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The ABC of upcoming Food Labelling changes...Country of Origin (COOL)
11.11.2020
For the final article of this series we look at the changes to Country of Origin Labelling (COOL) that are required from 1 January 2021. In our previous article on Brexit we touched on the requirements, however it is a complex topic with a lot of information. We will cover the general rules and the product specific controls for minced meat, fruit and vegetables, olive oil, honey blends, beef and veal, and eggs.
Requirements for providing information on the country of origin or place of provenance of food and drink products and ingredients are detailed in Article 26 of the Food Information to Consumers Regulation (EU) No. 1169/2011 (FIC). In 2018 an amend was made with Regulation (EU) No. 2018/775 to establish rules and requirements for the application of Article 26 (3) of the FIC - regarding the indication of the origin of the primary ingredient of a food. This came into force on 1 April 2020.
KEY POINTS FOR 'COOL' FROM 1 JANUARY 2021
Exporting to the EU
- GB - Food produced from GB must not be labelled as origin 'EU' from 1 January 2021.
- NI - Food from NI can continue to use ‘origin EU’ from 1 January 2021. Food from NI should be labelled as 'UK(NI)' or 'United Kingdom (Northern Ireland)' where EU law requires a member state to be indicated on the label.
Goods sold in GB and NI
- GB - Food produced from and sold in GB can be labelled as ‘origin EU’ until 30 September 2022. After this date food from and sold in GB must not be labelled as 'origin EU'.
- NI - Food produced from and sold in NI can continue to use ‘origin EU’ or ‘origin UK’ where EU law does not require an EU member state to be indicated on the label. However, where EU law requires the label to have an EU member state indicated, labels should refer to 'UK(NI)' or 'United Kingdom (Northern Ireland)'.
- NI into GB - Food produced from NI and sold in GB can be labelled as ‘UK(NI)’, ‘United Kingdom (Northern Ireland)’ or ‘UK’.
Foods placed on the market or labelled prior to 1 January 2021 can continue to be sold until stocks are exhausted.
PRODUCT SPECIFIC CONTROLS FOR GREAT BRITAIN AND NORTHERN IRELAND
Minced Meat
GB
- Minced meat sold in GB can continue to refer to 'EU' and 'non-EU' until 30 September 2022. After this date labels must use 'non-UK' or 'UK and non-UK' when the label does not list each country of origin.
NI
- Minced meat sold in NI must refer to 'EU' and 'non-EU' when the label does not list each country of origin from 1 January 2021.
Fruit and Vegetables
GB
- Mixes of fruit and vegetables sold in GB can continue to refer to 'EU' and 'non-EU' until 30 September 2022. From 1 October 2022, this must change to 'non-UK' or 'UK and non-UK' when the label does not list each country of origin. If part of an Approved Trader Scheme, the EU emblem must be changed to the GB version from 1 January 2021. Existing stock with the EU emblem on should only be sold in GB until it runs out.
NI
- Mixes of fruit and vegetables sold in NI must refer to 'EU' and 'non-EU' when the label does not list each country of origin from 1 January 2021.
Olive Oil
GB
- For olive oil blends sold in GB, the label must not use the term 'non-EU' from 1 October 2022. If the product is a blend of oils from different countries, the label must contain one of the following:
- a list of each country of origin
- the statement 'blend of olive oils from more than one country' or similar wording
- the name of the trading bloc to which a regional trade agreement applies, for example 'blend of olive oils of European Union origin'
NI
- Olive oil blends sold in NI must refer to 'EU' and 'non-EU' when the label does not list each country of origin from 1 January 2021.
Honey Blends
England and Wales
- For honey blends sold in England and Wales (where honeys are from different countries) the following terms can be used until 30 September 2022:
- blend of EU honeys
- blend of non-EU honeys
- blend of EU and non-EU honeys
- blend of honeys from more than one country (or similar wording) - from 1 October 2022 this term must be used if each country of origin is not listed.
If EU terms are to be used on the label they must be accurate. For example if a blend of UK and French honey was previously labelled 'blend of EU honeys' it would either need to list both countries or use the words 'blend of EU and non-EU honeys'.
Scotland
- For honey blends sold in Scotland from 1 January 2021, origin labelling options include the following:
- ‘blend of honeys from more than one country’ (or similar wording)
- Reference to the trading bloc of the countries of origin for example ‘blend of EU honeys’, 'blend of non-EU honeys', 'blend of EU and non-EU honeys'
NI: For honey blends placed on the market in NI after 1 January 2021 labels must reflect that GB honey is no longer EU honey, and use one of the following terms: 'blend of EU honeys', 'blend of non-EU honeys', 'blend of EU and non-EU honeys'.
Beef and Veal
GB
- Beef and veal sold in GB (that was born, reared or slaughtered outside of the UK) can refer to 'Origin: non-EU' until 30 September 2022. After this date labels must refer to 'Origin: non-UK' when the full individual country information is not available.
NI
- Beef and veal sold in NI (that was born, reared or slaughtered outside of the EU) must refer to 'Origin: non-EU' from 1 January 2021, when the full individual country information is not available.
Eggs
GB
- Eggs that do not meet domestic egg trade regulations can be marked as 'non-EC standard' or 'non-UK standard' until 30 September 2022. After this date eggs should be marked as 'non-UK standard'.
NI
- Eggs imported and sold in NI that do not meet EU marketing and trade regulations must be labelled as 'non-EC standard' from 1 January 2021.
SUMMARY
COOL is not a quick and simple subject, especially when guidance is changed so frequently as a result of ongoing negotiations.
Key Points:
- Food products of GB origin exported to the EU must not be labelled as 'origin EU' from 1 January 2021, NI food products can continue to use 'origin EU'. Foods placed on the market or labelled prior to this date can continue to be sold until stocks are exhausted.
- For products sold in GB, label changes come into force again on 1 October 2022, depending on the category and country of sale. Examples include replacing instances of ‘EU’ with ‘UK’ or stating the product is made from a ‘blend of [x] from more than one country’ (or similar wording).
*Disclaimer: The information presented in this document is a summary of key information from cited government resources, and is for general information purposes only. All information is subject to change and is correct as of 11.11.2020.*
