As we approach the 31st October, we thought it would be a good idea to provide you with some details on what it means to packaging claims for the UK following BREXIT.
Although law has been passed that says we cannot leave the EU without a deal, at present we don’t know what could happen. So, here are some details of what you need to be aware of, if we do leave without a deal.
BREXIT without a deal – exported products
Any products exported from the UK will no longer, with immediate effect, be allowed to use on the packaging the following:
- Any EU logos, including EU organic logos
- The EU healthmark
- A UK Address as main contact only
- Any EU terms which refer to the UK as being part of the EU, such as ‘Made in the EU’
Product claims must use the UK equivalent replacements for each instead:
- EU organic logo
You can replace the EU organic logo with a UK organic certification logo. However, a UK alternative will not be allowed unless it is approved and accepted by the EU (which we’re unclear about at the moment).
- The EU logo
This will not longer be allowed, under any circumstances and therefore there is not alternative and it must be removed from the packaging all together.
- The EU healthmark
You will need to remove reference to the EU on the healthmark and replace it with you GB, UK or United Kingdom. The health mark must be an oval mark at least 6.5 cm wide by 4.5 cm. Letters must be at least 0.8 cm high and figures at least 1 cm high.
- UK address
You now need to replace (or add as well) an address in the EU, for customers to contact.
- Made in the EU
This claim now needs replacing with something like ‘Made in the UK’.
You need to make sure that your company’s UK EORI code (Economic Operator Registration and Identification number), which is the number generated by HMRC – is on the invoice so it’s traceable.
BREXIT without a deal – products that are sold in the UK and not exported
All claims for products made in the UK and sold only in the UK (and therefore, not exported) have to follow the same rules as above, however there will be a 21-month transition period based on the European Union (Withdrawal) Act 2018.
BREXIT with a deal – exported products
As we don’t know what the deal may look like, we can only speculate about it. It is expected that we will be given a set amount of time to phase out the old packaging and update the claims, in line with the information above.
We can use the following for an agreed set amount of time:
- EU logo,
- EU reference on healthmarks and
- EU organic logos
Other benefits (which have not been agreed or discussed with the public)- we will have to wait for parliament to announce them.
BREXIT with a deal – products sold in the UK and not exported
This is the same as the conditions if we leave the EU without a deal. We have to follow the same rules as above, and there will be a 21-month transition period based on the European Union (Withdrawal) Act 2018.
If you haven’t started to get your packaging changes in place, you don’t have much time left. The worst case scenario being that we leave the EU at the end of the month without a deal, if you’ve not updated your packaging to meet the above requirements, it could be deemed illegal and stopped at the EU border. If you are concerned about your packaging and would like any help to update it, we would be happy to help. Please just get in touch. If you have any further insight into this, that you would be happy to share, please help your fellow techie’s and add it to the reply box below.
If you would like to look at the resources we are using, here is also a list of links you may find useful:
We've tagged this article as: Product labelling legal labelling
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