Windsor Framework - 'Not for EU'

What's happening?

The Windsor Framework introduces a new way to move pre-packed retail goods from Great Britain (England, Scotland and Wales) into Northern Ireland. It also includes products imported into Great Britain from the EU, as well as some products from the Rest of the World.

This means that as part of a three-phase roll out process, starting in October 2023 and running until July 2025, some products will require individual product labels, clearly marked ‘Not for EU’.

Does this replace existing framework?

The Northern Ireland Retail Movement Scheme (NIRMS) will also replace the current Scheme for Temporary Agrifood Movements into Northern Ireland (STAMNI) from 1 October 2023.

Does this apply to my business?

All businesses responsible for selling or enabling the movement of food for final consumption in Northern Ireland can benefit from this streamlined arrangement.

Why is this being introduced?

The framework and the standards on which the scheme operate will help to ease trade flows and ensure that consumers and businesses in Northern Ireland have fair access to the same goods as the rest of the UK, as well as providing the EU with reassurance that products originating from the UK Internal Market will not travel onward from Northern Ireland and into the EU Single Market.

For example…

If there is a food additive which is fully compliant with relevant UK safety standards, but not the EU – The Windsor Framework can therefore help to reduce trade friction, ensuring Northern Ireland has fair access to the same goods as the rest of the UK, whilst ensuring that non-EU compliant products do not pass into the EU.

How will this benefit my business?

• Streamlines movement of goods into Northern Ireland and allows businesses to move a wider variety of product that meets UK public health, organics and fisheries rules, which may have previously been prevented under EU legislation
• Enables more businesses to avoid cumbersome and costly certification and assurance processes, helping to reduce red tape complexity, overheads and production bottlenecks
• A wider cross-section of businesses are eligible for the Northern Ireland Retail Movement Scheme (NIRMS) and unlike the temporary STAMNI arrangement, are able to join on an ongoing basis
• The government will be providing financial support to adapt to the first phase of the scheme, this can be used to invest in coding and labelling equipment and processes which support an effective roll out of the framework

Here are a few more examples of how this works in practice…

• Prohibitions and restrictions on products such as seasoned lamb joints and British sausages have been removed, meaning that meat preparations can move under the General Certificate rather than being certified separately.
• Wine will no longer require VI-1 certificates
• Organic produce will be subject to UK public health and marketing rules

What about goods coming from Northern Ireland into Great Britain?

In order to ensure Northern Ireland can freely and fairly move goods into the UK market, Northern Ireland businesses will not need to apply these product labels when placing their products on the market in Great Britain.

What’s classed as an individual product label and where should it be placed?

A label which clearly states ‘Not for EU’ is required on individual products or on the outer packaging of a multipack.

If the products aren’t individually labelled, what are my options?

Where products are not individually labelled with ‘Not for EU’, product will require a label to the box or crate, on outer shrink wrap or by labelling the cage*

* For a cage to function as a ‘box’, it must be securely wrapped in a fully enclosed container until it arrives in Northern Ireland and with words ‘Not for EU’ to act as a ‘box’.

There is an element of flexibility built into the framework to take into account that businesses have different ways of working. It is advised that you implement the most practical method for your business.

Additional information

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.

Phase 1 (from 1^st October 2023)

What needs to be labelled?

All meat products and some fresh dairy moving from Great Britain to Northern Ireland.

What else do I need to know?

• Where products are not individually labelled with ‘Not for EU’, product will require a label to the box or crate, on outer shrink wrap or by labelling the cage.
• You do not need to label the tray that protects products or prevents leakage if the box/crate is labelled. For a cage to function as a ‘box’, it must be securely wrapped in a fully enclosed container until it arrives in Northern Ireland and with words ‘Not for EU’ to act as a ‘box’.
• In this 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).
• Phase 1 does not include composite products. For example, lasagne, pork pies or pepperoni pizza, which come into effect in Phase 3.

Specific definitions for Phase 1 products

These include but are not limited to what is shown below, a full list of commodity codes for products that need individual Phase 1 labels can be found here.

