the latest food news, legislation changes and discussion

New legislation - Genetic Technology (Precision Breeding) Act

Wed, 05 Apr 2023 09:53:09 GMT

The Genetic Technology (Precision Breeding) Act was passed into law on 23/03/23. Precision breeding uses technology such as gene editing to adapt the genetic code of organisms, the government claims that the act will allow farmers to grow crops which are drought and disease resistant. This will enable farmers to reduce the use of fertilisers and pesticides, and help breed animals that are less likely to catch harmful diseases.

A new science based regulatory system will be introduced to facilitate research and innovation in precision breeding. Stricter regulations will remain in place for genetically modified organisms (GMOs). The purpose of the act as stated in the legislation is 'to make provision about the release and marketing of, and risk assessments relating to, precision bred plants and animals, and the marketing of food and feed produced from such plants and animals; and for connected purposes'.

Genetic Technology (Precision Breeding) Act 2023 (legislation.gov.uk)

05/04/2023

Labelling food products for export - avoid the pitfalls

sjw.technical.ltd@outlook.com (Sarah Wolton) — Tue, 18 Oct 2022 10:13:01 GMT

Understanding the labelling requirements for different markets can be a minefield, particularly as the requirements are becoming increasingly non-harmonised across the EU. We regularly guide clients on the requirements for their chosen markets and as a result have come across some recurring themes. In this short article we've provided some tips on how to avoid the pitfalls and ensure export success.

Check Harmonised & National Legislation

Food labelling rules for the EU are harmonised under regulation no. 1169/2011, but there are many additional regulations and directives at National level that also need to be considered. This can include product specific rules such as restrictions on plant-based product naming, recycling/environmental information and registrations/notifications for products and packaging. There are also marketing standards and compositional standards for various products that need to be adhered to.

What about the UK? The UK currently follows retained EU law as well as National legislation; however, the recently approved Brexit Freedoms Bill will end the special legal status of all retained EU law by 31 December 2023. This will give the UK the opportunity to develop new laws, the impact of this is not yet known for food labelling legislation but is something we will be keeping an eye on.

Plan early - avoid a 'fail to fit' scenario

Often companies don't factor in the extra time and cost required to adapt labels to the standards in the country they wish to export to. This can result in a 'fail to fit' scenario, where the packaging isn't large enough to fit all the languages and markings on that are required. It's important to consider packaging design/size early on in the development process, as well as deciding which markets to sell into in advance (if possible). This avoids any quick fixes, such as having to over label packaging that is already printed. It also saves your labelling advisor from a big headache :)

Lost in translation

Automatic generated translators such as google translate/DeepL are sometimes used as a quick solution for on pack translations, however it is important not to rely solely on these as they can be a little too literal. Using native speaking translators is key, particularly with food products as English terms don't always translate well into other languages. For example, a vegan meat alternative described as 'chicken-style' in the UK might not have the correct meaning for consumers in some EU countries, unless the translation is adapted correctly. This is essential to get right, after all, if your customers don't understand your products why would they buy them?

Ensure you have all the puzzle pieces

Of course, labelling is only one area that needs to be sorted to ensure your product can be exported successfully. Here are our top 5 areas to address to ensure a smooth process:

Shipping & Distribution - having a good relationship with your shipping and distributors is key. Shipping services can vary depending on what INCOTerms you have agreed whether it is just bulk shipping, including warehousing, or if it is to include further distribution.
Importer of Record - An importer of record, provides a service for situations when a company is importing goods into a country where it has no representation and/or it wants the asset to remain the property of the exporter/shipper/origin company. The IOR provides an in-country presence to import the goods into that country.
Technical and legal market representation - Commonly referred to as Authorised Representation. An Authorised Representative (AR) is a recognised legal entity in the market where the product is being sold and holds the responsibility to act as a neutral party between the competent authorities and the non-EU/non-UK manufacturers. This is particularly useful if you do not wish to setup an entity in the EU/UK.
B2C considerations – Import One-Stop Shop (IOSS) for VAT claims - An EU IOSS VAT number is used to keep track of how much tax your business collects from sales and allows you to remit the VAT to the European country of registration. In the UK, imported goods are subject to import VAT, so you can either register for VAT or you can use an agent in the UK to import and supply goods on your behalf.
EORI (Economic Operator Registration and Identification) number - An EORI number is an identification number needed to export shipments from the UK and EU to keep track of shipments more smoothly.

