Food Labelling and Brexit
Foods placed on the EU market must comply with EU food law. The rules for labelling are set out in Regulation (EU) No. 1169/2011 on the provision of food information to the consumer. Visit our labelling legislation section for information on the general labelling requirements.
From 1 January 2021, if you import food from Great Britain you will need to comply with the requirements for placing imported food on the Irish market. Here are some questions that food businesses have asked us.
Do prepacked foods have to provide an EU address?
Yes. Regulation (EU) No. 1169/2011 specifies that the provision of the name and EU address of the food business operator responsible for the food within the EU is required. This name and address must be either:
- the operator in the EU under whose name or business name the food is marketed or
- if that operator is not established in the EU, the name and address of the importer into the EU market must be indicated on the label.
What about a UK address ?
From 1 January 2021, a UK address will not comply with the legislation as the operator whose name or business name the food is marketed is no longer in the EU. Therefore, the name and address of the importer into the EU market must be indicated on the label.
What about a Northern Irish address?
For food labelling purposes, the address of a food business operator established in Northern Ireland will continue to be accepted as an EU address. Under the terms of the Protocol on Ireland and Northern Ireland at the end of the transition EU food law will continue to apply to and in Northern Ireland.
Can an EU and a non-EU address appear on a food label?
A non-EU address can be indicated on the label in addition to but not in place of the EU address. The inclusion of this additional address on a label must not hide, obscure, detract from or interrupt the mandatory EU address.
Can I use a web address?
The address provided must be a physical address within the EU. A web address or email can be included in addition to the physical address.
Will Brexit affect origin labelling?
For products that require origin labelling e.g. honey and primary ingredients you will need to consider that following the transition period, the UK will no longer be EU for origin labelling. Therefore, for example if you currently label your honey ‘blend of EU honeys’ where it contains EU and UK honey then the label will need to be changed to ‘blend of EU and non-EU honeys’.
Who is responsible for food information on a label?
The food business operator responsible for food information is:
- the operator under whose name or business name the food is marketed or
- if that operator is not established in the EU, the importer into the EU market
The ‘responsible’ food business operator in the EU 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.
What about food placed on the market before the end of the transition period?
Food of non-animal origin that was lawfully placed on the EU or UK market before the 1 January 2021 can be made available on the EU or UK market and circulate between these two markets after the transition period.
Example: An individual food (of non-animal origin) sold by a UK-based producer to a UK based wholesaler before the end of the transition period can still be imported further into the EU without the need for re-labelling to indicate the name or business name and address of the EU importer.
This is only relevant to foods of non-animal origin e.g. drinks, deserts, confectionery, beverages etc. For food of animal origin e.g. meat, fish, milk, eggs, honey or foods containing these as an ingredient, this provision does not exist and therefore foods of animal origin have to comply with EU food law as of the end of the transition period, no matter if the food of animal origin had been placed on the UK market before the end of the transition period.
Further information is available in the EU food law notice.
Last reviewed: 1/1/2021