QA

摘要

Whatever the outcome of Brexit over the next few months, retailers and suppliers will need a strategy forcountry-of-origin labelling. Some retailers have already chosen to ensure that the country of origin is clear on labels. Others appear to be waiting to see how Brexit will impact UK legislation. This is risky because the new rules will apply to UK retailers, suppliers and manufacturers even in the event of a 'no deal', so taking action now is important to meet the 1 April 2020 deadline for compliance with the new rules. Part of Commission Implementing Regulation (EU) 2018/775, the legislation will mean clear labelling must be displayed on processed products, such as ready meals and canned food. The origin of any ingredients that make up 50 or more of the product, or smaller 'characterising' ingredients, will need to be displayed prominently front of pack. Retailers will need to ensure effective supplier engagement, especially in more complex supply chains, while suppliers will need to confirm whether the products they are supplying for own-brands need a geographical reference. The British Retail Consortium (BRC) has advised that own- brand product labels that involve trademarks or protected products, geographical references relating to the product or recipe, or customary product names lie outside the legislation. Using the BRC's decision tree, retailers assessing own-brand product labels need to focus on whether the origin indication covers a single ingredient or the whole product and ensure the claimed origin is the same as the product's provenance.