Category Question Answer
Wood Packaging Materials (WPM) Does frozen goods being transported on wooden pallets from UK to Northern Ireland need to meet ISPM15 guidelines and the pallets need to be heat treated and carry the ISPM15 stamp? Currently wood packaging material (WPM) moving between the UK and EU (includes NI) does not need to be subject to any specific treatment or controls. However, as of 1st January 2021 this will change and all WPM moving between GB and the EU (including NI) must meet ISPM15 international standards by undergoing heat treatment and marking.

Current UK Government guidance advises that checks on solid WPM imported into the UK will continue to be carried out on a risk-targeted basis only. The plant health risk from WPM imported from EU and NI is low and is not expected to change from 1st January 2021.

ISPM15 international standards apply to solid WPM such as packing cases, boxes and crates, drums and similar packing, pallets, box pallets and pallet collars and dunnage (loose wood used to protect goods and their packaging). These standards, however, do not apply to processed woods like plywood, raw wood less than 6mm thick or cardboard or other packaging materials.

You should specify the requirements for solid WPM in your contract with exporters. This will help protect you if the packaging fails inspection. Should packaging fail inspection and you're given an option to treat it - you can either find a company authorised to ISPM15 standards to carry out treatment or send the WPM back to the supplier.

WPM treated to ISPM15 standard will bear 2 marks on opposite sides of the pallet. These will be visible and legible and appear on the block, stringer or lead board of the pallet and should suffice to prove the pallet is compliant with ISPM15. Should the ISPM mark not be legible then the WPM may fail an inspection.

For more information on ISPM15 International Standards please follow this link: https://www.ippc.int/en/publications/regulation-wood-packaging-material-international-trade-0/
For more information on Government Guidance please follow this link: https://www.gov.uk/guidance/importing-and-exporting-plants-and-plant-products-from-1-january-2021

Labelling We produce frozen veg, fruits and herbs in EU and export to multiple countries under own brand. Our current labelling mentions our EU address, do we need to add UK address? If so, can we add it next to our EU address without any other remark? Or add 'Imported in the UK by **our company name** and address? The Government recently published updated guidance on labelling requirements from 1st January 2021. A summary article with links to the full guidance can be found on our website here:  Link The latest guidance states that there will be a derogation of 21 months after the end for transition period for pre-packaged foods being placed on the GB market meaning you can continue using an EU, GB or Northern Ireland address for the food business operator on pre-packaged food sold in GB until 30th September 2022. However, from 1st October 2022, all pre-packaged food sold in GB must include a UK address for the food business operator. If the food business operator is not in the UK, it must include the address of the importer. (Note: we do not know if the EU will allow any derogation period – but we are presuming not and therefore if goods are to be sold on the EU market then you must have an established EU address for the Food Business Operator or EU importer on the packaging or food label).

To answer your question specifically - Yes, you will need to add your company address as you are not located within the EU.

Do we need to add a UK address for this? YES – see notes above. Allowing for the derogation period, from 1st October 2022, all pre-packaged food sold in GB must include a UK address for the food business operator OR the importer into the UK – As you are not registered in the UK you should use your Company UK address.

To answer the second part of your question - if so, can we add it next to the Belgian address, without any other remark? The UK Government were taking a pragmatic approach to the use of 2 addresses during the transition period. I know they had previously said they would allow the use of two addresses on pre-packed foods placed on the GB market during the transition period - one being an importer address into the EU27 and the other an importer into the UK thus allowing a product to be marketed in both EU27 countries and the UK. However, we are not sure if this will be acceptable from January 1st 2021.

From a UK trading standards perspective, we believe any concerns would be over potential confusion. Conversations with enforcement officers regarding the fact that information must not be misleading, ambiguous or confusing. There is a risk that it is unclear by printing another address on the label, and also of course, a risk that if you are over-printing this might be open to printing error. There may also be a risk of food products being halted at the UK border and if there was an incident, from a food traceability perspective, 2 addresses may be seen as a confusion.

