Brexit might be a distant memory for the general public, but the UK’s food industry continues to deal with its impact. 

Labelling remains one of the most challenging areas to navigate, with food and beverage businesses seeking clarity on requirements for products moving between Great Britain and Northern Ireland. 

The UK government planned to introduce mandatory ‘Not for EU’ labels on food packaging across Great Britain in 2024. However, a recent decision to postpone the programme adds another twist to this ongoing story. 

‍Why is Northern Ireland causing a compliance headache?  

When the UK left the European Union, Northern Ireland found itself in a unique position. Technically, it is part of UK customs territory, but it effectively remains in the EU's single market. 

This overlap created significant challenges for businesses moving goods across the Irish Sea, with extensive paperwork and checks required under the Northern Ireland Protocol.

To address these issues, the UK and EU agreed to the Windsor Framework in 2023, introducing a new two-lane system with reduced checks for goods staying in Northern Ireland. 

As part of this framework, the Northern Ireland Retail Movement Scheme (NIRMS) launched in October 2023 to simplify the GB-to-NI flow of goods. The 'Not for EU' labelling requirement is one of NIRMS' key tools, helping to ensure products intended for Northern Ireland don't move into the EU market. 

‍When is Not for EU labelling being rolled out?  

Not for EU labelling rules are being implemented for products sold in Northern Ireland in a three phase plan from October 2023-July 2025:

‍Phase 1 (from October 2023):

Meat products include red meats, poultry and processed meat products. Composite products containing meat were exempt from phase one.

‍Phase 2 (from October 2024):

All the meat products from phase one plus all milk and dairy products including cheese, yoghurt and dairy ice cream. Composite products containing dairy products (for example, a chilled pizza with processed cheese) were exempt from phase two. 

‍Phase 3 (from July 2025):

All products from phases one and two plus composite products like pizzas, pies and other foods containing both animal and plant ingredients, along with fruit, vegetables, fish and eggs.

‍Are ‘Not for EU’ labels needed UK-wide? 

In January 2024, the Conservative government proposed expanding the Not for EU labelling scheme to England, Scotland and Wales for fear that limiting the labels to Northern Ireland could discourage businesses from serving this market. 

In a policy paper on Safeguarding the Union published in January 2024, the Rt Hon. Chris Heaton-Harris (then Secretary of State for Northern Ireland) noted that “the small size of the market means that some suppliers may not have been willing to make the change and may have decided, instead, to remove products from the market."

However, following a general election in July 2024, the new Labour government decided not to proceed with mandatory 'Not for EU' labelling across Great Britain. 

As a result, brands only need to implement Not for EU labels if you are shipping food to Northern Ireland. It is not necessary to add the label on products sold in England, Scotland and Wales.

‍Why did the government drop ‘Not for EU’ label expansion plans?

UK government officials have now suggested a more targeted approach, monitoring product supply to Northern Ireland and only implementing UK-wide labelling if specific problems arise.

This decision reflects significant industry concerns about the costs and complexity of implementing Not for EU labels. 

According to Just Food, one UK dairy company estimated that the labels would cost them £1 million annually. The Food and Drink Federation's chief executive, Karen Betts, warned that the new labels could increase manufacturing costs and ultimately raise consumer prices across the UK.

The postponement allows businesses to avoid immediate labelling changes and associated costs, which is particularly beneficial for brands operating on tight margins during the cost-of-living crisis.

Concerns weren't just financial, either. Betts also suggested that the proposed labels could have "a chilling effect on UK food and drink exports, particularly for SMEs." 

The changes coincided with implementing the Border Target Operating Model – a post-Brexit system of additional checks and controls on EU imports. Asking companies to manage two major operational updates simultaneously would have created a heavy administrative burden, especially for smaller businesses with limited resources to handle complex regulatory requirements.

‍Could food brands still be required to add Not for EU labels? 

Small producers with no intention to sell products in Northern Ireland need not worry about including a Not for EU label on product packaging. 

However, any vendors providing goods to large UK retail chains with a presence in Northern Ireland (for example, major supermarkets like Tesco and Sainsbury’s) may be required to apply Not for EU labels on all stock. 

‍Will ‘Not for EU’ labelling be extended in future?

While the UK-wide rollout has been postponed, the government isn't abandoning the concept entirely. According to The Grocer, Labour plans to keep the labelling system as a "contingency mechanism” – but only for specific products if evidence shows reduced availability in Northern Ireland.

A targeted approach would focus on products removed from Northern Ireland shelves, aiming to "level the playing field by removing any competitive advantage suppliers may get in avoiding sending products to Northern Ireland."

This flexible approach has been welcomed by industry bodies, with the Food and Drink Federation praising it as "proportionate." However, businesses should remain alert to potential future changes, especially if evidence emerges of products being withdrawn from the Northern Ireland market.

‍What does this mean for your business? 

For food and drink brands, the decision to freeze plans for UK-wide Not for EU labels brings both relief and ongoing uncertainty.

In terms of immediate impact, if you're not shipping to Northern Ireland, you won't need to implement Not for EU labelling for now. However, the original NIRMS requirements still apply if you're moving goods to Northern Ireland.

For now, the focus remains on maintaining robust NI supply chains while minimising disruption to the UK's internal market - a delicate balance that continues to shape post-Brexit trade relations.

Looking ahead, food and beverage brands should stay abreast of industry updates and be prepared for potential targeted implementation if future supply issues arise.