If you're struggling to understand the labelling requirements for your export markets, then we can help. We offer labelling guidance, as well as our Authorised Representation (FBO) service that we run in conjunction with CERTLabel. Get in touch to see how we can help!

18/10/22

UK Government delays Brexit labelling changes until 2024

sjw.technical.ltd@outlook.com (Sarah Wolton) — Mon, 12 Sep 2022 14:35:54 GMT

UK Government delays Brexit labelling changes until 2024

The UK government has announced a delay in the labelling changes for food products that were due to come into force on 1st October 2022. These have now been postponed to 1st January 2024, giving food producers another 15 months to adapt labels.

Defra has said this was 'in line with protecting consumers from unnecessary costs'. It would also allow food business operators to continue to deplete existing stocks of labels, wrapping and packaging until the new rules come into force.

Summary of the labelling changes:

Food Business Operator Address (FBO)
Companies can continue to use an EU, GB or NI FBO address on pre-packaged food or caseins until 31st December 2023
Labelling terms referring to 'EU' for specific products
Affects these products primarily: beef/veal, minced meat, honey blends, olive oil, fruit and veg, eggs, wine
UK/EC Health and Identification marks can be used until 31st December 2023

The government is set to publish more detailed guidance relating to these import controls in the coming weeks.

A copy of the note from DEFRA is here :

If you need any help in making changes to your labels so you're ready for the deadline, get in touch today.

Food Business Operator Address Requirements for Export - EU/UK

sjw.technical.ltd@outlook.com (Sarah Wolton) — Wed, 09 Jun 2021 14:38:11 GMT

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 requirement s:

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.

First Insect to be approved as a Novel Food

sjw.technical.ltd@outlook.com (Sarah Wolton) — Fri, 14 May 2021 15:39:10 GMT

Would you like Mealworms with that Sir?

Yes, you read that correctly... Following the endorsement by EU Member States in April 2021, a Regulation authorising dried yellow mealworm (the larvae of the beetle Tenebrio molitor ) as a novel food, will be adopted by the EC Commission in the coming weeks.

The eating of insects is not a new thing and in parts of the world insects are regularly eaten as an alternative source of protein, however this is the first insect to be approved as a novel food. The Novel Food Regulation helps food businesses to bring innovative foods to the market, whilst ensuring their safety. It concerns any food that has not been consumed ‘to a significant degree’ in the EU before 15 May 1997. This particular novel food is intended to be used as a whole, dried insect in snacks or as an ingredient in food products.

So is it safe?

Yes - Novel foods can only be authorised if they do not pose a risk to human health. The product has been through a stringent scientific assessment* by the European Food Safety Authority (EFSA) which concluded yellow mealworm was safe under the uses and use levels proposed.

Are there any health issues?

Potentially yes. EFSA found that the consumption of yellow mealworm may potentially lead to allergic reactions, particularly in people with pre-existing allergies to crustaceans and dust mites. Additionally, there may be a risk from gluten from the feed that the insects have consumed. This would be captured in any labelling on products that contain the insects.

Potential benefits

The FAO indicates that insects are highly nutritious and a healthy food source with high fat, protein, vitamin, fibre and mineral content, and are emerging as an alternative solution to animal protein. The consumption of insects is seen to contribute positively to the environment and to health and livelihoods. Insect-based proteins are considered a key area of research under the EU’s research and innovation funding programme ‘Horizon Europe’ which tackles climate change.

There are currently 11 additional applications for insects to be evaluated by EFSA, so it is possible we will see more being approved as novel foods.

14/05/2021

References :

* Safety of dried yellow mealworm (Tenebrio molitor larva) as a novel food pursuant to Regulation (EU) 2015/2283 https://efsa.onlinelibrary.wiley.com/doi/10.2903/j.efsa.2021.6343

Approval of first insect as Novel Food https://ec.europa.eu/food/safety/novel_food/authorisations/approval-first-insect-novel-food_en

Labelling food in the correct language - avoid penalties!

sjw.technical.ltd@outlook.com (Sarah Wolton) — Wed, 10 Feb 2021 17:16:50 GMT

UK Deli owner fined £1000 for not labelling products in English

10.02.2021

In the UK, it is an offence for retailers and wholesalers to supply food without English labelling. Regulation (EU) no 1169/2011 states that labels should be in a language easily understood by the consumers of the member states where a food is marketed.