Labelling We produce frozen veg, fruits and herbs in EU and export to multiple countries under customer's private label. Our current labelling mentions the customer's address (owner of the brand) - can we keep it like this or does our customer need to update their artwork? The Government recently published updated guidance on labelling requirements from 1st January 2021. A summary article with links to the full guidance can be found on our website here: Click Here  The latest guidance states that for pre-packaged foods being placed on the GB market there will be a derogation period of 21 months after the end of the transition period – this means that you can continue using an EU, GB or Northern Ireland address for the food business operator on pre-packaged food sold in GB until 30th September 2022. However, from 1st October 2022, all pre-packaged food sold in GB must include a UK address for the food business operator. If the food business operator is not in the UK, it must include the address of the importer. (Note: we do not know if the EU will allow any derogation period – but we are presuming not and therefore if goods are to be sold on the EU market then you must have an established EU address for the Food Business Operator or EU importer on the packaging or food label).

To answer your specific question - Customer’s private label, Current situation: the packaging mentions the address of the customer (owner of the brand). New situation: can we keep it like this? Or should we ask the customer to update their artworks? – From 1st October 2022 all pre-packaged food sold in GB must include a UK address for the food business operator or the importer into the UK. If these pre-packaged foods are the customers own branded products and it is their address on the label then they are food business operator that is responsible for the food. If their address is a registered UK address, then NO they do not need to update the address on the artwork.

Labelling What address should be on the label on importing bulk product from outside EU to sell to customers in UK? This must be either a UK registered adddress of a food business operator (FBO) or the importer into the UK
Labelling What address should be on the label on importing bulk product from outside EU being shipped direct to customers in Northern Ireland and Republic of Ireland but do not enter UK? For Northern Ireland (NI) - a registered address in Northern Ireland of a food business operator (FBO) or the importer into NI.
For Republic of Ireland (ROI) - this needs either an EU registered address (this can be ROI registered FBO address or other EU member state address) or the importer into the ROI or for the purposes of labelling, due to the NI Protocol you should be able to use a NI registered address as a valid EU address.
Labelling What address should be on the label on importing bulk product from outside EU and enters UK for re-packing/sleeving * and then be sold to Republic of Ireland as chilled product? It will be sold in Retailer's packaging to the Retailer? ** * At the point when product enters UK this will need a UK registered address of a food business operator (FBO) or the importer into the UK.
**If the Retailer is in the Republic of Ireland (ROI) and it is their brand in their packaging then use their address. Otherwise, it should either have an EU registered address (which can be ROI registered FBO or other EU member state address) or the importer into the ROI.
Labelling What address should be on the label on importing bulk product from ouside the EU and enters UK* and sold onto customers in EU**? *At the point when product enters the UK this will need a UK registered address of a food business operator (FBO) or the importer into the UK.
**At this point an EU registered address or the importer into the EU.
Labelling Where should the label information appear on pre-packed products, on the outer or primary packaging? Please click following link for the information you require:

https://www.gov.uk/guidance/food-labelling-giving-food-information-to-consumers

Labelling Is there a requirement to add 'kill dates' on outer case labels for EHC data? The following composite products destined for the EU Market must be accompanied by an Export Health Certificate if they contain:
Any amount of processed meat product as referred to in article 4(a) of Decision 2007/275/EC;
Half or more of any one processed POAO as referred to in article 4(b) of Decision 2007/275/EC, other than processed meat;
no processed meat and less than half of their substance of processed milk product where the final composite products do not meet the requirements of Article 6 of Commission Decision 2007/275/EC as referred to in article 4(c) of Decision 2007/275/EC
See: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32007D0275&from=EN
For example, you will find below a link to an EHC for poultry meat and poultry products which does ask for information on slaughter:
https://assets.publishing.service.gov.uk/media/5f68b887e90e077f5fd1a3bb/Draft-8296_English_V1.pdf
https://www.gov.uk/export-health-certificates/export-poultry-meat-to-the-european-union-certificate-8296

