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Food Business Operator Address Requirements for Export - EU/UK
Food Business Operator (FBO) Address Requirements for Export - EU & UK
Exporting to the European Union (EU) has been a challenge for food producers in the UK since BREXIT happened in early 2021. Many companies have stopped selling product into the EU until they can find a solution that meets the new market rules and their own business requirements; some have decided to stop exporting to the EU completely.
Understanding the labelling requirements can be difficult and time consuming, one particular area that has become a stumbling block is the Food Business Operator address and defining which address to use in different markets. Here's an overview of the requirements:
Exporting to the EU
If you export and sell products to the EU and are resident outside the EU, you will need local market representation. Businesses wishing to sell pre-packaged food and caseins into the EU nee d to have an EU or Northern Ireland (NI) address, or an address of the EU or NI importer of the food on the packaging or food label. A GB address alone is not sufficient.
Currently the options for food producers are to either set up a business entity in an EU country or to use an EU based importer. Setting up a business entity can be costly and comes with added administration and taxation requirements. Finding a suitable importer can also be tricky. Under EU law the importer i.e. the party bringing the product into the EU is primarily responsible for the food information on pre-packed food; some operators in the food chain understandably do not want to be named as the importer unless indemnities are in place.
There are also particular challenges for organic food producers trying to find EU importers that are both certified to organic standards and willing to deal with the added administration of TRACES NT and Certificates of Inspection (COI).
N.B - Northern Ireland follows EU rules for labelling so if you sell food from GB into NI you will also need an EU or NI FBO/importer address on pack.
Exporting to Great Britain
Businesses intending to sell food products into GB have a bit more time to make the changes to the FBO/importer address on pack. Food from a EU27 country can continue to be sold until 30th September 2022 without labelling changes - as long as it complies with EU law. You will still need local market representation to be able to sell into GB.
From 1st October 2022 a UK FBO/importer address is required on the packaging in addition to your company address. You will need to make it clear on the label which market the two addresses apply to i.e. imported into the UK by xx..
So is there a solution?
Yes.
This is where an Authorised Representative (AR) can help, acting as a neutral party between manufacturers and authorities whilst providing you with technical and legislative representation. The benefits of using an AR service include:
- providing you access to the EU/UK market, including the use of an EU/UK address on your packaging;
- representing you on your behalf for all legal issues pertaining to your product;
- notification of any regulatory changes that may affect your products;
- ensuring the availability of technical files in case of requests from authorities;
- reassurance that your product is suitable for the intended markets;
If you need help accessing the EU or UK market, check out our Authorised Representation (FBO) Service
in conjunction with CERTLabel Ltd.
We offer monthly billing which allows you more flexibility for representation, plus our FBO clients have access to VAT guidance notes for all EU27 countries.
