UK Labeling Requirements After Brexit: What Changed and What You Must Do

Since January 1, 2021, Great Britain (England, Scotland, Wales) operates under its own labeling regulations, no longer automatically aligned with EU rules. Northern Ireland has a more complex status, currently following EU rules for food under the Windsor Framework.

Key Changes from EU to UK Rules

Responsible Person / UK Food Business Operator

EU labels show an EU Food Business Operator (FBO). For GB sales, you must show a UK FBO, a name and UK address of the responsible party. This can be your distributor.

UK Conformity Assessment (UKCA) vs CE Marking

• CE marking still accepted in Great Britain until December 31, 2024 (extended for some sectors)
• UKCA marking now required for regulated products (electrical equipment, toys, PPE, etc.) sold in Great Britain
• Northern Ireland still uses CE marking

Nutrition Declaration Format

UK retained the same format as EU FIC but uses imperial measures alongside metric for some categories (e.g., pints for milk).

Country of Origin Rules

The UK has its own country of origin labeling requirements, broadly aligned with (but not identical to) EU rules. 'Product of the EU' can no longer be used for products sold in GB, must now specify individual member state.

Allergen Labeling

Allergen rules remain identical to EU (same 14 major allergens). However Natasha's Law (from October 2021) introduced new requirements for Prepacked for Direct Sale (PPDS) foods, full ingredient and allergen list required.

Weights and Measures

The UK Weights and Measures Act still applies. Net content must be stated in metric for pre-packed food (metric-only, or metric with imperial in brackets).

Selling Simultaneously in EU and UK

If you sell the same product in both markets, you have three options:

1. Single label, include both UK FBO and EU FBO addresses, meet both standards
2. Two-label system, UK-specific and EU-specific labels
3. Oversticker, cover EU FBO address with UK-specific sticker (legitimate but unattractive)

For high-volume, permanent listings, option 1 (a dual-compliant single label) is the most professional and cost-effective.

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