From 1 October 2023, businesses in Great Britain (England, Scotland and Wales) will be able to move prepacked retail goods as well as certain loose goods including fruit and vegetables through the “green lane” to Northern Ireland, under the Windsor Framework. This is the Northern Ireland Retail Movement Scheme.
From this date, there will be new, proportionate labelling requirements for moving goods through the green lane, to make sure that goods are not moved onwards into the EU. These include different requirements for labelling individual products, some boxes and displaying signage in retail premises in Northern Ireland.
The Northern Ireland Retail Movement Scheme means you will no longer need to complete multiple export health certificates or put an EU address on individual products. Movements will use a single General Certificate instead, and can use an address in the United Kingdom (England, Scotland, Wales, Northern Ireland), the Channel Islands (Guernsey and Jersey) and the Isle of Man.
You must continue to follow existing UK food packaging and labelling regulations and any health and identification marks needed.
Under the Northern Ireland Retail Movement Scheme some food products will need individual product labels with the words ‘Not for EU’. These requirements will be brought in through 3 phases from October 2023 to July 2025.
This includes products imported into Great Britain from the European Union and certain products from the Rest of the World. You only need to label the outer packaging of a multipack. In the first phase, only products moving into Northern Ireland under the Northern Ireland Retail Movement Scheme will need to meet the labelling requirements. From phase 2, the government intends to introduce labelling requirements in Great Britain (England, Scotland and Wales) following consultation.
The requirements for box labels and retail premises signage will only ever be applied to goods moving to Northern Ireland under the Northern Ireland Retail Movement Scheme.
In order to ensure unfettered access for Northern Ireland goods to the UK market, Northern Ireland businesses will not need to apply these product labels when placing their products on the market in Great Britain.
From 1 October 2023 all meat products and some dairy products that are moving from Great Britain to Northern Ireland will need to be individually labelled. Find the full list of commodity codes included in phase 1.
In the first phase, only products moving into Northern Ireland under the Northern Ireland Retail Movement Scheme will need to meet the labelling requirements. From phase 2, the government intends to introduce labelling requirements for Great Britain (England, Scotland and Wales).
From 1 October 2024, in addition to the phase 1 products, all milk and dairy products moving to Northern Ireland under the Northern Ireland Retail Movement Scheme will need to be individually labelled.
At this stage, all meat and dairy products in Great Britain (England, Scotland and Wales) will also need to be individually labelled.
From 1 July 2025, composite products, fruit, vegetables and fish moving to Northern Ireland under the Northern Ireland Retail Movement Scheme will also need to be individually labelled. The same products in Great Britain (England, Scotland and Wales) would also need to be individually labelled.
Not all products moved under the Northern Ireland Retail Movement Scheme need to be individually labelled. There is an exemption list below. If products are individually labelled, you will not need to label the box, nor provide appropriate signage.
Phase 1: Products that need individual product labels from 1 October 2023
From 1 October 2023, individual labels will be required on all prepacked meat, prepacked meat products, meat packed on sales premises and some dairy products using this scheme.
‘Prepacked’ means packed for the final consumer or catering operator, so that the contents cannot be altered without opening or changing the packaging.
Compound products are included in phase 1, if they contain one or more of the products in the phase 1 list. For example, a chicken kiev or a cheeseburger. Find out how to identify compound products.
Phase 1 does not include composite products. For example, lasagne, pork pies or pepperoni pizza. These come into force in phase 3.
This includes chilled, frozen, dried and ambient meat, which are defined as the edible parts of any animal intended for human consumption.
Meat includes but is not limited to:
- red meats – lamb, beef, pork, steak, minced meat, veal, venison
- game meats – rabbit, game birds, wild birds for consumption
- poultry – chicken, turkey, quail
- ‘exotic’ meats which are intended for human consumption – kangaroo, ostrich
- any domestic bovine species including bison and Bubalus species
- other domestic species of ‘red meats’ including swine, ovine, caprine and domestic solipeds
- poultry including chickens, turkey, any farmed domestic birds, and any farmed wild birds
rabbits, hares and rodents
- any wild game, including wilds birds or wild land mammals, that are hunted for consumption, whether they are truly wild or kept in wild-like conditions to be hunted
- any lagomorphs which live in the wild and are hunted for consumption.
