Understanding Food Labelling Under the Windsor Framework

If you move agrifood products from anywhere in Great Britain (i.e. England, Scotland, or Wales) to Northern Ireland, you need to understand the requirements of the Windsor Framework.

Adopted by the UK on 24^th March 2023, it introduced a system of 'green' and 'red' lanes for importation control.

For agrifood goods from other areas of the United Kingdom entering and intended for consumption in Northern Ireland, the green lane has simpler paperwork and checks under the Northern Ireland Retail Movement Scheme (NIRMS).

The red lane, where full control checks are in place, is reserved for goods bound for the Republic of Ireland, or elsewhere in the European Union (EU).

Replacing the Northern Ireland Protocol, the Windsor Framework aims to safeguard food supplies to Northern Ireland and has two key benefits:

• A simplified process with reduced documentation.
• Reduced costs for moving agrifood goods from other parts of the UK to Northern Ireland.

For clarity on UK Government guidance and the labelling requirements of the Windsor Framework, we asked Mabel Hove, Specifications Technologist at NSF, to answer some frequently asked questions:

Replacing the Northern Ireland Protocol, the Windsor Framework makes the movement of goods to Northern Ireland from other parts of the UK easier.

For agrifood goods destined for consumers in Northern Ireland, the label should clearly indicate ‘Not for EU’ to prevent the onward movement of those goods into the Republic of Ireland or elsewhere in the European Union.

Meat and some dairy products were included in Phase 1 of the agreement from October 2023.

All milk and dairy products will need to comply in Phase 2 from 1^st October 2024, and more products in Phase 3, coming into effect from 1^st July 2025.

Under the scheme, businesses can move goods that are produced to UK public health and safety standards. For example, goods containing the additive titanium dioxide (banned in the EU) can be moved to Northern Ireland from other parts of the UK.

Where relevant, these goods will still need to meet EU standards on animal and plant health diseases. Products imported into Great Britain from the European Union, and products from the rest of the world can be moved under terms of NIRMS.

Comprehending and complying with regulations can be challenging, particularly for businesses targeting both the UK and EU markets. Differentiating between products labelled "Not for EU" and those intended for the EU market is crucial. Businesses that export products to the EU need to establish different production lines to be able to label goods correctly.

The labels can be written, printed, stencilled, marked, embossed, impressed on, or attached to the product. The labels can be adhesive labels (stickers) or sticky tape, and they must not be easily removable.

The label must be easy to see, clear to read, and unlikely to fall off or be removed. It should not be hidden or covered by any other writing or pictures.

Phase 3 products are required to have a label on the box or crate until 1^st July 2025 when they will need individual labelling.

Retail premises in Northern Ireland are required to apply labels on shelves for products that are not currently individually labelled and have been moved under the NIRMS terms. There must be clear visibility to customers that the goods are not to be moved, sold to or consumed within the EU.

Yes, complexities exist, especially for businesses supplying multiple markets. Ongoing interpretation of the requirements and expert advice is vital.

For example, a business that supplies catering premises was moving food from elsewhere in the UK to Northern Ireland, and to the Republic of Ireland.

They were confused about how to implement the ‘Not for EU’ labelling.

With expert guidance from NSF, their products were labelled in accordance with both EU and UK requirements. As they aim to continue supplying the same goods to both markets, their products are not moved via the green lane and therefore ‘Not for EU’ labelling is not required.

It is important to note that only goods moved to Northern Ireland under the NIRMS terms need to meet these labelling requirements. If products are moved via the red lane and intended for onward movement to the EU, they do not require ‘Not for EU’ labelling. These products should comply with EU public health or consumer protection standards and all EU labelling requirements.

Catering operators do not need to label shelves for food products that are intended for consumption ‘on the spot’ in Northern Ireland. They also do not need to display posters next to these food products.

A full list of products that are exempt from individual labelling can be found on the gov.uk website.

While it aims to streamline the movement of food, there may be increased costs for manufacturers to meet labelling requirements. A proactive approach and ongoing consultations aim to minimise disruptions for consumers.

Consumers may be confused by a ‘Not for EU’ label, as it could suggest the food standard is not sufficiently high for the EU market. However, apart from a few exceptions, UK food standards are largely based on the assimilated EU regulations. ‘Not for EU’ labelling does not mean a product is of lower standard.

For consumers in Northern Ireland, it is a positive move as this ensures they have the same access to goods that are available to consumers elsewhere in the UK.

Regular updates and summaries will be added to this article as they arise to ensure you stay informed and compliant as the framework evolves.

The consultation for the proposed new regulation ‘The Marking of Retail Goods Regulations 2024’ ended on 15^th March 2024.

As of 30 September 2024, the UK Government has confirmed that it will not proceed with the mandatory introduction of ‘not for EU’ labelling in Great Britain, which was initially planned to start on 1 October 2024. This decision was made after careful consideration of the consultation and engagement with businesses. The government will continue to monitor the supply of agri-foods into Northern Ireland and may apply ‘not for EU’ labelling in the future if necessary.

Phase 2

1^st October 2024: Phase 2, ‘Not for EU’ individual labelling required for all milk and dairy products going into Northern Ireland under the terms of NIRMS.

Phase 3

1^st July 2025: Phase 3, ‘Not for EU’ individual labelling will be required for composite products, unprocessed fruits & vegetables, fish, eggs, honey, and pet food.

Composite products are those that contain both plant origin and processed products of animal origin for human consumption, for example, pizza. Note that products such as yoghurt with fruit are dairy products that come under Phase 2.

Mabel Hove

Food Technologist, Regulatory and Labelling Consulting, NSF

Mabel has over 17 years of experience in food labelling, specifications management, artwork, and regulatory compliance. Her expertise supports clients throughout the entire product lifecycle, from raw material compliance to final artwork approval.

She has successfully collaborated with major international food retailers and manufacturers to launch products in the UK and EU markets. Mabel holds a BSc in Food and Nutrition.