On Friday 28^th July, Defra published further guidance on elements of the Windsor Framework, including how the retail movement scheme (ReMoS or NIRMS as it is now referred to) will work, how to register and seal consignments, and groupage and mixed load consignments.

As always, there is a lot of information to go through so please bear with us whilst we digest. In the meantime, a summary of the guidance can be found below along with details of a series of webinars Defra have scheduled to help you gain further information and explanation about the changes.

Webinars:

These will run on MS Teams over the next 3 weeks, will be approx. 45mins-1 hour long and will include a presentation and Q&A section.

Tuesday, 8th Aug 09:30* – The Northern Ireland Retail Movement Scheme, groupage and mixed load consignments

Wednesday, 16th Aug 14:00* – The Northern Ireland Retail Movement Scheme, groupage and mixed load consignments

Tuesday 22nd Aug 09:30* – The Northern Ireland Retail Movement Scheme, groupage and mixed load consignments

To register your interest please email NIDBusinessReadinessTeam@defra.gov.uk.

 

Summary

Implementation of the Framework is taking place in stages up to 2025. As of 30th September, this year, the existing UK Trader Scheme (UKTS) will be replaced by a new UK Internal Market Scheme (UKIMS).

Procedures for the movement of goods subject to Sanitary and Phyto Sanitary (SPS) controls will also change with effect from 1 October 2023. Currently they are supported under STAMNI (Scheme for the Temporary Agrifood Movements to Northern Ireland). This will be replaced in October 2023 by a new scheme, the Northern Ireland Retail Movement Scheme. This will be available to a much broader range of traders and includes new labelling provisions applicable to goods for sale only in Northern Ireland for goods moving through the new ‘green lane’. Movements which do not qualify under the scheme will move through the ‘red lane’. The government will continue to provide support through the Digital Assistance Scheme, and should goods remain in Northern Ireland, the Movement Assistance Scheme.

Formal registration for the Northern Ireland Retail Movement Scheme will be launched in September 2023. In the meantime, traders are able to register their interest through a pre-registration process, the key elements of which are outlined below.

Note: 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. Unlike STAMNI, businesses will be able to join the Northern Ireland Retail Movement Scheme on an ongoing basis.

 

Key elements of the Scheme:

From 1 September 2023, all businesses responsible for selling or facilitating the movement of food for final consumption in Northern Ireland will be able to register for the Northern Ireland Retail Movement Scheme (NIRMS).

 

I am eligible, how do I register for the Scheme?

As part of the registration there are important steps you will need to follow, along with necessary systems to be put in place which is covered within the guidance. This includes:

Pre-registration: To enable registration for the Northern Ireland Retail Movement Scheme you will need to ensure you are already registered on some key accounts as well as a specific portal if your business is based in Northern Ireland.

Sign up to system: On completion of pre-registration, you will then be able to sign up using the new digital platform which will allow you to send or receive goods under the Northern Ireland Retail Movement Scheme.

During registration: You will need to provide details of all establishments for dispatch or receipt of goods under the scheme and confirm that you are a registered food business operator (FBO) in the UK. The business sending the consignment in GB and the business receiving the consignment in NI need to be registered for the scheme.

Application process: You will need to agree to the terms and conditions of the scheme. If your application is successful, you will receive an email confirmation along with a Scheme Membership Number for your business and Establishment Numbers for all establishments sending or receiving goods.

Registered: Once you are registered on the Northern Ireland Retail Movement Scheme, you will be able to complete the General Certificate (GC) via a link which will be provided following sign to the scheme through Export Health Certificate Online (EHC Online).

Sealing consignments: All consignments must be sealed with an authorised seal with appropriate supervision. The seal must have a unique identifier with associated number, and the number must be included in the General Certificate. Further explanation on sealing consignments can be found here.

Compliance: In line with the existing processes under STAMNI the NI destination establishment must inform DAERA of the arrival of the goods at the NI listed establishment via the Common Health Entry Document Operators Platform (CHOP) system, within 48 hours. DAERA will complete any channelling procedures and will follow up by email, if necessary, rather than “if there are any discrepancies”.

DAERA will complete 100% documentary verification on the General Certificate and Common Health Entry Document (CHED) using the CHED Inspection Platform, Common Health Entry Document Interface Platform (CHIP).  All goods must be labelled in accordance with the scheme’s labelling requirements. Details on the eligibility of products that you can move under the Northern Ireland Retail Movement Scheme can be found here.

How do I express an interest in registering for the Scheme?

Expressing an Interest in joining the Northern Ireland Retail Movement Scheme will grant you access to further details and webinars on how the scheme will work and the onboarding requirements, including what can be done ahead of 1 September 2023. If you would like to express an interest in registering for the scheme, please send an email to NIRetailMovementSchemeRegistration@defra.gov.uk, providing your name, email address, company name and whether you are based in GB or NI.

