101 UK Brexit Notes
Connemara Programme October 16 2018 pg. 81 Addresses on food labels For pre-packed products sold in the UK, the label would need to include the name and a UK address of the responsible food business operator. The food business operator is the business under whose name the food is marketed in the UK or, if that operator is not established in the UK, the importer of the product into the UK. An EU address alone would no longer be valid for the UK market. Similarly, a UK address alone would no longer be valid for the EU market and an address within the remaining EU member states will be required following EU exit. A UK address together with an EU address on the label would mean that the label is valid for both the UK and EU markets. For example, a business based in France but selling products in the UK can currently provide its name and address in France on products sold in the UK. In a ‘no deal’, the business would need to provide the address of a responsible business in the UK by, for example, setting up a UK hub or working with an importer. A food business in the UK selling pre-packaged food in France can currently provide the address of the business in the UK. In a ‘no deal’, the business would need to provide an address for the responsible business or importer into the EU, in one of the remaining EU member states. In order to mitigate the immediate impacts of these changes, in particular on UK food retailers selling food originating in the EU, we will consult with stakeholders on an option to continue to allow, for a period of up to 6 months following a no-deal exit from the EU, food bearing an EU address to be placed on the UK market. In addition, for foods already labelled and placed on the UK market bearing an EU27 address, these will be allowed to be sold through until stocks are exhausted. We will be working with businesses and local authorities, who are responsible for enforcing labelling standards, to support adjustment to any necessary changes. Natural Mineral Waters Natural Mineral Waters (NMWs) currently undergo a specific recognition process in order to be able to be marketed across the EU. Each country carries out this recognition as stipulated in the EU rules in Directive 2009/54/EC. We will amend our domestic regulations to ensure the rules on natural mineral waters can continue to operate. This means the status of NMW recognitions granted by all nations of the UK would still be recognised across the UK, and UK NMW producers would not need to renew their recognition in the UK internal market. We will also amend our current domestic regulations to ensure in a no deal scenario we would be able to make our own decisions on the recognition of both existing and future NMWs recognised by the EU. The UK government will set out more information and options in a full public consultation. NMW producers should take note that natural mineral waters recognised in the UK may no longer be accepted as such in the EU (please see stakeholder notice by the Commission on 23 January 2018 to that effect). In the event of ‘no deal’, UK NMW producers need to be prepared to apply for recognition of their water through an EU member state after the UK leaves the EU. These applications will be treated as third country applications and be processed in the same way as third country applications for third country NMWs are processed now.
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