Exports Labelling
What you need to know
Under the Windsor Framework, it was announced that the Northern Ireland Retail Movement Scheme (NIRMS) would be rolled out to allow products to move more smoothly into NI from GB via a fast-track process (referred to as Green lane/NIRMS).
To prevent these products from entering the EU market without undergoing full regulatory checks from NI (having avoided the more rigorous checks of the non-NIRMS or “Red Lane”) the decision was made to add a “Not for EU” label to goods placed on the NI market via Green Lane/NIRMS.
Initially, the labelling applied only to NI. To avoid placing a unique burden on GB producers, the UK Government proposed extending the requirement across the UK.
Following industry feedback and a formal consultation, the UK Government decided not to proceed with the GB-wide rollout. As a result, the “Not for EU” label is only required for goods moving from GB to NI under NIRMS.
Phased Rollout Timeline
The plan was a rolling plan in 3 phases for different categories of goods/different jurisdictions from Oct 2023-July 2025
Phase 1 - Oct 2023, with certain goods (all meat, some dairy) going to NI from GB being individually labelled.
Phase 2 - Oct 2024, includes all phase 1 products plus ALL milk and dairy. This phase applies only to goods moving from GB to NI.
Phase 3 - July 2025, is for Phase 1 & 2 products plus composite products, fruit, vegetables and fish. This phase applies only to goods moving from GB to NI.
The current Guidance and details of the 3-phase rollout can be found here:
Note the text at end of page “This requirement includes products imported into Great Britain from the European Union, including Ireland or certain products from the Rest of the World.”
Please note that different products are affected in different phases, and some products are exempted entirely (see exemptions here: https://www.gov.uk/guidance/labelling-requirements-for-certain-products-moving-from-great-britain-to-retail-premises-in-northern-ireland-under-the-retail-movement-scheme#exceptions-food-products-that-do-not-need-individual-labels)
Change of Government
A new UK Government took office in July 2025. While some decisions are still pending, the current guidance remains in place: products moved from GB to NI under NIRMS must be labelled “Not for EU”. Exporters should continue to follow the phased rollout unless new information is published.
Conclusion: “Not for EU” labelling is not mandatory for goods placed on the GB market. However, if products are intended for the Northern Ireland market or could move onward to NI, “Not for EU” labelling may become relevant.
The importer or Food Business Operator takes responsibility for the information contained on the food label.
Until 31 Dec 2023, an EU address may be used on product labels on the market in the UK.
From 1 Jan 2024, all pre-packed food or caseins on the GB market must include a UK address for product sold in GB.
Products sold in NI must have either a NI address or an EU address.
From 1 Jan 2024, all pre-packed food or caseins on the GB market must include: the name of the business whose name the food is marketed under
• The address of the business that has imported the food
• The address must be a UK address for product sold in GB.
Products sold in NI must have either a NI address or an EU address.
Until 31 Dec 2023, an EU address may be used, but after this date the label must include a UK FBO address, or a UK Importer address.
Health marks are oval stamps that must be applied to certain food products of animal origin (POAO). EU health marks will no longer be recognised in the UK. EU health marks must be replaced with new UK health marks. However there is a transitional period up to 31 December 2023. This will allow UK businesses to deplete existing stocks of labels, wrapping and packaging carrying the ‘UK/EC’ identification mark owned by the food business operator at the end of the Transition Period.
The provision is available to UK food businesses for POAO placed on the market in Great Britain. It is not applicable to POAO produced in the UK for placing on the EU, Northern Ireland or non-EU markets.
It is not intended to enable businesses to replenish stocks of labels, wrapping and packaging carrying the ‘UK/EC’ identification mark after the end of the Transition Period. Businesses are encouraged to adopt the new markings as soon as possible once the Transition Period ends.
The provision started from 1 January 2021 and is available for food businesses up to 31 December 2023. After this date, the use of stocks of labels, wrapping and packaging with the ‘UK/EC’ identification mark will be unlawful.
Identification marks are oval stamps that must be applied to certain food products of animal origin (POAO). EU identification marks are no longer recognised in the UK. A transition period has been in place since 1 January 2021 and has been extended to 31 December 2023. From this date, EU identification marks must be replaced with new UK identification marks.
EU law on Geographical Indicators (GI’s) no longer apply in the UK. The UK authorities ask that you apply for their own GI scheme. Registered GIs from the island of Ireland e.g. Irish Whiskey and Irish Cream continue to be recognised. It is optional to use the EU logo when the product is on sale in Great Britain if the products is protected under an EU scheme.
Food registered as organic in the EU can use the EU organic logo as long as they meet the EU organic labelling requirements and statement of agricultural origin.
There are specific food origin labelling requirements for a range of foods including:
• Beef and veal
• Poultry, sheep, goats and swine
• Fish and seafood
• Minced meat
• Eggs
• Olive oil
• Blended honeys
• Wine
• Fruit and vegetables
In general where origin is included on the label, the UK must not be referred to as EU. Products originating in UK can be labelled Origin: UK but not Origin: EU.
There are specific rules around meat origin, minced meat from different origins and meat originating in NI. For more guidance see Food labelling: country of origin