Please note, expressing an interest does not constitute registering for the NI Retail Movement Scheme, registration will open 1 September 2023.

Northern Ireland Retail Movement Scheme: groupage and mixed load consignments 

The guidance published is specifically for businesses moving consignments of scheme-compliant agrifood products within grouped loads (known as ‘groupage’) from Great Britain (England, Scotland, and Wales) to Northern Ireland, which may include consignments of Northern Ireland Retail Movement Scheme (NIRMS) goods and consignments of non-NIRMS goods.
Details of eligible products can be found within the section above. It also notes the steps to take to utilise the certification and standards benefits of the NIRMS when moving scheme-compliant goods in a load which contains non-NIRMS goods (which will be subject to full Official Control regulations (OCR) controls).
You can find existing guidance on moving groups of agrifood products from Great Britain to Northern Ireland under full OCR compliance here.

Full guidance can be found here but the guidance covers in detail: –
What groupage is under the Windsor Framework: how you can continue to move goods using any of the following groupage models; linear or consolidation hub.

Actions consignor is required to follow, in line with current arrangements under STAMNI, after contacting the haulier: which is to complete a General Certificate (GC) for the consignment, provide a packing list with your GC, submit both the GC and the packing list, confirming consignment meets the scheme conditions and send the GC and attachments to the Consignee in NI, who will raise a Common Health Entry Document (CHED).

Actions consignee is required to follow, in line with current arrangements under STAMNI, once the above paperwork has been received from the consignor: Produce a retail movement CHED (at least 4 hours in advance of arrival in NI), attaching the General Certificate (including seal number) and packing list and finally the NI destination establishment must inform DAERA of the arrival of the goods at the NI listed establishment within 48 hours, as is currently the case under STAMNI.

Sealing your NIRMS consignment (and if all consignments on lorry are NIRMS consignments): You must ensure that all your consignments are sealed with an authorised seal under the supervision of a Scheme member’s responsible person. The seal must have a unique identifier with associated number, and the number must be included in the General Certificate. Further explanation on seal requirements can be found in the Northern Ireland Retail Movement Scheme section above and full guidance here link.

Mixed load of NIRMS and non NIRMS consignments: If the grouped load contains a mix of NI Retail Movement Scheme compliant goods and consignments which are not eligible for the NI Retail Movement Scheme the lorry, as a whole, cannot benefit from all the facilitations under the Northern Ireland Retail Movement Scheme. Further explanation can be found in the full guidance here.

Action:
You should continue to use guidance and procedures that presently are in place on gov.uk until new procedures come into effect on 1st October 2023.

For up-to-date guidance we encourage you to sign up for gov.uk alerts.

Defra hold a fortnightly NI-GB Food Supply Chain Forum, the next session will be held on Thursday 3 August at 09.00. The Forum is open to all traders. If you would like to attend and do not already have the invite, please email: NIGBFoodSupplyChainForum@defra.gov.uk

 

Questions/queries on the guidance can be sent to traders@defra.gov.uk

The Food Standards Agency (FSA) and Food Standards Scotland (FSS) have issued advice today (27^th July 2023) that pregnant women and those with a weakened immune system should avoid eating ready-to-eat cold-smoked or cured fish, following publication of a risk assessment showing they are at higher risk of severe illness from listeriosis. Products include smoked salmon, smoked trout, and gravlax.

As the risk of serious illness from listeriosis increases with age, the FSA and FSS are also advising that older people should be aware of the risks associated with eating these products.

The FSA and FSS’s joint risk assessment, commissioned in response to an ongoing outbreak of Listeria monocytogenes linked to ready-to-eat cold smoked fish, found that while the risk of contracting listeriosis in higher-risk individuals from cold-smoked fish is low, the severity of the illness is high. This means there is the potential for severe illness, hospitalisation, and death among higher risk groups.

Professor Robin May, FSA Chief Scientific Adviser, said: 

“Our risk assessment shows that there is still an ongoing risk to health associated with eating cold-smoked fish for specific groups of vulnerable people, including pregnant women and individuals with impaired immunity.

“In light of the risk assessment, we are advising that these consumers avoid ready-to-eat cold-smoked and cured fish products.

“If you are in the group of people more at risk of listeria infection, and you decide to consume these products, we strongly recommend that you first cook them until steaming hot all the way through. This will ensure that any listeria present in the product is killed before it is eaten.”

The FSA, FSS, and UK Health Security Agency have been investigating and taking steps to tackle an ongoing outbreak of Listeria monocytogenes linked to smoked fish since cases were first reported in 2020. There have been 19 linked cases of listeriosis dating back to 2020, and sadly four people have died.

Dr Gauri Godbole, Consultant Microbiologist at UKHSA said: 

“While smoked fish has a higher risk of carrying listeria, the overall risk to the population is very low. However, some people are more likely to get a serious infection including those who are pregnant and those with weakened immune systems. The risk also increases with age.

