As reported in last week’s newsletter, we would strongly urge members to participate in the consultation recently launched by Defra on proposals to implement ‘not for EU’ labelling on goods across GB.

The rationale for this proposal is stated as being ‘to maintain continuity of supply to Northern Ireland’ in an effort to secure ‘Northern Irelands integral place in the United Kingdom’.

In practice it will mean that, to place goods for sale on the GB market, they must be labelled as ‘not for EU’. However, due to Unfettered Market Access rules this labelling requirement will not apply to qualifying goods moving from Northern Ireland to Great Britain.

There are 28 questions in total which seek views on the implementation of the policy in the following areas:

• Your or your business’ trade within the UK Internal Market – in particular with NI
• How you would expect to see this policy enforced
• How you’re already preparing, or will prepare, to introduce these requirements
• Any challenges you might face in introducing these requirements, and how you see this being managed
• Expected impacts (including costs and benefits)
• Where you think targeted exemptions may help to ensure these requirements are implemented effectively, for example exemptions for types of product or types of business

Whilst many questions provide multiple choice answers there are others which really are worth spending some time on, and those are the ones where you are asked to provide explanations to substantiate your answers or data as to the impact of such proposals, for example Q8, 12b, 13, 14 and 15 onwards. Whist the BFFF have represented members views in previous months, this is now your chance to evidence what we have been saying and ensure your thoughts and concerns are heard loud and clear.

Defra would prefer to receive responses through their Citizen Space platform here, although you will see at the bottom of the page, that pdf’s of the consultation have been provided should you prefer to answer via email. We have also transferred the consultation over to word format should you find it easier to work with. This can be accessed here.

Email responses should be sent to markingofretailgoods.consultation@defra.gov.uk

This consultation will close on 15 March 2024.