EU Rules on Primary Ingredient Origin Declarations: What do they mean for the UK?

March 5, 2020| by Ben Allen

New rules will apply from 1st April 2020, which may mean suppliers will need to consider whether they need to relabel their products.  It will depend upon the approach taken by the UK authorities…

Primary Ingredients

Back in the summer of 2018, Nielsen Brandbank published a blog detailing the EU’s new rules regarding origin declarations for primary ingredients.  We anticipated that, by now (one month before the new rules come into effect), we would be updating our original Blog with information about the UK’s approach to the rules.  As yet, we do not have that clarity.

EU Exit

When the UK left the EU on 31st January 2020, it entered into a ‘transition period’ (during which time all EU law continues to apply).  Accordingly, the implementing regulation setting down the rules for primary ingredient origin declarations will continue to be directly applicable in the UK.  However, the relevant question, for present purposes, then becomes: what approach will the UK authorities take to enforcement (and penalties)?  

Defra Consultation

In fact, this is now the specific subject of a consultation launched by Defra, last week.  That consultation closes on 20th March 2020.  Of course, we cannot pre-empt its outcome. However, it is of interest to note remarks by Defra that, ‘…[t]he large majority of meat and dairy foods on sale in our major supermarkets already provide this information accurately and honestly.’  For now, we will have to await the outcome of the Defra consultation.  

Food Label Compliance Service

Whatever the final position is, Nielsen Brandbank is ready to support its customers to achieve compliance.  Our ability to do this is now significantly improved by the launch of our Food Label Compliance Service, which – following a successful pilot – has now been launched to the full market.  For more information about our Food Label Compliance Service, click here.

The information in this article is not offered as, and must not be regarded as, legal advice.  Independent legal advice should always be sought. Neither Nielsen Brandbank, nor its affiliates, accept any liability arising from any action or inaction as a result of the above information.  accessed 28 February 2020.


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