Blog: Product and food safety rules in a ‘no deal’ Brexit – Out-Law.com

Where there is an EU-based manufacturer, then a UK based importer, authorised person or responsible person is required in order to access the UK market where sales are not made directly to consumers/end users.

Where the importer route is used, the EU, or other foreign manufacturer and the UK importer need to display their name, trade name/mark and address – together, ‘details’ – on the product or the packaging.

For placement on the market in Great Britain, until 31 December 2023, these details can be provided on accompanying documentation where the products are imported from the European Economic Area (EEA) or Switzerland.

This grace period is not applicable to construction products, medical devices, interoperability of the rail system and transportable pressure equipment. For example, for construction products, the requirements will take effect from 1 January 2021.

Where there is a UK based manufacturer, then an EU or Northern Ireland based importer, authorised person or  responsible person is required to access the EU market where sales are not made directly to consumers/end users.

Where the importer route is used, both the UK manufacturer and EU/NI importer need to display their name, trade name/mark and address on the product or packaging.

Where the products are destined for both the UK and EU market, the products can be dual labelled – with the details of both the EU manufacturer and the UK importer or vice versa.

It is possible to provide the details of the UK importer on accompanying information during the period until 31 December 2023. This grace period is not presently available for the EU market. See UK market section for grace periods there.

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