“Most people who are affected by listeriosis will have no symptoms or experience mild diarrhoea which subsides in a few days. Those who are more vulnerable can be at risk of severe illness such as meningitis and life-threatening sepsis. Listeriosis in pregnancy can cause very serious illness in mothers and their babies.”

The updated advice applies to pregnant women and those with weakened immune systems, such as people with certain underlying conditions for example cancer, diabetes, liver and kidney disease, or anyone taking medications which can weaken the immune system.

The level of risk will depend on whether the individual has underlying health conditions. The risk also increases with advancing age and in pregnancy.

Cold-smoked fish such as smoked salmon or trout, and cured fish such as gravlax, have not been fully cooked during the production process to kill any listeria that may be present, and therefore present a higher risk of infection.

‘Cold-smoked’ fish is normally labelled as ‘smoked’ fish on packaging. Ready-to-eat cold-smoked fish typically comes in thin slices, and it can be eaten cold. It may also be found in sushi.

Once thoroughly cooked, the smoked fish will be safe to eat, and can be served immediately, or served cold after being chilled in the fridge.

If consumers would like to add cold-smoked fish to dishes like cooked pasta or scrambled eggs, it is important to cook it first. This is because simply warming it through while preparing a meal will not heat the fish to a high enough temperature to kill any listeria present.

Smoked fish products that have been heat-treated during production, such as tinned smoked fish, may be safely consumed without further cooking. These tinned products are heated to a high temperature during production, sufficient to kill any listeria that may be present.

Most people who are affected by listeriosis will get mild gastroenteritis which subsides in a few days. However, certain individuals are particularly at risk of severe symptoms which can include meningitis and life-threatening sepsis.  Listeriosis in pregnancy can cause miscarriages and severe sepsis or meningitis in new-born babies.

Cases of listeriosis from smoked fish remain rare overall. If you have eaten these products recently, you do not need to do anything unless you get symptoms of the infection. These include a high temperature of 38C and above, aches and pains, chills, feeling and being sick, or diarrhoea. Contact NHS 111 or your GP surgery if you are unwell and pregnant or have a weakened immune system and you think you could have listeriosis.

More information on listeria is available on the FSA’s listeria guidance page.

Defra have announced this week that they will be deferring Extended Producer Responsibility payments for 1 year from October 2024 to October 2025.

Their official statement of 26^th July reads:

Following extensive engagement with industry, and in light of the pressure facing consumers and businesses in the current economic context, new rules to ensure packaging producers pay for the cost of recycling their packaging will be deferred a year from October 2024 to 2025.

Government will use the additional year to continue to discuss the scheme’s design with industry and reduce the costs of implementation wherever possible. In anticipation of EPR, producers have already started to use less packaging and adopt easier to recycle packaging formats, and we expect this process to continue – ensuring that costs are not then passed onto households later on.

This decision to defer producer payments has been taken jointly with the devolved administrations and will provide industry, local authorities and waste management companies with more time to prepare to ensure the success of the scheme, helping make sure it is best designed to deliver on long term recycling goals while supporting households with the immediate challenge of high prices caused by inflation.

Environment Minister Rebecca Pow said:

We’re determined to transform the way we collect, recycle and reuse our waste materials so we eliminate all avoidable waste by 2050 in a way that works for households and consumers. That’s better for our environment.

We are also listening to industry and ensuring our work to tackle inflation and to drive up recycling go hand in hand, to make sure our reforms will be a success.

Simon Roberts, CEO of Sainsbury’s, said:

Whilst we remain absolutely committed to a circular economy and support the introduction of EPR, we welcome today’s announcement.

This will provide the necessary time to work across our industry and with Government in order to get EPR right first time. This decision is also an important step in minimising further pressure on food inflation and we will continue to focus on delivering the best value to customers in the coming months.

Paul Vanston, Chief Executive of the Industry Council for Packaging and the Environment (INCPEN), said:

UK and devolved Ministers are making the right set of decisions at this time to drive forward the shaping of the collections and packaging reforms.

Ensuring overall systems efficiency, cost-effectiveness and high recycling performance are essentials for the governments and stakeholders to achieve together.

The government remains committed to delivering on its commitments to eliminating avoidable waste by 2050 and recycle 65% of municipal waste by 2035.

The extended producer responsibility scheme will play a central part in delivering that mission and will build on other measures, including the tax on plastic packaging which does not meet a minimum threshold of at least 30% recycled content, which came into force last April, and the upcoming bans on countless single-use plastic items, including cutlery and plates.

Meanwhile, our single-use plastic carrier charge has successfully cut usage by more than 97% in the main supermarkets.

Consistent recycling collections for households will come in after the implementation of the extended producer responsibility scheme. More details on this will be set out in due course.