • Sector Specific Regulation
  • Other Useful Links.
Food Labelling – Address of the Food Business Operator 
Ireland and Northern Ireland

Goods sold in Northern Ireland will continue to follow EU rules for food labelling.

Pre-packaged food that is placed on the market in the EU or sold in Northern Ireland, must have the EU or Northern Ireland address of the food business operator or importer on its packaging.

Therefore, Northern Irish, or 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.

From 1 October 2022, a UK address will be required for the food business operator or importer.

For further information, please see FSAI and HMRC guidance.

Please also see useful links section further below.

Country of Origin Labels 
Ireland and Northern Ireland

Food from GB must not be labelled as ‘origin EU’. However, food from Northern Ireland can continue to use ‘origin EU’. Where EU law requires the Member State origin on the product, food from Northern Ireland should be labelled as ‘UK(NI)’ or ‘United Kingdom (Northern Ireland)’. 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’.


Useful Information

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 here.


Organic Product Logo
Ireland and Northern Ireland

The EU has agreed to recognize 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 the EU Organic Logo is used it must meet all EU Organic labelling requirements. The EU Organic logo must also meet statement of agricultural origin requirements.

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.

  • DAERA – Northern Ireland, click here.
  • GOV.UK guidance here.
  • EU guidance on this subject is available here.
  • Food Safety Authority of Ireland guidance here.
  • Department of Agriculture Ireland here.


Nutrition-Related Labelling
Ireland and Northern Ireland

EU law on food composition, ingredients and limits for contaminants/residues applies to all food placed on the EU market – no matter where it was produced.  

EU legislation relating to nutrition-related labelling will apply in Northern IrelandAll food and drink products placed on the market in either Northern Ireland or Ireland from 1st January 2021 will be required to meet all EU regulations on both Product Standards and labelling.

As a result, Marketing Standards Checks will be conducted at point of entry into Northern Ireland for any food products imported from GB. These will be administered by DAERA.

There will be no changes with regards to marketing standards for food in Northern Ireland being exported to GB or the EU.

Businesses in Northern Ireland/Ireland should be mindful of the potential for divergence in Food Composition Standards between the UK and the EU going forward.

  • More information from DAERA on Marketing Standards – Northern Ireland, can be found here.
  • More information from GOV.UK on requirements Food standards: labelling and composition can be found here.
  • More information from Food Safety Authority of Ireland on topics such as food imports, food labelling and more can be found here.


For legislation see below:

  • GOV.UK Nutrition legislation here.
  • EU Food legislation here.


Chemicals Classification, Labelling and Packaging
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 .

Following the recent end of the transition period Reach Regulations will continue to apply across Northern Ireland and Ireland. However, it is important to be aware if trading with the rest of the UK that they are no longer bound by the EU Reach Regulations.

Businesses who import chemicals from GB should engage with their suppler in GB to ensure that all products are correctly packaged and labelled to meet EU Reach Requirements. 

REACH is a European Regulation and is an acronym for the Registration, Evaluation, Authorization and Restriction of Chemicals.

It is essential that businesses in Northern Ireland/Ireland comply with both sets of regulations.

Over time there is likely to be an increased level of divergence between the UK and EU Reach. Businesses should monitor this for future developments.

Where notification is required of the hazard classification and labelling of substances placed on the Northern Ireland market, businesses in Northern Ireland should do so to through the European Chemicals Agency (ECHA). Link provided further below. 

Downstream users and distributors in Northern Ireland who are supplied by businesses in the EU/EEA won’t face new requirements. 

For chemicals traded from GB to Northern Ireland, the responsibility for the classification, labelling and packaging of chemicals will rest with the Northern Ireland-based business that places the chemical on the Northern Ireland market, even if it is currently a downstream user or distributor.

  • For Health and Safety Executive UK advice on duties of Northern Ireland-based businesses directly supplying chemicals to Great Britain read here and for UK Chemical classification read here.
  • For Health and Safety Authority Ireland updates on REACH read here and for EU information (ECHA) REACH read here.


Conformity Assessments, CE Mark, UKNI Mark, UKCA Mark
Ireland and Northern Ireland

The Northern Ireland Protocol came into force on 1 January 2021. For as long as it is in force;

“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.”

For most manufactured goods, the EU conformity assessment marking is the CE mark. 

This section will reference the CE mark (EU), the UKNI mark (NI) and the UKCA mark (UK). Please also see useful links section further below where we have included key government links for this topic.

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 never apply the UKNI marking on its own. To check whether you need to use the UKNI markingread 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. However, CE marking will be accepted until 1 January 2022 for certain products. 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.

Key Points

  • From the 1st January 2022 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.


Useful links

GOV.UK Placing manufactured goods on the market in Northern Ireland click here.
GOV.UK Placing manufactured goods on the market in Great Britain click
here.
GOV.UK Using the UKNI marking click
here.
GOV.UK Guidance Conformity assessment and accreditation click
here.
HSA Ireland Health and Safety Authority Ireland click
here.
FSAI Ireland Food Safety Authority of Ireland click
here.
National Standards Authority Ireland click
here.


Sector Specific Regulation
Ireland and Northern Ireland

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.


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.

• Information and Communications Technology Technicians (ICTTech).


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.


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.


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.

Useful Links 

GOV.UK – Placing manufactured goods on the market in Northern Ireland, click here.
GOV.UK – Placing manufactured goods on the market in Great Britain, click
here.
GOV.UK – Using the UKNI marking, click
here.
GOV.UK – Guidance Conformity assessment and accreditation, click
here.
GOV.UK – UK Timber Regulation, click
here.
GOV.UK – Designated Standards: Lists of standards that businesses can use to show their products, services or processes comply with essential requirements of legislation, click
here.
GOV.UK – Protected geographical food and drink names: UK GI schemes, click
here.
GOV.UK – Rules for wine importers, exporters, producers, retailers and distributors, click
here.
GOV.UK – How organic food producers, sellers and importers must label organic food products, click
here.

GOV.UK – Declaring reusable packaging for Great Britain imports and exports click here.