Northern Ireland Retail Movement Scheme: Labelling requirements

There are specific requirements for Northern Ireland retailers labelling certain agri-food products under the Northern Ireland Retail Movement Scheme.

Individual labels

Under the 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 requirement 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 from 1 October 2023, only products moving into Northern Ireland under the Retail Movement Scheme will need to meet the labelling requirements. In phase 2 from 1 October 2024, 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 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.

Phase 1: Labelling requirements from 1 October 2023

From 1 October 2023, all meat products and some fresh 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 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).

Read more about phase 1 of the NI Retail Movement Scheme.

Phase 2: Labelling requirements 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 Retail Movement Scheme will need to be individually labelled.

At this stage, all meat and dairy products in Great Britain (England, Scotland and Wales) would also need to be individually labelled.

Read more about phase 2 of the NI Retail Movement Scheme.

Phase 3: Labelling requirements from 1 July 2025

From 1 July 2025, composite products, fruit, vegetables and fish moving to Northern Ireland under the 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 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.

Read more about phase 3 of the NI Retail Movement Scheme.

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
• frozen peas
• dried herbs and spices
• flavourings
• jam
• peanut butter
• maple syrup
• olive oil
• vinegar
• tomato ketchup
• nuts and seeds
• popcorn, crackers and crisps
• tomato soup
• frozen chips
• tea bags, dried tea leaves, and coffee
• cereals
• flour
• rice
• natural sugar
• wine

Deregulated fruits:

• pineapples
• bananas
• coconuts
• dates
• durians

Box label requirements

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.

In-store 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 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; and 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 are 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.

Technical requirements for product labelling

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 labelling requirements

Authorities will carry out proportionate risk-based and intelligence-led checks to ensure that these requirements are in place.