Committee publication · Correspondence · 10 June 2025

Correspondence from the Minister for Biosecurity regarding the Marking of Retail Goods Regulations 2025, dated 5 June 2025,

From: Environment, Food and Rural Affairs Committee

Inquiry: Animal and plant health

Summary

Baroness Hayman writes to inform the EFRA Committee of the Marking of Retail Goods Regulations 2025, laid 5 June. The SI provides contingency powers to mandate 'not for EU' labelling on goods in Great Britain if Northern Ireland faces serious product delisting under the Northern Ireland Retail Movement Scheme (NIRMS). The measure responds to Phase 3 expansion from 1 July 2025 and supports commitments in the Safeguarding the Union Command Paper.

Key findings

  • The Marking of Retail Goods Regulations 2025 grants the Secretary of State a contingency power to introduce 'not for EU' labelling on Great Britain retail goods where delisting threatens Northern Ireland product availability.
  • NIRMS Phase 3 (1 July 2025) will expand product scope, raising delisting risk; the SI must be in force by that date to provide intervention capability.
  • Manufacturers currently face labelling costs and logistics complexity under NIRMS requirements; mandating labels on the larger GB market is intended to remove financial incentives for delisting in NI.
  • The UK and EU have reached common understanding on a future SPS Agreement that would remove broad agri-food and plant requirements, potentially eliminating the need for 'not for EU' labelling.
  • Any SI activation will be a last resort after stakeholder engagement fails; Devolved Government ministers will be consulted before the Secretary of State triggers intervention on specific retail goods.

Tone

Procedural

Topics

trade-policynorthern-irelandretail-regulationfood-safety

Key actors

Baroness Hayman of Ullock, Alistair Carmichael MP, Environment, Food and Rural Affairs Committee, Secretary of State, UK Government, European Union, Devolved Governments

Notable line

… the intention is to incentivise retailers and manufacturers to make the changes necessary for compliance with the smaller GB-NI route.

Key Quotes

Since launching in October 2023, the Northern Ireland Retail Movement Scheme (NIRMS) has allowed eligible agrifood products to move between Great Britain (GB) and Northern Ireland (NI) without needing to go through full European Union (EU) Sanitary and Phytosanitary (SPS) requirements, provided they are not transported onwards to the EU for sale.
Baroness Hayman of Ullock · explaining the NIRMS framework
For some businesses, the additional cost and complexity to apply labels and maintain separate production lines for different markets will not be financially viable, particularly given that NI represents 3% of the UK retail market.
Baroness Hayman of Ullock · on business burden and delisting risk
By mandating 'not for EU' labelling for the much larger GB market, the intention is to incentivise retailers and manufacturers to make the changes necessary for compliance with the smaller GB-NI route.
Baroness Hayman of Ullock · explaining the policy logic of the SI
Phase 3 of NIRMS commences on 1 July 2025, bringing a much greater range of products into scope and potentially increasing the risk of delisting.
Baroness Hayman of Ullock · justifying the timing of the legislation
… we expect that most goods will no longer need to be labelled 'not for EU' in the future. However, achieving such benefits relies on the UK being a reliable partner which delivers on its existing commitments.
Baroness Hayman of Ullock · on the future SPS Agreement and interim compliance obligations
It should be noted that the activation of the SI will be considered as a last resort, where other engagement methods have failed and supply is at risk.
Baroness Hayman of Ullock · on when the contingency power would be used
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Source · parliament.uk record ↗

Correspondence from the Minister for Biosecurity regarding the Marking of Retail Goods Regulations 2025, dated 5 June 2025, | Beyond The Vote | Beyond The Vote