101 UK Brexit Notes
Connemara Programme October 16 2018 pg. 80 Business: Labelling: Food Purpose This notice sets out how labelling of food and compositional standards (minimum standards for certain types of key foods) would be affected if the UK leaves the EU in March 2019 without a deal. It sets out the actions food businesses would need to consider to continue to comply with food compositional standards and labelling legislation. Before 29 March 2019 Food labelling and compositional standards exist to maintain consumer confidence and a level playing field for businesses. Labelling Labelling rules ensure consumers have easy access to the information they need to make an informed choice on which food to buy and eat. For example, all pre-packaged food must have a name that accurately describes the product. Multi-ingredient food must have an ingredients list with allergens highlighted. These labelling provisions are set out primarily in EU Regulation 1169/2011 on the provision of Food Information to Consumers (plus the related Implementing Regulation 1337/2013 on the country of origin of certain meats). Compositional standards Compositional standards lay down minimum standards for certain types of foods, for example honey, jam, chocolate products, sugars, instant coffee, bottled waters and fruit juices. These laws provide a level playing field for producers of these commodities and ensure minimum quality standards are maintained. The EU-based rules on compositional standards are set out in the following sets of English regulations: the Jam and Similar Products (England) Regulations 2003 the Natural Mineral Water, Spring Water and Bottled Drinking Water (England) Regulations 2007 the Spreadable Fats (Marketing Standards) and Milk and Milk Products (Protection of Designations) (England) Regulations 2008 the Honey (England) Regulations 2015 the Coffee Extracts and Chicory Extracts (England) Regulations 2000 the Fruit Juices and Fruit Nectars (England) Regulations 2013 the Condensed Milk and Dried Milk (England) Regulations 2015 the Cocoa and Chocolate Products (England) Regulations 2003 the Specified Sugar Products (England) Regulations 2003 the Caseins and Caseinates (England) Regulations 2017 In addition, there are domestic (non-EU) rules for England on compositional standards regarding products containing meat, and bread and flour. Equivalent regulations for all of the above exist for Scotland, Wales and Northern Ireland. After March 2019 if there’s no deal The UK government will maintain our current world-leading set of standards on food safety, food labelling and food quality, ensuring high food standards at home and promoting high standards internationally. Initially, the EU-based provisions would all be rolled over, as part of the Withdrawal Act, and fixed where necessary by statutory instrument so the rules apply as before. However, some changes would be required to reflect the fact that the UK will no longer be a member of the EU. Where the UK has its own compositional standards that do not stem from the EU, such as specific national rules on products containing meat and the composition of bread and flour, these would remain unchanged. Labelling the origin of food Use of the term ‘EU’ in origin labelling would no longer be correct for food or ingredients from the UK. Some products will require further changes. For example, labels of honey blends from more than one country referring to the EU would be replaced with more appropriate terminology. We would replace the requirement for EU/non EU blended honey indications with ‘blend of honeys from more than one country’ or similar wording in the domestic honey regulations. In addition, from April 2020, the country of origin or place of provenance of the primary ingredient of a food (where different to that given for the food overall) will be required on labels as part of EU rules on food labelling. The government may seek views on whether similar national rules would be appropriate in the UK when EU rules no longer apply.
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