Failure to comply with trading standards law can lead to enforcement action, as seen with a deli owner in Maidenhead this week where the owner was fined £1000 for selling products not labelled in English.

Here's a brief overview of the responsibilities of retailers and wholesalers when it comes to food labelling and language on pack.

Retailer Responsibilities

Retailers in England and Wales must ensure that the food and drink they sell displays the mandatory information required by law - this needs to be in English and appear either on a label (or attached to) the packaging, or on a label clearly readable through the packaging. Labels can also have additional languages when some of the consumers are likely to be non-English speakers.

Similarly, If you are exporting to an EU country, food labels need to be in the most appropriate language for the country you are selling to.

What about Wholesalers?

Wholesalers must ensure that the food they sell complies with the regulations if the packaging will not be changed or repackaged by the eventual retailer. For example , a wholesaler sells bottled drinks to retailers in trays, the bottles won't be repackaged or altered before reaching the end consumer. The bottled drink is therefore ready for delivery to the end consumer and must have the correct labelling in English.

Mandatory information can be supplied as described above for retailers or can be supplied on documentation provided previously or accompanying the food, however the below must appear on the external packaging:

Name of the food
Durability indication
Storage conditions
Business details

If you are considering importing food from outside the UK, you'll need to check that the labels comply with UK legislation. It is not yet known if future UK food legislation will continue to harmonise with EU regulations.

Are your labels compliant and in the correct language? If you are importing or exporting we can help you see through the Brexit haze!

*Disclaimer: The information presented in this article is a summary of key information from food regulations, and is for general information purposes only. All information is subject to change and is correct as of 10.12.2021.

Nutri-Score - could it help us to choose the healthy option?

sjw.technical.ltd@outlook.com (Sarah Wolton) — Tue, 24 Nov 2020 14:28:11 GMT

Germany rolls out 'Nutri-Score' front of pack nutrition labelling - who will be next?

23.11.2020

As another EU member state officially rolls out the ‘Nutri-Score’ front of pack nutrition labelling (FOPNL) scheme, would the UK benefit from adopting the scheme?

What is Nutri-Score?

Nutri-score is a front of pack nutritional label which converts the nutritional value of food and beverages into a simple score. The formula takes into account both the nutrients to limit (energy value, sugar, saturated fats and salt) and the values to favour (fibre, protein, fruit, vegetables and nuts). The scheme has a ranking system from -15 for the healthiest product to +50 for the least healthy, each product has a 5 letter code with its own colour.

Where is it used?

Nutri-Score was first developed in France in 2017, since then the Netherlands, Switzerland, Spain, Belgium and now Germany have adopted the scheme as their voluntary labelling scheme of choice. The scheme has also been trialled by some major retailers and food producers but is currently voluntary. The EC commission plans to harmonise mandatory front of pack nutrition labelling as part of its Farm-to-Fork food strategy, but no decisions have been made just yet.

Why use it?

The main objective of the scheme is to enable consumers to easily understand and compare information between products, helping them make the best choice for their health. You can see at a glance which products should be avoided and which ones are recommended.

There are however concerns from countries where traditional delicacies such as cured meats or olive oil are core products, as the Nutri-Score system would potentially penalise these products. Many of these products are known for their health benefits and are at the heart of diets such as the Mediterranean diet, so focusing on a limited number of 'bad' nutrients may put consumers off.

As most of us know healthy eating is all about balance along with lifestyle factors. Research carried out on consumers in the EU* suggested that Nutri-score has the potential to boost sales of healthy products, without affecting the sales of unhealthy products. It may however help consumers to eat smaller portions of those less healthy products.**

Should the UK use Nutri-Score?

At a time where the UK has the largest rates of obesity in Europe, and 62% of the UK is overweight perhaps now is the time to simplify our food nutritional labelling to help consumers shift to healthier diets. In July 2020, the government published a consultation on the UK's FOPNL to gain the public's views, this has now closed so we await the results...Watch this space!