- animal blood
- any other wild game which does not fall into the above specific categories if it is intended for human consumption
- meat preparations
- any other products produced from parts of animals, including gelatine (sweets with gelatine do not need to be individually labelled as they are shelf-stable products)
Prepacked meat products
These are meat products which may have been divided, parted, severed, sliced, boned, minced, skinned, ground, cut, cleaned, trimmed, husked, milled, and packed so that the cut surface shows the product no longer has the characteristics of meat.
These products could be fresh, chilled, frozen, deep-frozen or thawed.
Meat packed on sales premises
This is meat which is prepared and packed before sale to a consumer, such as:
- meat and animal origin products which are butchered on site, pckaged and sold on the shop floor, like cuts of steak or lamb, fresh poultry or cuts of game
- meat products which are processed and packaged on site, like fresh mince products that are produced and packaged on site
- meat on supermarket deli or butcher counters where the product is packaged before sale
Some dairy products (including both prepacked and packed on sales premises)
- pasteurised milk, buttermilk or cream products
- cottage cheese, quark cheese or raw (unprocessed) cheese, of any animal origin
- crème fraiche and sour cream
Check the full list of commodity codes for products that need individual labels by 1 October 2023.
Phase 2: Products that need individual product labels from 1 October 2024
From 1 October 2024, in addition to the phase 1 products, all milk and dairy products moving to Northern Ireland under the Northern Ireland Retail Movement Scheme will need to be individually labelled:
all milk, buttermilk or cream
anhydrous milk fat (AMF)
viili or fil
From 1 October 2024, all meat and dairy products in Great Britain (England, Scotland and Wales) will also need to be individually labelled.
Phase 2 does not include composite products that contain products from this list. For example, a chilled pizza with processed cheese on it. These come into force in phase 3.
However, it is not a composite product if a plant product adds special characteristics to a POAO, like flavour, sweetness or acts as thickening or decorative agent. Therefore, it needs to be individually labelled. For example, if herbs are added to cheese or fruit to yoghurt, they are dairy products as the plant product adds flavour.
Phase 3: Products that need individual product labels from 1 July 2025
From 1 July 2025, additional food products that move through the Northern Ireland Retail Movement Scheme must be individually labelled. This includes pet food, fruit and vegetables, fish and composite products such as pizza.
Composite products are products that contain both products of plant origin and processed products of animal origin (POAO) for human consumption.
‘Processing’ means any action that substantially alters the original product, including heating, smoking, curing, maturing, drying, marinating, extraction, extrusion or a combination of those processes.
Exceptions: food products that do not need individual labels
You will not need to individually label the following products, (although box and retail premises labelling requirements apply):
- products sold loose or by weight on the sales premises at the consumer’s request
- products processed and sold on the sales premises by a retailer, for direct consumption
- products for sale in a factory canteen, institutional canteen, restaurant, or other similar food service operators that are intended for eating on the spot in Northern Ireland
Shelf-stable composite products:
confectionery including sweets, chocolate and other food preparations containing cocoa
pasta, noodles and couscous, not mixed or filled with meat products
bread, cakes, biscuits, waffles and wafers, rusks, toasted bread and similar toasted products
olives stuffed with fish
extracts, essences and concentrates of coffee, tea or maté and preparations with a basis of any of these products
roasted chicory and other roasted coffee substitutes, and extracts, essences and concentrates of these products
soup stocks and flavourings packaged for the final consumer
food supplements packaged for the final consumer, that contain small amounts of animal products or glucosamine, chondroitin or chitosan
liqueurs and cordials
Products that meet UK public health standards; and those not requiring certification or controls at agri-food points of entry under the Official Controls Regulation, including:
processed or canned fruit and vegetables
dried herbs and spices
nuts and seeds
popcorn, crackers and crisps
tea bags, dried tea leaves, and coffee
Where products are not individually labelled with the words ‘Not for EU’, there are requirements to label the box or crate under the Windsor Framework.
This requirement will take effect from 1 October 2023.
As more products are individually labelled in phases 2 and 3, the requirement for box labelling of those products will cease.
It is recognised that businesses move products in different ways. Therefore this requirement should be implemented in the most pragmatic way possible, such as:
labelling of shrink wrap which is not removed until products are unloaded at stores where appropriate, for example because products are not stored in boxes or crates.
