No-deal Brexit creates potential labelling nightmare

The Brexit timer is ticking and what progress have we made since the fateful referendum on 23rd June 2016?

Honestly, not much has changed. Since then, the government have been pitching and rejecting Brexit deals left, right and centre and the leading parties are currently disintegrating from within.

Where does this leave you in the Food industry?

Well, we’re sat here in the state of a ‘no-deal’ and we’re just over one month away before Brexit is supposedly going to be pushed through. Defra have recently announced there will be new guidance on food labelling in the event of a no-deal and there is a huge potential impact on meat, fish and dairy suppliers across the Food industry along with other retailers and manufacturers.

What changes must you make to comply with the new guidance?

From Friday 29th March 2019:

• EU Organic logo: Cannot be used on any UK organic products unless the UK and EU reach an equivalency agreement  
• EU emblem: Must not be used on UK goods unless authorised by the EU
• Pre-packaged food and caseins sold in the EU: Must include an EU address for the food beverage operator or EU importer
• Country of origin labels: It will be inaccurate to label UK food as origin ‘EU’. The government are set to take a ‘pragmatic’ approach to enforcing this rule for foods sold in the UK

By Tuesday 31st December 2019:

• EU health and identification marks: Must be replaced with new UK health and identification marks
• Pre-packaged food and caseins sold in the UK: Must include a UK address for the food beverage operator or importer
• Country of origin labels: Any reference to ‘EU origin’ must be replaced with ‘UK origin’

Wait, do I really need to adhere to all this in the case of a no-deal?

If you export meat, fish or dairy products to the EU or other countries you will have no choice but to use the new marks, as confirmed by the FSA in the event of a no-deal. Primarily, because the UK will lose all entitlement to use any abbreviation on health or identification marks that implies a membership to the EU.

However, the FSA have only recently written to industry and proposed what the new identification for health marks will look like. Chief Operating Officer at the FDF, Tim Rycroft told the Grocer: “There seems to be EU reluctance to accept the new design developed by Defra. This is a major concern for suppliers.”

Even if the new safeguards of the UK logo are approved, UK businesses will only be able to export to the EU if they are certified by an organic control body recognised and approved by the EU. To do this, UK bodies will have to apply to the European Commission for recognition, but that process may take nine months and they can’t officially apply until the UK is a ‘third country’.

So, what on earth can you do if we reach a no-deal?

Everybody is in the unknown, but it would be worth noting that the FSA may be getting in contact with you very soon to tell you all about these new identification marks. There is no harm in creating an emergency plan… if only the government had thought of this.

We know that businesses across the Food industry will need time to work through old packaging stocks due to historic minimum purchase orders that are made to keep costs down. Having to get rid of all this packaging will create a monumental cost to the environment and industry.

Within our Dynamics Food solution powered by Dynamics 365 Business Central (formerly Dynamics NAV), you can directly create a report with the details and layout you need and then print this report on a label printer. All of this, with the same ease that would be involved with amending a Word document.

Brexit has been a borderline farce since the referendum, but we don’t want any business across the Food industry to be caught cold by the new potential labelling changes. Let’s cross our fingers that they strike a deal soon and be mindful of the incoming changes in the event they fail to even get that far.