References/further reading

*The Impact of the Nutri-Score Nutrition Label on perceived Healthiness and Purchase Intentions’ 2020 Appetite. Joyce De Temmerman et al. https://doi.org/10.1016/j.appet.2020.104995

** Impact of Front-of-Pack Nutrition Labels on Portion Size Selection: An Experimental Study in a French cohort' Nutrients 2018. Manon Egnell et al. https://doi.org/10.3390/nu10091268

How does Nutri-Score impact shoppers purchase intentions - www.foodnavigator.com/article/2020/10/29

The ABC of upcoming Food Labelling changes...Country of Origin (COOL)

sjw.technical.ltd@outlook.com (Sarah Wolton) — Tue, 17 Nov 2020 18:08:02 GMT

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.*

The ABC of upcoming Food Labelling Changes - Brexit

sjw.technical.ltd@outlook.com (Sarah Wolton) — Tue, 17 Nov 2020 17:46:55 GMT

26.10.2020

Following on from the first article in this series where we looked at allergen labelling for PPDS foods, we move on to the next topic... Brexit . As the UK draws closer to the end of the transition period on 31st December 2020 , a new labelling regime commences on 1st January 2021 . A number of changes will be necessary from this date, which we will go through in more detail.

EXPORTING TO THE EU

Key points:

Food of animal origin placed on the EU market before 1 January 2021 can continue to circulate within the EU market without labelling changes.
Food of non-animal origin placed on the UK or EU markets before 1 January 2021 can continue to circulate both in the EU and UK markets without labelling changes.
All food placed on the EU market from 1 January 2021 will have to meet EU rules.

In the 'Withdrawal Agreement' a product is ‘placed on the market’ in the EU when it is first supplied for distribution, consumption or commercial use, whether free of charge or not.

GOODS SOLD IN GREAT BRITAIN (GB) AND NORTHERN IRELAND (NI)

The guidance for food sold in GB and NI is subject to agreement with devolved administrations and Parliamentary process. Goods sold in NI will continue to follow EU rules for labelling, but some labelling changes may be required. Any required labelling changes for goods sold in GB will need to be made by 30 September 2022. Local authorities in GB will be responsible for enforcement of labelling changes.

LABELLING CHANGES - THE 5 KEY AREAS

Food Business Operator (FBO) address
EU Health and Identification Marks & EU emblem
Organic Products & Use of logo
Country of Origin Labelling
Protected Geographical Status Changes (GI) Logos

1. Food Business Operator (FBO) address

All pre-packaged products sold in the EU currently need the address of the responsible FBO to be printed on the product labels (as per regulation (EU) No 1169/2011). From 1 January 2021 a UK FBO address will no longer be suitable for UK origin products being sold in EU countries. If a UK based FBO is not established in the EU or NI, the name and address of the EU or NI importer must be indicated on the label.

You can continue to use an EU, GB or NI address for the FBO on pre-packaged foods or caseins sold in GB until 30 September 2022. From 1 October 2022, these products must include a UK address for the FBO, if the FBO is not in the UK, the address of the importer should be included.

Remember: A FBO address must be a physical address for the persons responsible for the labelling and must be contactable for any issues/consumer feedback - a PO box address in unacceptable.

2. EU Health and Identification Marks & EU emblem

The current UK/EC oval health and identification mark on products of animal origin (POAO) produced in the UK can be used until 11pm GMT on 31 December 2020. After this date a new default health and identification mark will need to be applied to POAO produced and placed on the market in GB, NI and exported outside of the UK.

Currently legislation is being proposed to allow a 21-month adjustment period for goods placed on the GB market, this is to allow UK businesses to manage existing label stocks that have the 'UK/EC' identification mark' on. The adjustment period will not be applicable for GB/NI products destined for the EU or non-EU markets. From 1 October 2022 the use of old labels/packaging will be unlawful. Further guidance on placing POAO on the NI market will be published shortly.

The EU emblem must not be used on goods produced in Great Britain (England, Scotland and Wales) from 1 January 2021, unless authorised by the EU to do so.

3. Organic Products & Use of Logo

Companies that produce, process, label or trade in organic food and feed in GB will have to follow GB rules from 1 January 2021. GB will recognise the EU as 'equivalent' for the purpose of trade in organics until 31 December 2021, all food registered as organic in the EU will also continue to be accepted as organic in the UK market up to this date. The EU will decide whether to accept food and feed registered in the UK as organic from 1 January 2021.

