We have responded to Defra's consultation on amending food labelling laws in the event that the UK leaves the EU in a ‘no deal’ scenario. Read our response below.
1. Duration of the transition: Proposal 6 months.
IFST suggests a transition phase of 12-18 months.
The proposed changes will have a significant impact for businesses and require high numbers of labels to be re-designed and printed. The planned extension to COOL for primary ingredients - April 2020, will extend COOL further across the food industry.
When labels are re-designed several steps need to be followed: Redesign : Compliance check : Review : Printing (non UK in many cases): Supply Chain : Stock management.
Due to the high volume of labels to be changed there could be bottle necks at various stages of the process and resource issues given a 6-month time frame. We would recommend at least a 12-month time frame; Ideally 12- 18 months aiming to capture in "one hit" COOL additional labelling requirements i.e. one timeframe for Brexit linked changes and COOL revisions.
2. Further points?
The EU has developed extensive science-based regulation providing a greater level of food safety for the consumer than many other global regions. Therefore we feel it would be in the consumer interest to be informed if a food is coming from within the EU i.e. 3 categories for the labelling: UK ; EU ; non UK-EU or similar wording.