If products are not stored in boxes, crates or shrink wrap, you can label the cage.
You do not need to label the tray that protects products or prevents leakage if the box is labelled.
During transportation a cage can function as a box if it is a fully enclosed container until it arrives in Northern Ireland. This means that cages must be securely wrapped with tape with the words ‘Not for EU’ to function as ‘boxes’.
The Government will engage further with retailers on the practical methods that can be used to meet this requirement.
Labelling for retailer premises in Northern Ireland
Where products are not individually labelled, retail premises must also ensure appropriate visibility in store of the fact that these goods are not to be sold in the EU.
These requirements apply to all retail establishments in Northern Ireland.
Where food products are not individually labelled and have moved under the Northern Ireland Retail Movement Scheme there should be shelf level labelling with the words ‘Not for EU’.
Businesses may have a range of different ways of displaying and indicating the price of products and can take this into account when labelling a shelf. This can include:
the individual price tag on the shelf
a separate label next to the price tag on the shelf
The Government will continue to engage with industry on the practical ways in which these requirements can be met.
Retail premises must also display posters in their stores, so customers are aware that goods moved under this scheme are intended for consumption in the United Kingdom; not to be sold or consumed in the EU.
Posters may be in paper or digital format. Premises can create their own posters with the relevant information. The positioning and number of posters is at the discretion of individual stores.
Catering operators do not need to label shelves for food products that are intended for eating on the spot in Northern Ireland. This includes food products in a factory canteen, institutional canteen, catered event or restaurant. You do not need to display posters next to these food products.
Retail premises are responsible for ensuring that these arrangements are in place.
30-day transition period
The UK government recognises that there will already be products on the market in Northern Ireland when each new phase comes into effect. Therefore, there will be a 30 day transition period at the start of each phase. This means that goods that are already on the market will not need to be relabelled and will be able to be sold during the transition period.
After each transition period ends, relevant goods will need to be labelled with the words ‘Not for EU‘ both on boxes and individual products in line with these requirements.
Food products that were moved into Northern Ireland before 1 October 2023 will not need to be individually labelled until 31 October 2023.
Phase 2 products that were moved into Northern Ireland before 1 October 2024 will not need to be individually labelled until 31 October 2024.
Phase 3 products that were moved into Northern Ireland before 1 July 2025 will not need to be individually labelled until 31 July 2025.
Technical requirements for the label
The labels can be written, printed, stencilled, marked, embossed, impressed on or attached to the product, box or shelf. The labels can be adhesive labels (stickers) or sticky tape, if they are not easily removable.
The label must be easy to see, clear to read and unlikely to fall off or be removed. It should not be hidden or covered by any other writing or pictures.
On boxes, crates and products, you can put the label anywhere. It can be incorporated into individual packaging if it does not cover any other required information.
Products should be marked in line with existing UK labelling requirements.
Enforcing the requirements
Authorities will carry out proportionate risk-based and intelligence-led checks to ensure that these requirements are in place.
If you have questions about the new labelling requirements, please email email@example.com.
The UK Government will provide financial support to help businesses with the new labelling requirements in phase 1. Funding will cover a range of activities that could help your business meet the labelling requirements.
To benefit from this support, you should keep all evidence of your costs to prepare to meet the new labelling requirements on 1 October 2023, as you may get payment retrospectively. More guidance will follow shortly on the arrangements for benefiting from this support.
The funding will not cover the labelling changes for phases 2 and 3.
England, Scotland and Wales: future labelling requirements for food products
From October 2024, the UK Government intends to extend the requirement for individual labels under the Northern Ireland Retail Movement Scheme to relevant products in England, Scotland and Wales.
That means from that date, you would also need to label meat and dairy products for sale in England, Scotland and Wales with the words ‘Not for EU’.
From July 2025, the requirements for England, Scotland and Wales would fall in line with the Phase 3 requirements, meaning that fruit and vegetables, composite products and fish will also need to be individually labelled.
You will not need to add labels to boxes, crates or shelves in England, Scotland and Wales.
This requirement includes products imported into Great Britain from the European Union, including Ireland or certain products from the Rest of the World.
More guidance on these requirements will follow.