The EU organic logo must not be used on any UK organic food or feed from 1 January 2021 unless it has been authorised by the relevant control body, and if the UK and EU agree to recognise each other’s standards.

4. Country of Origin Labelling

Exporting to the EU

Food produced from GB must not be labelled as origin ‘EU’ from 1 January 2021. Food from Northern Ireland can continue to use ‘origin EU’ from 1 January 2021.

Goods sold in GB and NI

Food from and sold in GB can be labelled as ‘origin EU’ until 30 September 2022. After this date, food from GB must not be labelled as ‘origin EU’. Food from and sold in NI can continue to use 'origin EU' from 1 January 2021.

There are specific products where additional rules apply for products sold in GB and NI, if you need more information on labelling for minced meat, fruit and vegetables, olive oil, honey blends, beef & veal , and eggs look out for the next article.

5. Geographical Indication (GI) Logo

The EU protected food name scheme enables consumers to identify foods with clear regional provenance, after 1 January 2021 EU protection laws will no longer apply to UK related GI products. The UK will set up its own GI schemes which launch from 1 January 2021. UK schemes will protect the geographical names of food, drink & agricultural products, spirit drinks, wine & aromatised wine. There will be a 3-year transition period for producers to adopt the relevant UK logos (PDO, PGI, TSG), which will be available to download from 1 January 2021.

The UK logo will be mandatory for GB products registered from 1 January 2021 onwards . GI products that are protected in the EU can continue to use the EU logo in the UK after the transition period. Products sold in NI will need to use EU logos if the product is registered under the EU GI schemes, but it is optional to use the new UK GI logos if the product is registered under UK schemes.

*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, correct as of 26.10.20.*

The ABC of upcoming Food Labelling Changes

sjw.technical.ltd@outlook.com (Sarah Wolton) — Tue, 17 Nov 2020 17:13:07 GMT

13.10.2020

Food legislation is constantly evolving, but recently there have been 3 specific areas that have dominated changes in UK/EU food labelling. This series of articles will aim to inform you of the latest changes that may affect your products and what you need to do to comply.

So what will be covered in the ABC of food labelling changes?

We'll look at A llergen Labelling (PPDS), B rexit, and C ountry of Origin Labelling.

ALLERGEN LABELLING FOR 'PREPACKED FOR DIRECT SALE FOOD'

When is it happening? 1st October 2021

Food labelling requirements for prepacked for direct sale food will change from 1st October 2021 in England, Wales and Northern Ireland**. The change in law follows the death of Natasha Ednan-Laperouse who had an allergic reaction to a baguette that didn't have allergen labelling on pack (as it was not required by law at the time). The latest law changes will help protect food hypersensitive consumers by requiring more types of food to have allergen information on the labelling.

What are 'Prepacked for direct sale (PPDS) foods'?

PPDS foods are products which are packaged at the same place they are offered to the consumer. It includes food that is packaged before the consumer selects or orders it, it can include food that customers pick themselves as well as pre-wrapped products that are kept behind the counter.

Examples of PPDS:

Sandwiches packaged by a food business and sold/offered from the same premises
Fast food - wrapped or packaged before a consumer selects/orders it
Bakery products - packaged before a consumer selects it
Supermarket products which are produced and packaged in store i.e. pizzas, pre-weighed/packed cheese & meats, rotisserie chicken, baked products
Free samples of cakes if they are packaged at the premises
Food packaged and sold on a market stall (if sold by the same business)
Food packaged by a butcher i.e. burgers or sausages on the premises for sale

What information will be required on PPDS food labels?

Pre-packed for direct sale food will need to have a label showing the name of the food and a full ingredients list with any of the 14 allergenic ingredients mandated by legislation that are present in the food emphasised in the ingredients list.

** Applicable Legislation:

The Food Information (Amendment) (England) Regulations 2019 (SI 2019 No. 1218)

The Food Information (Wales) (Amendment) (No.2) Regulations 2020 (2020 No. 80)

The Food Information (Amendment No. 2) Regulations (Northern Ireland) 2020 (2020 No. 80)

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