Navigating the Future of UK Food & Drink Labelling and Packaging

Donal Denvir - Manager UK, Global Business Development

The landscape of UK food and drink packaging and labelling regulations has been evolving at pace, particularly in the wake of Brexit. Recognising the importance of staying abreast of these developments, over 120 Irish suppliers registered for Bord Bia’s recent webinar, which delved into the forthcoming modifications to labelling and packaging requirements within this crucial market.

Donal Denvir, General Manager of Bord Bia UK was joined on the webinar by Siobhan King-Hughes, Director of Supply Chain and Trade at PerformanSC Supply Chain and George Atkinson, Head of Policy at Valpak for an overview of some key changes impacting Irish suppliers this year. The speaker presentations were followed by a lively audience Q&A session.

Donal began by referencing the long-awaited and newly-drafted Target Operating Model (TOM). Some key points are the pre-notification of imports on UK Sanitary and Phytosanitary (SPS) system (IPAFFS) will apply to all Irish SPS goods from 31 Oct 2023, also from 31 Oct health certification for imports to GB from EU will apply to a wider range of goods. The final version of the TOM is due in June, where we expect to see more information on implementation dates for Border control Post SPS entry controls for Irish goods moving to GB. Bord Bia will be following up with more information as it becomes available.

Siobhan King-Hughes presented several crucial considerations for food and drink product labels that Irish suppliers must prepare for this year. Effective 1st January 2024, all pre-packaged Irish food and drink products intended for the UK market must display a UK address on the label for market surveillance purposes. This address may belong to an importer or an authorized representative. For non-prepacked foods, the same information must be included in the accompanying documentation. Siobhan proceeded to examine various address options for Irish producers and the factors to consider for each alternative. Furthermore, she reminded attendees that the "EU/Non-EU" phrasing on labels, utilized for products requiring origin information, will no longer be valid from January 1, 2024. Instead, the appropriate designation to use will be "UK/Non-UK."

George Atkinson delivered a comprehensive analysis of the Extended Producer Responsibility (EPR) framework in the United Kingdom, detailing the rationale behind its evolution and the implications for various stakeholders along the supply chain. The presentation included a timeline of EPR's development, as well as a delineation of the obligated parties and the forthcoming changes in responsibility. Under the new EPR system, the obligation will shift from the current multi-party responsibility model—encompassing manufacturers, converters, packer/fillers, and suppliers—to a single-party responsibility model, which will involve brand owners, importers, online marketplaces, fillers, or distributors. This 100%, single-party responsibility for reporting packaging data is expected to commence in late 2023, with waste management fee payments beginning in 2024. Exemptions will be available based on turnover and the volume of packaging supplied. It is strongly recommended that Irish suppliers carefully examine their potential obligations under the new EPR framework.

George also addressed the financial implications of the new system. Retail brand owners may experience a significant increase in expenses related to household packaging, potentially seeing a sevenfold rise in costs. Meanwhile, brand owners of household packaging not sold directly to consumers could face an even more dramatic escalation, with costs potentially increasing tenfold.

Additionally, George highlighted the forthcoming Scottish Deposit Return Scheme (DRS). Although the implementation of this scheme has been deferred to March 2024 since the webinar, it is crucial for Irish suppliers to be aware of its impending arrival. Moreover, a deposit return scheme is being planned for the remainder of the United Kingdom; however, the timeline for its execution is more protracted, and there are currently variations between the constituent countries of the UK.

George's concluding slide serves as a convenient checklist for Irish suppliers as they ready themselves for the forthcoming EPR regulatory changes in the United Kingdom.

This summary is just a flavour of the information-packed webinar, for more details please follow the link below to a recording of the webinar and a link to the accompanying presentation slides.

References:

Bord Bia Webinar “Changes to UK Food and Drink Labelling and Packaging: https://www.bordbia.ie/industry/events/past-events-presentations/speaker-presentations-2023/changes-to-uk-food-and-drink-labelling-and-packaging/

PerformanSC Supply Chain: https://performansc.com

Valpak: https://www.valpak.co.uk/

Scottish DRS postponed: https://depositreturnscheme.zerowastescotland.org.uk/

TOM -Bord Bia News https://www.bordbia.ie/industry/trading-with-uk/news-and-events/news/breaking-news--uk-govt-issues-target-operating-model-tom-update/