• Prepacked meat Chilled frozen and ambient meat
• Prepacked meat products Meat products which may have been buchered and packed so that the cut surface shows the product no longer has the characteristics of meat.
• Meat packed on sales premises Meat prepped and packed before being sold to a consumer, such as but not limited to meat and animal origin products, such as cuts of lamb or steak, fresh poultry or game which has been butchered, packaged and sold on the shop floor.
• Meat products which are processed on site and supermarket deli or butcher counter meat which is prepped and packaged before sale.
• Some dairy products Pasteurised milk, buttermilk or cream products, cottage cheese, quark cheese or raw (unprocessed) cheese of any animal origin, crème fraiche and sour cream.

Phase 2 (from 1st October 2024)

What needs to be labelled?

In addition to Phase 1 products, all milk and dairy products moving from Great Britain to Northern Ireland.

What else do I need to know?

• At this stage, all meat and dairy products in Great Britain (England, Scotland and Wales) would also need to be individually labelled.
• Phase 2 does not include composite products that contain products from this list. For example, a chilled pizza with processed cheese on it, these come into force in Phase 3.
• Please be aware, it is not a composite product if a plant product adds special characteristics to Processed Products of Animal Origin (POAO), like flavour, sweetness or acts as thickening or decorative agent. Therefore, it needs to be individually labelled. For example, if herbs are added to cheese or fruit to yoghurt, they are classed as dairy products as the plant product adds flavour.

Specific definitions for Phase 2 products

• All milk, buttermilk or cream, whey, butter, butteroil, caseins, anhydrous milk fat (AMF), cheese, yogurt, kefir, koumiss, viili or fil, smetana, fil,rjaženka, rūgušpiens and ice cream.

Phase 3 (from 1^st July 2025)

What needs to be labelled?

In addition to Phase 1 and 2 products, composite products, fruit, vegetables and fish and composite products such as pizza moving from Great Britain to Northern Ireland. The same products in Great Britain would also need to be individually labelled.

Specific definitions for Phase 3 products

Composite products are products that contain both products of plant origin and Processed Products of Animal Origin (POAO) for human consumption.

‘Processing’ means any action that substantially alters the original product, including heating, smoking, curing, maturing, drying, marinating, extraction, extrusion or a combination of those processes.

What products are exempt?

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

Also including but not limited to:

• Shelf-stable composite products such as sweets, chocolate, pasta, bread, extracts, soup stocks, food supplements, liqueurs, 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, dried herbs and spices, flavourings, jam, maple syrup, olive oil vinegar, ketchup, nuts and seeds, popcorn, crackers, crisps, soup, frozen chips, tea bags, coffee, cereal, flour rice, natural sugar, wine.
• Deregulated fruits such as pineapples, bananas, coconuts, dates and durians.

Transition period

The UK government has taken into account that there will already be products on the market in Northern Ireland as each phase is introduced. Therefore, there will be a 30 day transition period at the start of each phase to avoid the need for goods already on the market to be relabelled. These goods can be sold with no disruption during the transition phase.

Roll out timeline

After each transition period ends, relevant goods will need to be labelled with the words ‘Not for EU‘ both on boxes and individual products in line with these requirements.

• Food products that were moved into Northern Ireland before 1 October 2023 will not need to be individually labelled until 31 October 2023.
• Phase 2 products that were moved into Northern Ireland before 1 October 2024 will not need to be individually labelled until 31 October 2024.
• Phase 3 products that were moved into Northern Ireland before 1 July 2025 will not need to be individually labelled until 31 July 2025.

­­­What can I do now to prepare for the framework?

An effective way to manage the upcoming changes brought in with the Windsor Framework ‘Not for EU’ labelling framework would be to invest in your production line coding and labelling technology.

The Government will also be providing financial support to help businesses with the new requirements in Phase 1. Funding will cover a range of activities to ensure your lines are agile and able to adapt to changing legislation. To benefit from this support, you should keep all evidence of your costs to prepare to meet the new labelling requirements on 1 October 2023, as you may get payment retrospectively.

Whether this be for Print and Apply Labellers, which can automate the multipack labelling process, or Thermal Transfer, Continuous Inkjet or Laser for adding and automating this process for individual packs. Choosing a coding solutions provider that can provide full pack-to-pallet coding solutions with a history of adapting current and emerging legislative changes will help to circumvent costly waste and the time, resource and complexity of manually implementing this framework.