The 1st January 2021 marked the end of the UK’s Brexit transition period, and the beginning of many changes to come to the UK market. From this date onwards, EU legislation no longer applied to the UK and free movement of goods between the UK and EU had ended.
The UK (excluding Northern Ireland because of the Protocol on Ireland/Northern Ireland) is now considered to be a third country, meaning custom formalities and changes in regulation have taken place, which in turn may affect how your business operates.
For now, EU law has been implemented into UK legislation, as the EU (Withdrawal) Act 2018, set out with Brexit in mind, allowed for current EU frameworks to be retained by the UK. However, the UK is now no longer able to amend or update these regulations without introducing new primary UK legislation. This means that EU legislation due to take effect any time henceforth will not be automatically implemented by the UK. From now on, the UK will have to make its own decision regarding future EU regulations.
Whilst EU legislation has been retained by the UK, some changes will still have to be made to products entering the UK market. With regards to food products, this includes changes to labelling. For example, Organic food products in the UK continuing to use the EU leaf on labels should accompany this with the EU agricultural origin statement (i.e. EU / non-EU) rather than a UK agricultural statement. Agriculture of origin statements on products in Northern Ireland which have sourced ingredients from Great Britain must also reflect non-EU origin.
Other food labelling changes include the requirement of a UK Food Business Operator (FBO) address. An EU FBO address will no longer suffice. Likewise, UK FBO addresses are not sufficient for products marketed in the EU. This means that products marketed in both the UK and EU will require both addresses. Here at RNI Consulting we can assist you in dealing with this hurdle by acting as both your EU and UK ‘responsible person’.
Similarly, for cosmetic products an EU responsible person is required for cosmetics marketed in the EU and a UK responsible person for those entering the UK market. The same goes for medical devices, where a responsible person with a UK registered address will also be required for registration of medical devices in the UK.
Get in touch with our team of scientific and regulatory experts so that we can assist you in making the adjustments necessary to enter a post Brexit UK market. Whether it be acting as both your UK and EU Responsible Person for food supplements, cosmetic products or medical devices, or ensuring your products meet new UK regulations, RNI is here to make this adaptation stress-free for you and your business. With consultants in the UK, EU and USA we are perfectly positioned to provide regulatory guidance and business strategy for companies inside and outside the UK.
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