In conclusion it would be advisable to add the 'kill date' as the border inspection post has to verify that the composite products originate from a third country that is authorised to export such products (ie composite products containing processed products of animal origin) into the EU

It is also advisable to check with APHA:
APHA Centre for International Trade in Carlisle:
Email: ssc.carlisle@apha.gov.uk Tel: 03000 200301
Another useful link is:
https://www.gov.uk/guidance/exporting-animals-animal-products-fish-and-fishery-products-if-the-uk-leaves-the-eu-with-no-deal

Labelling We are finalising packaging for Retail products - these have been manufactured in the UK but will be sold in Ireland at a Retailer - are there any clear rules regards the changing of Health Marks to GBXXXX? Are there deadlines for supply as opposed to remaining on the market if they are different? The most current guidance as of mid-September 2020 is as follows:
https://www.food.gov.uk/business-guidance/guidance-on-health-and-identification-marks-that-applies-from-1-january-2021.

Further Government guidance is due out imminently, but as of 08/10/20 has been delayed.
As it currently stands, any changes to labelling will only come into effect after 31st December 2020 at the earliest but the exact date will depend on details agreed in any trade deal.

Health/identification marks, including timings, are part of the trade negotiations and at the moment Government is still in negotiations. The current 'UK AA1234 EC' format health/identification mark must continue to be used on all products produced in the UK as we are still bound by EU legislation. This also means that the 'GB format' mark must not be used during the transition period. The UK Government were considering allowing FBO's to use it earlier than 31st December 2020 for product placed on the GB market but have confirmed this would not legally be allowed. Government have however confirmed that product in old packaging will be allowed to be sold on the GB market for a period of 21 months after December 31st 2020. As yet, we do not have confirmation as to whether the EU will allow the same period of derogation. We will update this information as and when further guidance is issued.

Import/
Export
How do I import and export goods between Great Britain and the EU from 1 January 2021? Business exporting live animals or products of animal origin from Great Britain to the EU will require an Export Health Certificate (EHC) from Friday 1 January 2021. EHCs will be available via the online digital system known as EHC Online. Exporters will be able to apply for their EHC online and in most cases have them approved digitally by a certifying officer (CO). The EHC Online system is available via gov.uk. There are more than 100 EU export health certificates being developed and exporters will be able to see and decide which are applicable for their goods or consignments. For more details and to register please see www.gov.uk/export-health-certificates
Import How do I import goods from EU27 to Great Britain? Business exporting live animals or products of animal origin from Great Britain to the EU will require an Export Health Certificate (EHC) from Friday 1 January 2021. EHCs will be available via the online digital system known as EHC Online. Exporters will be able to apply for their EHC online and in most cases have them approved digitally by a certifying officer (CO). The EHC Online system is available via gov.uk. There are more than 100 EU export health certificates being developed and exporters will be able to see and decide which are applicable for their goods or consignments. For more details and to register please see www.gov.uk/export-health-certificates
Please click on the following link for step by step flowcharts from gov.uk: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/910155/How_to_import_goods_from_the_EU-into_GB_from_January_2021.pdf
Export How do I export goods from Great Britain to EU27? Business exporting live animals or products of animal origin from Great Britain to the EU will require an Export Health Certificate (EHC) from Friday 1 January 2021. EHCs will be available via the online digital system known as EHC Online. Exporters will be able to apply for their EHC online and in most cases have them approved digitally by a certifying officer (CO). The EHC Online system is available via gov.uk. There are more than 100 EU export health certificates being developed and exporters will be able to see and decide which are applicable for their goods or consignments. For more details and to register please see www.gov.uk/export-health-certificates
Please click on the following link for step by step flowcharts from gov. uk: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/910156/How_to_export_goods_from_GB_into_the-EU_from_January_2021.pdf

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