After implementation of the EU Transition Programme (30 September 2022), regulation is likely to further change and adapt – especially regarding food labelling. For now, aside from removing EU institutions and schemes from labelling authentication processes, EU rules still apply. 

Compliance with regulation such as organic logos or health and identification marks for food products of animal origin should be complied with as prior to Brexit. Post Transition Programme rules on labelling and identification marks should be noted as compliance with old regulation will then be unlawful and re-labelling will be required.

Came into effect in 2021, still relevant in 2022 as the impacts of Brexit manifest

The UKCA mark is relevant for goods sold in the EU. Labels with the UKCA mark can be added until 1 January 2023; after that the mark must be directly on the product. Different rules will apply in Northern Ireland.

A manufacturer intending to sell in GB and the EU will need two separate marks and conformity assessments as the EU will not recognise the UKCA or GB conformity assessment. 

A single identity product may need to be differently tested and labelled. This will result in changes such as production lines variations, multiple packaging orders, different conformity documentation and additional promotion/advertising/ specifications will be required. Long term impacts may include new distributor contracts in the EU or setting up an EU entity.

All products placed on the EU market must continue to comply with EU rules. Food from and sold in GB can be labelled as ‘origin EU’ until 30 September 2022. From 1 October 2022, food from GB must not be labelled as ‘origin EU’.

Regulation of product origin labels will change following the EU Transition Period. British food, drink and agricultural products must display the new geographical identification logos from 1 January 2024.

The UK Government will launch a public enquiry to investigate the impacts, pitfalls and potential successfully handled aspects of the COVID-19 pandemic to inform Government decision-making and strategy going forward. 

Scotland will have its own enquiry in late 2021/early 2022.

Participation in the enquiry is encouraged as an opportunity to feedback on the impacts and experience of the pandemic on business.

Government and public health bodies continue to issue health and safety requirements and guidance to protect workplaces and minimise the impacts of COVID.

Comply with any legal requirements and consult guidance to inform best practices in regards to health and safety. If and when the pandemic eases, expect enforcement of BAU health & safety requirements to ramp up.