Windsor Framework Defra Guidance
Windsor Framework Defra Guidance published on 9 June 2023 ahead of a phased roll out for additional food labelling requirements in force from 1 October. The Windsor Framework - further detail and publications - GOV.UK (www.gov.uk)
The implementation of the Framework will happen in stages through into 2025.
Some arrangements are already in force. On 1 May 2023 a temporary VAT zero-rate was introduced in Northern Ireland for the domestic installation of solar panels, insulation, heat pumps and other energy saving materials
From 30 September/1 October 2023, the new sanitary and phytosanitary “green lane” arrangements will take effect: including a new Retail Movement Scheme for agrifood retail products; new rules to allow plants to move smoothly in to Northern Ireland; and new arrangements to enable seed potatoes to move once again from Great Britain to Northern Ireland.
From September 2024, the full “green lane” will take effect for the movement of all goods between Great Britain and Northern Ireland
Agrifood retail products into Northern Ireland are currently supported under the Scheme for the Temporary Agrifood Movements to Northern Ireland (STAMNI). This will be replaced in October 2023 by a new scheme, the Retail Movement Scheme. This will be available to a much broader range of traders, removing checks and complex certification requirements, and enabling goods made to UK public health standards to be moved.
Formal registration for the new scheme will be launched in September 2023. In the meantime, traders are able to register their interest through a pre-registration process. The STAMNI scheme will remain in operation until these new arrangements enter into force. All existing members of the STAMNI scheme will be contacted directly regarding moving seamlessly to the new scheme.
Labelling
Under the Retail Movement Scheme some food products will need individual product labels with the words ‘Not for EU’. These requirements will be brought in through 3 phases from October 2023 to July 2025.
Phase 1
From 1 October 2023 all meat products and some fresh dairy products that are moving from Great Britain to Northern Ireland will need to be individually labelled.
In the first phase, only products moving into Northern Ireland under the Retail Movement Scheme will need to meet the labelling requirements. From phase 2, the government intends to introduce labelling requirements for Great Britain (England, Scotland and Wales).
Phase 2
From 1 October 2024, in addition to the phase 1 products, all milk and dairy products moving to Northern Ireland under the Retail Movement Scheme will need to be individually labelled.
At this stage, all meat and dairy products in Great Britain (England, Scotland and Wales) would also need to be individually labelled.
Phase 3
From 1 July 2025, composite products, fruit, vegetables and fish moving to Northern Ireland under the Retail Movement Scheme will also need to be individually labelled. The same products in Great Britain (England, Scotland and Wales) would also need to be individually labelled.
Not all products moved under the Retail Movement Scheme need to be individually labelled.
Exemptions include products sold loose or by weight on the sales premises at the consumer’s request, products processed and sold on the sales premises by a retailer, for direct consumption, products for sale in a factory canteen, institutional canteen, restaurant, or other similar food service operators that are intended for eating on the spot in Northern Ireland, Shelf-stable composite products. Products that meet UK public health standards; and those not requiring certification or controls at agri-food points of entry under the Official Controls Regulation, including tea, sugar, jam, wine, cereals, processed or canned fruit and vegetables.
Also, if products are individually labelled, you will not need to label the box, nor provide appropriate signage.
The government has allowed for a 30 day transitio period at the start of each phase, which neans that goods that are already on the market will not need to be re-labelled and will be able to be sold during that period.
In addition to the labelling changes, Defra also revealed some green lane processed products of animal origin (POAO) goods will need a export health certificate, albeit more simplified.
The government has so far said that “movements will use a single General Certificate” rather than multiple certificates, but further details on this EHC are still to come.
Opinion –
This is an enormous change that has been undertaken with very little consultation for industry and one that will be resource intensive for a sector that already has been under pressure. The time line before additional labelling is required is likely to mean an amount of product using the red channels in any event.
Industry opinion is already strongly that a ‘not for EU’ labelling on a GB-wide basis is unnecessary and will fail to deliver any practical benefits for shoppers or businesses. Instead, it is likely to increase costs, and undermine exports and investment.
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